IMDG
How Do You Ship Bullets? (IMO)

shipping bullets by ocean

What to do when you are moving and need to ship a whole lot of bullets?

98% of our repackaging clientele are businesses, but there are 2% of our clientele that are regular people. At least, this is how I refer to them. These folks are a “Mr. or Mrs. Smith” who have absolutely no idea about the dangerous goods world, but what they wish to send is considered dangerous goods. These folks are referred to us from carriers, freight forwarders, and sometimes by internet search results.

Recently I had a Mr. Smith call us to ask about packaging cartridges as recommended by his freight forwarder. He is moving to Europe and is packing up his entire house, which includes his firearms and the cartridges that go with them. He already had all his ducks in a row meaning his export/import documentation and certification for the firearms and whatever else was needed to ship the firearms and cartridges, but he needed to get the cartridges packaged up for transport. That’s where ICC comes in.

What Are We Really Dealing With?

Mr. Smith didn’t have any transport information such as UN number or shipping name. So, I asked him to email me pictures of the cartridges, because he mentioned they were all in their original retail packages. I was able to call the manufacturer directly and ask for the shipping info. Continue Reading…

Excepted Quantities
UPS Excepted Quantities Update

Red semi truck on highway

UPS Makes Changes to its International Special Commodities (ISC) Program

UPS has announced it will be making changes to its International Special Commodifies (ISC) Program which enables selected customers under contract to ship certain prohibited articles.

This initiative has added more than 50 countries that can ship biological substances, shipments utilizing dry ice, and goods in excepted quantities internationally.

What does this Include?

UPS will now pick up and deliver packages containing UN3373 (Biologic Substances, Category B, Diagnostic Specimen and Clinical Specimen) as well as UN1845 (Carbon Dioxide, solid or dry ice) to 51 added countries and territories bringing the total number of countries to over 100.

In addition, the countries that were added to the list can now ship dangerous goods in excepted quantities internationally if authorized by the regulations.

The full list of approved countries can be found here:
UPS – Approved Countries

What is an Excepted Quantity?

Dangerous goods shipped in excepted quantities allow relief from certain regulations in small quantities outlined by IATA in §2.6. Be sure to check IATA for specific details and to use the label below when shipping in excepted quantities.

Excepted Quantity Label
Excepted Quantity Label (LB-USL350N)

Where can I find packaging for UN3373 Category B Specimens and dry ice shipments?

At ICC we have a wide variety of packaging specifically designed for biological packaging as well as dry ice shippers for international shipments similar to the kit below:

[caption Continue Reading…

Regulatory Helpdesk: January 15, 2018

Here are the top 4 questions last week:

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Worded Label Requirements

Q. Are worded labels required for use in US transport?
A. Based on 172.405(a), except where prescribed, wording is optional on US hazard class labels.

Placement of UN Number, Shipping Name and Hazard Class Label

Q. Can you put the “ISH” information (shipping name, UN number and hazard label) on the top of a package (e.g. box)?
A. That depends. Different regulations express it differently, but the key message is that the information must be easily located and read; and with few exceptions in proximity to each other on the same surface of the package. All common regulations (49 CFR, Canadian TDGR, IATA DGR, IMDG Code) have a general requirement for legibility.

49 CFR requires the information to be clearly visible on a surface other than the bottom [172.304(f) and 172.304(a)(i)]- so the top could be allowed if the configuration resulted in it being clearly visible.

IATA DGR and the IMDG Code do not specify top/bottom but only require the information to be “readily visible” [IATA 7.2.6.1(a); IMDG 5.2.1.2.1, 5.2.2,1.6].

TDGR, however, is a little more prescriptive- requiring the information to be “on any side … other than the side on Continue Reading…

Regulatory Helpdesk: January 8, 2018

3 Questions from our Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Disclosing Concentration Ranges Under WHMIS 2015

Q. Do I have to indicate “Proprietary” on a WHMIS (M)SDS when masking actual concentrations with ranges?
A. It depends. WHMIS 1988 accepted the use of concentration ranges on MSDS to mask confidential business information (CBI) without requiring any indication.

WHMIS 2015 does not currently allow the use of ranges other than the concentration range actually present for a variable substance (also, unlike WHMIS 1988, ranges cannot be used to allow a single SDS for a series of different but similar products).

Products subject to an approved masking under the HMIR Act do have to, in both versions, reference the exemption authorization on the (M)SDS.

A CBI amendment under consideration may re-introduce the permissible use of ranges to unilaterally mask actual concentrations. This proposal as currently written requires a statement in the SDS when a range is used that’s wider than the actual concentration range, to protect CBI. We’ll have to wait for the final amendment to answer the question going forward …

IMDG or TDG?

Q. Does a shipment within Canada by vessel from Newfoundland require placarding according to the IMDG Code or do the provisions of the TDGR Continue Reading…
Lithium Battery
Lithium Battery Placarding and Segregation

Lithium Batteries, Laptop battery

Lithium Battery Segregation

It is January and all of the new or updated transport regulations are in full swing. This includes the new IATA addendums and IMDG Code corrigenda that were recently published. That leaves many tracking down what changed in and how those changes could impact business. Add to that dealing with the complexities that come with shipping lithium batteries and many people end up feeling confused like Vincent “Vinny” Barbarino on “Welcome Back Kotter”. Check out that memory.

Here is my attempt to simplify the placarding and segregation requirements as they now stand for lithium batteries. Let’s take a look at each topic and regulation to sort things out.

49 CFR – US Ground

Placarding (§172.504): Class 9 materials are found on Table 2. This indicates that when the gross aggregate weight of the materials in the transport vehicle reaches 1001 pounds (454 kilograms) placards would be needed. In Paragraph (f)(9) there is an exception. The exception tells us that placards are not needed for Class 9 materials shipped domestically. Easy right? Now this paragraph also tells us that should you use a bulk packaging of batteries, we would be required to mark the identification number on an orange panel, a white square-on-point configuration or a Class 9 placard.

Segregation and Separation Chart of Hazardous Materials (§177.848): There is currently nothing in this section of 49 CFR to indicate batteries should be segregated or Continue Reading…

Danger Placard
DG on the Other Side of the World

This slideshow requires JavaScript.

What’s wrong with these photos?

Well, nothing, if you consider where it was taken (a remote town in Thailand).

Even while on vacation, someone in the Dangerous Goods field is always on the lookout for dangerous goods in their environment. I know when I first joined ICC, I never noticed placards on trucks, but soon after it seemed like they were on every transport that passed by. Those blessed to be in our line of work have a heightened awareness for the dangers around us.

As we all know, regulations concerning dangerous goods differ around the globe. As much as we would like to think the regulations are harmonized, they’re really not. Enforcement is the same. There are only so many inspectors available compared to the number of shipments each day.

One has to wonder what training these workers have. Where are the transport labels, the Hazcom labels, and the blocking and bracing?

I feel a lot more comfortable knowing that shipments of gases in the US and Canada will be properly secured when transported, and they will always have proper labels. Regulations are in place for one reason, and that is to protect workers and the community.

ICC is your source for products, services, and training – all under one roof. Call us today.

Repacking Dangerous Goods
Shipping Laptops to Australia

Lithium Batteries, Laptop battery

Shipping Laptops Means Shipping Lithium Batteries

If you were to ship a laptop 5 years ago, all you would need to do was pack it up and ship it. Like shipping socks. But now that same laptop is considered a dangerous good due to the lithium battery it contains.

The Situation

I had a customer drop off 2 laptops going to Australia. He wanted me to prepare the shipment for air transport as he isn’t certified to ship dangerous goods via air. He said he received about 6 pallets of marine vessel equipment returning from Canada to Australia and he said someone put these 2 laptops in one of those pallets thinking it can all go as general cargo. He knew that there are restrictions on shipping lithium batteries via air so he knew he had to call in the expert!

This slideshow requires JavaScript.

The Solution

I removed the battery from the laptop to see the watt hour rating. It was 41-watt hour and the total net quantity of lithium was below 5 kg (well below). Which meant these laptops are classified as Section II for UN3481, Lithium ion batteries contained in equipment; therefore, does not require a shipper’s declaration. It’s always good news for the client when it falls in Section II as it saves the client money.

I placed both laptops inside a good strong box (each laptop was initially Continue Reading…

Repacking Dangerous Goods
Shipping Different Dangerous Goods in One Package

Man preparing shipment

Q Value!

Now doesn’t that sound interesting. When you want to ship different dangerous goods in one outer packaging, you have to calculate something called a “Q value” using a formula. The Q value ordeal is only applicable to air shipments and seldom used as most prefer to put the dangerous goods in separate packaging.

Last week a customer requested to have 2 different dangerous goods packaged and shipped to Brazil via air. Since the quantities for each product was less than 200 ml I thought I might be able to apply the “Q” value and besides it’s always better to consolidate your shipment if you can to prevent loss/delay of packages. Especially this time of the year.

I ensured the dangerous goods met all the requirements of Section 5.0.2.11 of the IATA Regulation. I calculated the “Q” value and it was less than 1.0. So, everything seemed to be a go. For packaging, I used a 4GV box and lots of vermiculite to:

  1. separate the two dangerous goods and
  2. more than enough absorbent in case there was a leak (only one product was liquid)

Applied all the labels and markings, created the shipper’s declaration and added the Q value as required per Section 8.1.6.9.2(f), then shipped it out with Fedex.

I like to throw in a knuckleball once in a while and keep things Continue Reading…

Regulatory Helpdesk: December 11, 2017

Top 4 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

UN Numbers on Explosive Placards

Q.Can the UN number be added to a class 1.4 placard shipping UN0323 ground in the U.S?

A. 49 CFR 172.334(a) States no person may display an identification number on Explosives 1.2, 1.2, 1.3, 1.4, 1.5, or 1.6. In this case 0323 is classified as a 1.4, So it cannot display the ID number.

IMDG Corrigenda

Q. Section 5.3.2.0.1 has changed with the Dec 2017 Corrigenda to the IMDG. Why would you need to put a proper shipping name on a CTU when a placard is all that is really required?

A. First of all that section speaks specifically to 3 situations where information beyond a placard is required. The 3rd one really doesn’t exist anymore, but the first 2 do. The first is when you have a TANK cargo transport unit. Tanks as defined in Section 1.2 are those that are portable tanks, road tank-vehicles like gasoline highway trucks, and rail tank-wagons which are those rounded rail cars that you see. The second is when you have bulk containers. For either of these situations a placard is needed as well as the PSN. Given the corrigenda the height Continue Reading…

ICC Top 10 List
10 Things That Might Put You on Santa’s Naughty List

Presents under the Christmas tree

Shipping Dangerous Goods During the Holiday Season

If you ask for any of these things for Christmas, Santa may not be happy. All of the items below are in one-way or another, regulated as Dangerous Goods under the IATA regulations, thus, they cannot simply be placed in Santa’s sleigh. I wonder if Santa has a Dangerous Goods Coordinator or is current on his training.

10. Perfume

Most perfumes are flammable. Santa may be able to use the Limited Quantity exemption, but it will still need a label and a completed Shipper’s Declaration form.

9. Oil-based paints

Hoping to get some paint from Santa this year? Paints are also flammable, and depending on the flashpoint and volume per package, may have to be shipped fully regulated.

8. Hoverboards

Asking for a hoverboard will certainly put you on the naughty list. Most hoverboards are manufactured in China, and many do not have Lithium Battery Test data (UN 38.3). Furthermore, depending on the Watt Hour rating, these may not even be able to be shipped in his sleigh!

7. Vanilla Extract

Hoping for some Vanilla to replenish your stock after making all those cookies for Santa? Vanilla, in its concentrated form is flammable. Let’s hope the bottle is small enough to get an exemption such as those under excepted, de minimis or limited quantity.

6. Nail Polish or Nail Polish Remover

It might be better to have your nails done Continue Reading…