Regulatory Helpdesk: March 12

Combustible Liquids, Using Chemtrec’s Number, Keeping Up-To-Date, and Other Paperwork

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.

DG Documentation on Overpacks

Q. If there are multiple skids of dangerous goods (overpacks) in a shipment on which one should the copies of the invoices and shipping papers be attached?
A. Neither the DOT nor IATA regulations tell you to put “paperwork” on the outer packages or overpacks. That is a carrier/driver thing. All the regulations care about is the proper marking and labeling that they require. You also have to be able to physically hand your paperwork to the carrier. Your best bet would be to talk to your carrier directly as to how they want it handled.

Combustible Liquids

Q. I have a liquid with a flashpoint of 100° F and it does not meet any other hazard classes. It is not an RQ, waste or marine pollutant. After manufacturing, it is placed in tubes and then shipped for sale in retail stores. What marks and labels are needed on the outside of the packages?
A. The flashpoint of this material is 100° F and there are no other hazards under the transport regulations. This means it technically meets the definition of a flammable liquid in Packing Group III per §173.120 Continue Reading…
HazMat box with tape gun
Am I Using the Right Tape on my HazMat Shipment? (FAQ)

Man preparing shipment

Frequently Asked Questions About Tape Being Used With UN Boxes

Often times I get questions regarding which type of tape could be used with the various packaging we sell here at ICC Compliance Center. Like many other answers to questions, most of the questions can be answered straight from the regulations. As many of us know, sometimes when it comes to packaging, the regulations may not be specific enough to the questions we have. That’s when I turn to the PHMSA Interpretations for guidance.

What are PHMSA Interpretations?

PHMSA interpretations are written explanations of the hazardous materials regulations by various members of the D.O.T. They come in in the form of letters that are answering specific questions asked by a wide variety of dangerous goods professionals. They are to be used only as a form of guidance when following the regulations.

Do keep in mind that the interpretations that are currently posted in the database reflect the current application of the 49 CFR to the specific questions and may be removed if there are changes to the regulations or deemed inaccurate. The PHMSA interpretation browser can be found on PHMSA’s website.

HazMat Shipment Tape FAQs

Q. Can I put more strips of the tape than what is referenced in the closing instructions along the seam of the box?
A. Yes. Per Interpretation Response #06-0129 at the link below, as long as the specified Continue Reading…
DOT 49 CFR USA
Alternative Ways to Ship Perfume Under 49 CFR

Different bottle of perfume on a wooden table

Shipping Perfume: The Regulations

Every so often our regulatory team is asked a question that on the surface seems funny but in reality, has some interesting facets upon review. For example, can a perfume ever be shipped as anything but a perfume under the 49 CFR regulations? It sounds like a basic question. The short answer is yes. However, when you move through the intricacies of the regulations it can be a quite complex answer dependent on many factors.

Exceptions

Most of us familiar with the regulations would immediately think about the exceptions for small quantities, excepted quantities, de minimis, limited quantities and consumer commodities. However, before we can look at any of those, you need a clear indication of what you are actually shipping. 

For perfume the shipping description is UN1266, Perfumery products, Class 3, Packing Group II or III. There is one special provision that applies for ground shipments on this entry. It is SP-149 that allows the inner container limit to be 1.3 gallons or 5 L when shipped as limited quantity or consumer commodity.

Let’s look at each exception and see if it would apply:

  1. 4 Small Quantity (§173.4). For this exception, we are limited to domestic highway and rail transport only. We also see that our Class 3 material is allowed. The maximum amount allowed per inner container for this exception is 1 oz. or 30 ml.
  2. Excepted Quantity 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…

IATA
How Do You Ship an Engine? (IATA)

Diesel Engine Close Up

How should you provide quantity on a shipper’s declaration for an engine?

Generating a shipper’s declaration for an engine isn’t exactly new to me. I have been creating shipper’s declarations for engines since the very first time I stepped into the DG packaging world, and that was a long time ago. Therefore, it hit me pretty hard when a client’s shipment, containing an engine, was rejected by their air carrier.

Engines and UN Numbers

For many years the UN number for engines and vehicles were the same and it was classified as hazard class 9. Just recently it was changed so that each type of engine has their own UN number and hazard class. Therefore, internal combustion engines containing flammable liquid is classified as UN3528 and falls under hazard class 3.

My client said there was a small amount of diesel fuel inside (it wasn’t drained). Based on this I classified his engine as UN3528. He provided me with the completed shipment detail form which provided me with all the details of the shipment including net weight of the engine and the amount of fuel inside the engine.

Quantity of the Engine on the Shipper’s Declaration

I started to work on the shipper’s declaration and had to stop at the “Quantity and type of packing” section. There wasn’t an immediate measurement I could use for the engine. As per column “J” and 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…

Single Packaging
4G Combination Packaging Dos and Don’ts

Man preparing shipment

Can I Make changes to my 4G Combination Package?

Some time ago, I wrote a blog that outlined the benefits and regulations of the 4GV packaging. Often referred to as Variation 2 packaging, we discussed the main benefit of this packaging is that different types of inner containers can be used whether they are liquid in glass bottles, metal cans, plastic bottles, or different types of solids. But what about non-4GV packaging (basically any combination package that has a UN marking on it that excludes the “V”)?

Can changes be made to the inner packaging? Here are some questions below that will clear up some of the confusion.

Replacing Plastic with Metal

PK-1GRPC Combination Packaging
PK-1GRPC 4G Plastic Container Combination Package
(Learn More)

UN Marking: 4G/Y5.1/S

    • Q. So what we have here is our PK-1GRPC kit. This includes a plastic HDPE bottle and a corrugated box. Can this box also be used to ship dangerous goods with a tin plated paint cans?
    • A. No. This box was tested at the lab with a one gallon HDPE bottle, so in this case you would not be allowed to use this box with any other type of inner container with a different structural design. 178.601 (g) (1) (i) (a) TP14850 8.1.2.3 (a)

Substituting an Insert for Absorbent or Adding Additional Cushioning

PK-NQTCA 4G Combination Packaging
PK-NQTCA 4G Paint Can Shipper (Learn More)

UN Marking: 4G/Y4.0/S

PHMSA Change Notice

Man preparing shipment

PHMSA Issues Notice of Change on Termination of M-Number and R-Number Approvals with no Expiration Date

PHMSA has made a proposal to terminate previously approved M-numbers and R-numbers that were issued without an expiration date. Unless approval holders can either show why their approvals should not be terminated as provided in 49 CFR 107.713(c)(1) or apply for a modification of their approval in accordance with 49 CFR 107.705 prior to the effective date, their M-number may be considered expired. Modified approvals will conform to the Approvals and Permits Division’s standardized format in which all approvals have a 5-year expiration date.

M Number on UN packaging

What is an M-Number?

An “M-Number” or manufacturer number is issued by the D.O.T. to a manufacturer of packaging related to hazardous goods as a means of identification. This number is used in place of the manufacturer’s name and address as authorized in 49 CFR 178.503. In addition, an “R” number was a number previously given to companies that recondition their hazardous goods packaging, but PHMSA now uses M-numbers in their place. Often times the M-number is displayed on the outside of a package (like in the above picture). Manufacturer’s symbols can come in two formats. The first format lists the manufacturers sequentially by Identification Number (M#). The second format lists each state’s manufacturers alphabetically by city and company name. The identification number, the name and address, the status, and Continue Reading…

Single Packaging
UN Specification Packaging Mystery

UN Specification Packaging Mystery

We Got a Mystery to Solve

One of my favorite childhood shows was “Scooby-Doo, Where Are You?”. How he and his group of friends could solve all those crazy hauntings and monsters always amazed me. Nothing made me happier than when the culprit was discovered and he uttered the words, “If it weren’t for you pesky kids, I would have gotten away with it.” After all I was only a kid and catching the bad guys was a big deal.

Occasionally during a training class odd questions or little mysteries arise. In those times I can feel like Thelma from my childhood show tracking down the clues and getting an answer. Here is one from one mystery from a recent training. It came about after our discussion on United Nations (UN) Specification Packaging. We had just finished reviewing all the parts of the packaging codes and discussing the manufacturer’s packing instructions as they apply to 49 CFR – US ground regulations. This lead to talking about their actual facility. Below is a picture of a box they have on site for use. They wanted to know if it was in compliance.

Ah, a mystery I can solve.

UN Specification Packaging Mystery 2

In case you didn’t catch why they asked about this particular box and compliance, take a look at the FOUR package specification codes on the box. For most boxes, there is only one code derived from the Continue Reading…

Single Packaging
Anatomy of a Box

Anatomy of a Box - UN Packaging

Fiberboard’s Organs

As we know, the human body is made up of many essential components, from the smallest microscopic cell to the largest of organs. The same goes for corrugated boxes, but instead of cells, there are tiny fibers, and instead of organs, there is inner fluting. All components are necessary to have strong and sound structure. Let’s take a look at the anatomy of a box.

The Corrugated Fiberboard

What exactly is a box mostly made of? Corrugated fiberboard. The corrugated fiberboard is essentially the skeleton of the box. Made up by thousands of tiny fibers, it is created by a corrugator. A corrugator is a large machine that combines two different kinds of paper to create cut sheets of corrugated fiberboard. The flat, facing sheets are referred to as the linerboard. Linerboard is a thin fiberboard that makes up the outer layer. Flutes are inner arches attached in between the linerboards with a starch based adhesive. They are designed to resist pressure and bending in all directions.

corrugated cardboard linerboard
Linerboard

corrugated cardboard Fluting
Fluting

Together makes Corrugated Fiberboard

Fiberboard box

Corrugated Fiberboard can come with various amount of flutes within the linerboard, usually ranging from single wall to triple wall.

Single Face: Consists of 1 linerboard and 1 flute

Single wall: Contains 2 liner boards and 1 flute.

Double wall: Contains 3 linerboards and 2 flutes.

Triple Wall: Contains 4 linerboards and 3 flutes.

Single, double, and triple walled fiberboard

In addition the outer Continue Reading…