Have you ever seen an aircraft fire extinguisher? If not, they don’t look anything like a regular fire extinguisher. For most of us when someone says, “fire extinguisher”, we imagine some kind of red cylinder with a pin, nozzle, and trigger. But an aircraft fire extinguisher looks like a ball with antennas sticking out. That’s why I call them “funky looking fire extinguishers”.
I was asked if I can assist with shipping out an aircraft fire extinguisher via air for a client. Absolutely I can. The client dropped off the fire extinguisher which was wrapped in bubble wrap. As per the SDS it was classified as UN1956 but for those with equivalency certificates/special permits it can be classified as UN1044. Now since these funky fire extinguishers don’t exactly have the surface area to place the markings and labels, I used a strong tag to affix the label and markings as per Section 184.108.40.206 (d) of the IATA Regulations. I wrapped the fire extinguisher in more bubble wrap in such a way to prevent any accidental activation during transport. I used a strong outer packaging and filled the void space with packing peanuts. Placed all the labels and markings on the outside of the package and send it out the same day with FedEx. The package arrived at its destination nice and early at Continue Reading…
A gentleman called to ask if we can help him ship out a small sample (125mL) of sodium hydroxide via air. I said, “absolutely”! He then asked, “maybe you can send it out as limited quantity?”. He was trained to ship dangerous goods via ground but not air. Folks trained in both modes of transport will agree that sending something using the limited quantity exemption by ground is tremendously different from sending that same product using the limited quantity exemption by air.
Shipping Limited Quantities by Ground vs Shipping by Air
Let’s just say for ground, life is good when you can apply the limited quantity exemption to the shipment. It’s easy and cheaper. Yes, it takes a while to get wherever it is going but that’s what you pay for. Sending the same product for a quantity that falls within the limited quantity exemption for air transport may save you a couple of bucks, but that’s it. The only place to really save some money is on packaging. Sending a product using the limited quantity exemption for air exempts you from using a UN standardized package; however, there are some tests that are required for that package. That’s why I said, “may”.
If you ship this small of a volume on a regular basis then it may be worth doing the tests, but if you only Continue Reading…
In theory this is an easy question. In practice, it can be easy too, or of course, we can make life difficult on ourselves and do some math.
We’ll start with the easy stuff. Look up the commodity in IATA Section 4.2 (a.k.a. The Blue Pages). We’ll use UN1978, PROPANE, CLASS 2.1 as an example. It is forbidden on passenger aircraft and we find a value of 150 kg as a maximum net per package on Cargo Aircraft Only.
Appendix A defines “Net Quantity” as “the weight or volume of the dangerous goods contained in a package excluding the weight or volume of any packaging material.” This means we are only concerned with the weight of the gas, not including the weight of the cylinder.
So that should be easy right? We just have to weigh the full cylinder and subtract the tare weight of the cylinder (what it weighs without the gas). Yes, that’s pretty much it! Using our example, we weigh our propane tank, subtract the tare weight of the tank and so long as that difference doesn’t exceed 150 kg, we’re in good shape.
One final thing to confirm is that the cylinder doesn’t exceed any maximum quantity that may be limited by the country of manufacture. In Canada, this can be referenced using the CSA Standard B339-08.
A question we are often asked at ICC Compliance Center is “how small does a dangerous goods shipment have to be to not be regulated?” Not just limited quantity, not just excepted quantity – totally not regulated. Common sense tells us that, at a certain level, tiny amounts of dangerous goods do not pose a hazard during transport. Unfortunately, until recently, this question was not really addressed directly, other than by using other small quantity provisions, such as limited quantities.
However, the UN Subcommittee on the Transportation of Dangerous Goods has been working on this issue, and the question has started to be answered by various regulations based on the UN Recommendations. For example, starting in 2013, shippers by air who use the ICAO Technical Instructions for the Safe Transport of Dangerous Goods (TIs), and the IATA Dangerous Goods Regulations (DGR), will be able to ship very small amounts of dangerous goods as non-regulated under the so-called “de minimis” provisions.
The 54th Edition (2013) of the DGR has a new section, 2.6.10, which establishes the procedures for shipping as a de minimis quantity. The procedure is as follows:
Look up the goods being shipped on the List of Dangerous Goods (Table 4.2), and check the Excepted Quantity code given in column F. If the code is E1, E2, E4 or E5, the goods can be shipped as de minimis, Continue Reading…
On April 11, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice of proposed rulemaking (NPRM) in the US Federal Register relating to transportation of lithium batteries by air. PHMSA is considering harmonizing the current hazardous materials regulations (HMR) with the requirements that are found in the 2013-2014 ICAO Technical Instructions. PHMSA published an NPRM in January 2010 addressing harmonization to the 2011-2012 ICAO Technical Instructions, but a final rulemaking was not published in relation to that previous NPRM. The new NPRM will incorporate the additional or revised requirements found in the newer Technical Instructions, and will allow interested persons to supplement comments that were submitted previously. The lithium battery provisions recently adopted by ICAO will become effective for international air transport on January 1, 2013. Comments relating to this NPRM are due by May 11, 2012.