Regulatory Helpdesk: February 19 & 26

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…

Single Packaging
Change Notice: BX-23D (PK-MT122)

In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to BX-23D (PK-MT122).

  1. The clear tape required for closure of this packaging has changed from 3M #305 48mm wide clear tape to 3M #375 48mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.

Click here to view our packing instructions and certificate downloads »

If you have any questions or concerns, please contact our customer relations center at 888-442-9628 in the USA, 888-977-4834 in Canada.

Thank you,
Michael S. Zendano
Packaging Specialist

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…

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…
Danger Placard
DG on the Other Side of the World

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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!

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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…

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…

Single Packaging
Change Notice: BX-8SP

In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to BX-8SP.

  1. The maximum gross weight allowance for this design has been increased from 4.2 kg to 5.4 kg. The specification marking that is printed on the boxes has been updated to reflect this change.

Click here to view our packing instructions and certificate downloads »

If you have any questions or concerns, please contact our customer relations center in the US at 888‐442‐9628 or in Canada at 888‐977‐4834.

Thank you,
Michael S. Zendano
Packaging Specialist

Regulatory Helpdesk: November 27, 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.

Lithium Battery Special Provision

Q. Why is only a reference to Packing Instruction Section IB required on a lithium battery Shipper’s Declaration – what about shipments made under Section I or IA?
A. Sections I and IA refer to fully regulated shipments so it’s redundant to indicate an authorization unless there’s a special provision deviation involved.

Although Section II shipments don’t require a Shipper’s Declaration document, if an airwaybill is used a notation must be made indicating the Section II status like “Lithium ion batteries in compliance with Section II of PI— CAO”.

This is particularly true for UN3090 or UN3480 where the document is required to indicate the CAO status.

Shippers also need to verify any listed state or operator variations that may require information over that mandate by IATA DGR.

Determining the Size of the Package

Q. I have a customer who wants a “portable tank” of product instead of our usual smaller sized containers, can I oblige?
A:

  • Characterize your product,
  • read the container supplier’s specification,
  • read the relevant regulation,
  • read the cited container standard; review 1. & 2. in the context of 3. & 4; decide on any required modifications.

Shipping Continue Reading…