Welcome to the ever-changing world of transporting lithium batteries. It feels like just yesterday we were discussing the introduction of the new Class 9 hazard label dedicated to just batteries and the new handling “mark”. Would you believe that started at the end of 2016? In an attempt to clarify things, here is the first of several blogs dedicated to one of the new versions of a transport regulation. The focus will be what changed in regards to lithium batteries for that mode. My first choice, only because it is my favorite regulation, is the 60th edition of the International Air Transport Association or IATA as many of us know it. By the way, ICC will be hosting a training on lithium batteries on January 24th and 25th. Call us today to get registered today.
Listed below are the specific sections, paragraphs, packing instructions and the like that had changes for lithium cells and batteries. If you aren’t overly familiar with shipping batteries, what is below can be a bit overwhelming. You can access our “cheat sheet” for required labels by ground, ocean, and air.
60th Edition Changes for Batteries:
New classification criteria – As part of 220.127.116.11.1 there are 2 new paragraphs around the classification of lithium batteries. One paragraph talks about “hybrid” batteries, which are those that contain both ion and metal while the other is about Continue Reading…
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.
Q. We have a customer that is asking why the VOC content is “N/Av” on their SDS. It is required under OSHA or WHMIS?
A. According to US federal OSHA Hazcom 2012, and Canadian WHMIS 2015 rules, VOC information is not actually a mandatory item to appear in any section of a 16 Section SDS. It is commonly requested as a sub-item in Section 9, which is why ICC automatically includes the subheading. ICC does not calculate VOC levels, so the data would have to be provided by you. VOC information is common info to have for coatings, and has become important for coatings manufacturers due to Environmental regulations.
Lithium Battery Mark
Q. Customer called and asked if they ship UN3480 lithium batteries ground within the US, can they use the lithium battery mark instead of the class 9 lithium battery label, or do both have to be on the package. He also wanted to know what packing group lithium battery packaging had to be?
A. When shipping ground within the US, you are required to use a lithium battery mark OR a Class 9 lithium battery label. So just the lithium battery mark is fine in Continue Reading…
Shipments to Puerto Rico, Non-hazardous substances, the Overpack label, and Aviation Regulated Liquids or Solids
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.
Shipping to Puerto Rico
Q. If 49 CFR is used to make a vessel shipment of limited quantities from the mainland US to Puerto Rico is a shipping paper required? I’m asking because limited quantities don’t require shipping papers.
A. Technically that is true. Shipping papers are not needed for US GROUND shipments. You have to read the fine print in paragraph 173.150(b) which is the section on limited quantities for flammable and combustible liquids. It that paragraph it says, ” … is not subject to the shipping paper requirements of subpart C of part 172 of this subchapter, unless the material meets the definition of a hazardous substance, hazardous waste, marine pollutant, or is offered for transportation and transported by aircraft or vessel, and is eligible for the exceptions provided in §173.156 of this part“.
Non-hazardous substances under WHMIS 2015
Q.Customer called and asked if SDS’s were required for non-hazardous substances and where to find this in the WHMIS 2015 Regulations?
A.The answer to your question can be found below in WHMIS 2015, which states that safety data sheets only pertain to a hazardous product, therefore Continue Reading…
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.
Q. Section 18.104.22.168.1 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…
The formalization of the overpack concept into the Canadian TDG regulations has been the subject of concern for domestic shippers of dangerous goods due to the wording for fully regulated (TDGR 4.10.1) products. The wording implies that even when the DG safety marks for packages within the overpack are visible, the overpack must still have an “OVERPACK” mark displayed. This leads to some additional labelling requirements, particularly for shippers of stretch-wrapped pallet loads.
We’ll pause to review the concept of an overpack, consistent among the various regulations (e.g. TDG, UN Model Recommendations, IMDG, IATA, & 49 CFR).
An overpack is non-standardized packaging that:
Is used for handling convenience (e.g. to reduce multiple handling- I.e. 4 drums on a skid, allowing loading 4 at once rather than 4 trips, or 6 small containers in a “non-spec” master carton, or 48 small boxes stretch wrapped on a skid; a keg (small drum) in a non-spec box for stability, etc. )
Cannot be used as a replacement for inadequate, required “standardized” packaging
Is to be unopened between consignor and receiver
Cannot interfere with the integrity of the standardized packaging (e.g. banding cutting into boxes on a pallet)
The common principle requires that the description of DG that cannot be seen once the overpack is in place will be reproduced on the outside of the overpack.