Q&A: Why does the E3 code indicate a dangerous good is not eligible for the De Minimus exception?

My reply the same day (12.23.20):

Thank you for contacting me. I will try to answer your question below.

I presume you are referring to the De Minimis Quantities exception of the International Air Transport Association (IATA) at 2.6.10 of the IATA Dangerous Goods Regulations. While there is a similar De Minimis Quantities exception at 49 CFR 173.4b in the Hazardous Materials Regulations of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA), the domestic regulations do not use the “E codes” as do those of IATA.
The “E codes” (E0, E1, E2, E3, E4, & E5) are found in column F of the List of Dangerous Goods. Their primary purpose is to identify the limits of the Excepted Quantity exception.
Once the E code is determined for a dangerous good the shipper or packer is directed to 2.6 of the IATA Dangerous Goods Regulations to determine the inner and outer packaging quantity limits and packaging requirements for transport as an Excepted Quantity.
Within 2.6 at 2.6.10 are the requirements for transport subject to the De Minimis exception. There, as noted above, the De Minimis exception is limited solely to dangerous goods associated with the E codes of E1, E2, E4, & E5.

Why not E3?

I don’t know for certain why E3 is excluded from eligibility for the De Minimis exception.
However, I can surmise it is not due to the quantity limits but more likely due to the type of dangerous good that is assigned the E3 code. It is possible that the dangerous good assigned E3 as an excepted quantity is not acceptable to ship by air as DeMinimis.
I did a quick review of most of the List of Dangerous Goods and discovered that every E3 code in column F was associated with a Class 3 Flammable Liquid in Packing Group I.

I hope that helps. Please contact me with any other questions.

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The reply:

Thanks for giving this a shot – we kinda went in a circle – I did the same. Have wonderful holiday

Conclusion:

Not every answer has a satisfactory answer in the regulations. Though I couldn’t answer this “why?” question, I’m sure I’ll be able to answer and “how” question you may have about the transportation of dangerous goods or hazardous materials.

Significant Changes and Amendments to the 62nd Edition (2021) of the IATA Dangerous Goods Regulations

The International Air Transport Association (IATA) publishes a new edition of its Dangerous Goods Regulations for each calendar year. In effect for the remainder of calendar year 2020 is the 61st edition. Beginning January 1, 2021 all transport of dangerous goods subject to IATA’s Dangerous Goods Regulations must be in compliance with the 62nd edition. The purpose of this article is to summarize the significant changes in store for 2021 in the 62nd edition.

Before we begin…

UPDATE: On January 18, 2021 IATA posted it’s first Addendum to the 62nd Edition of the IATA Dangerous Goods Regulations. These revisions are effective as of January 1, 2021.
UPDATE TO THE UPDATE: On February 23, 2021 IATA posted Addendum II to the 62nd Edition of the IATA Dangerous Goods Regulations. These revisions are effective January 1, 2021.
The IATA Dangerous Goods Regulations is a “field manual” of the Technical Instructions of the International Civil Aviation Organization (ICAO).
The ICAO Technical Instructions are updated every two years. However, the IATA Dangerous Goods Regulations are updated every calendar year due to frequent changes within the airline industry and a desire for greater safety and efficiency in air transportation of dangerous goods.
What’s inside the IATA Dangerous Goods Regulations? Good question:
The 62nd Edition of the IATA Dangerous Goods Regulations is effective from January 1, 2021 to December 31, 2021
- Section 1 – Applicability: shipper and operator responsibilities, training, security, incident reporting
- Section 2 – Limitations: forbidden and hidden goods, storage and transport quantities, transport by post, transport by passengers/crew, limited quantity exception, excepted quantity exception, State and operator variations
- Section 3 – Classification: defining criteria of hazard classes and divisions, multiple hazards, Packing Group
- Section 4 – Identification: list of dangerous goods (blue pages), numerical cross-reference list, special provisions
- Section 5 – Packing Instructions (yellow pages): Packing instructions – fully regulated and limited quantity – for all dangerous goods by passenger and cargo aircraft (PAX) and cargo aircraft only (CAO)
- Section 6 – Packaging Specifications: inner packaging, UN, construction and testing, limited quantity
- Section 7 – Marking and Labeling (pink pages): package marks, hazard labels, handling labels
- Section 8 – Documentation (more pink pages): shipper’s declaration for dangerous goods, air waybill
- Section 9 – Handling: storage, loading, inspection, information provision, reporting, training, document retention for operators (air carriers)
- Section 10 – Radioactive material (a few more pink pages): transport, limitations, classification, identification, packing, testing, labelling, documentation, handling
- Appendices: A-I
- Index

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If a visual will help, watch this short video describing the IATA Dangerous Goods Regulations.

Scope and Applicability:

As noted above, this article will only address the significant changes to the 62nd Edition of the IATA Dangerous Goods Regulations for 2021.
This article is only a summary of a document available on the IATA website: Significant Changes and Amendments to the 62nd Edition (2021). Read it for a more thorough description of these changes and amendments for 2021.
Even the document available from IATA is not meant to be an exhaustive listing of all changes to the 62nd Edition. Make sure you do your research to confirm compliance.
This short video explains the reference marks used in the IATA Dangerous Goods Regulations to indicate changes to the DGR from the previous edition.

Significant Changes and Amendments to the 62nd Edition of the IATA Dangerous Goods Regulations for 2021:

Section 1 – Applicability

1.5 – Training Requirements. The training requirements have been revised to implement a competency-based approach to dangerous goods training and assessment. These changes were originally shown in Appendix I – Impending Changes of the 61st Edition (2020) and are now found in subsection 1.5 of the 62nd Edition for 2021. During a two-year transition period (until December 31, 2022) the training requirements from the 61st Edition may continue to be used. For this reason subsection 1.5 from the 61st Edition has been moved to Attachment A of Appendix H in the 62nd Edition.

Competency-based training is an effort by IATA to provide training focused on the key competencies and skills that each employee needs in order to perform specific tasks in the packaging, loading, and shipping of dangerous goods by air. What it means is that as of 12.31.22 your IATA Dangerous Goods training will have to change.

Other changes were made to the list of exceptions at 1.2.7 to include dangerous goods required for preservation of organs intended for transplant and pest management activities and new entries were added to the indicative list of high consequence dangerous goods in Table 1.7.A.

Section 2 – Limitations

Subsection 2.3 – revised to allow for passengers to carry the following dangerous goods:

Nickel-metal hydride or dry batteries
Self-inflating safety device and spare gas cartridges
Portable electronic devices (PED) and spare batteries for PED

Subsection 2.4 – revised to clarify the packing instructions (PI 954) required when dry ice is used as a refrigerant for UN3373 (Biological substance, category B) when the dangerous good is to be transported by post.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Section 3 – Classification

3.6.2.5 – revised to add a new criteria to address solid medical waste containing Category A infectious substances.
3.8.2 – revisions to the criteria for assignment of Packing Groups to corrosive substances and mixtures.

Section 4 – Identification

Several amendments to the List of Dangerous Goods in subsection 4.2. Including:

Addition of UN0511, UN0512, & UN0513 for Detonators, electronic in divisions 1.1B, 1.4B, and 1.4S respectively
Addition of new proper shipping name, Dangerous goods in articles to UN 3363
Addition of UN3549 for Medical waste, Category A, affecting animals or humans
UN2216, Fish meal, stabilized is no longer forbidden. It is now permitted on both passenger aircraft and cargo aircraft only
Packing instruction number for UN3291, Biomedical waste, n.o.s., Clinical waste, unspecified, n.o.s., Medical waste, n.o.s., and Regulated medical waste, n.o.s. has been changed from PI 622 to PI 621
“Stabilized” was added to the proper shipping name for UN2522, 2-Dimethylaminoethyl methacrylate

Amendments to special provisions in subsection 4.4 include:

Inclusion of the State of the operator as an approving authority (previously it was only the State of origin) for lithium batteries shipped under special provisions A88 (prototypes) and A99 (more than 35 kg OK for cargo aircraft only).
Special provisions A88 and A99 revised to require the packing instruction number shown on the Shipper’s Declaration be the one identified in the special provision from the Supplement to the ICAO Technical Instructions: PI 910 for A88 and PI 974 for A99.
To reflect the addition of a new proper shipping name to UN3363 (Dangerous goods in articles), the words “machinery or apparatus” in special provision A107 were replaced by “article”.
Revisions to A145 for waste gas cartridges and waste receptacles, small, containing gas.
Significant revisions to A154 to address transport of damaged and defective lithium batteries.
Revision to A201 to allow for the transport of lithium batteries as cargo on passenger aircraft if urgent medical need and with approval of State of origin and operator.

New special provisions:

A215 permits shipper to use a listed proper shipping name as the technical name for UN3077 and UN3082.
A219 (assigned to UN2216, Fish meal, stabilized) specifies antioxidants must be added to fish meal to prevent spontaneous combustion.

Section 5 – Packing

5.0.2.5 – new text added clarifies a packaging may meet more than one tested design type and may bear more than one UN specification mark.

Revisions to packing instructions include:

PI 378 and PI 972 – permits fuel tanks of machinery to have up to 1/4 of a tank of fuel where the machinery cannot be loaded other than upright.
PI 457, PI 463, PI 465, PI 470, PI 471, PI 479, PI 482, PI 490, PI 491, and PI 555 – single packagings permitted by these packing instructions now align with those permitted in the UN Model Regulations and elsewhere in the DGR.
PI 492, PI 870, PI 971, and PI 972 – cells and/or batteries must be packed directly into the outer packagings.
PI 622 – renumbered to PI 621 to align with the UN Model Regulations.
PI 650 and PI 959 – diamond-shaped mark with the UN number must appear on one side of the package.
PI 956 – includes reference to UN 2216, Fish meal, stabilized.
PI 957 – allows for both combination and single packagings.
PI 962 – includes reference to the new proper shipping name Dangerous goods in articles and to use “article’ or “articles” in place of “machinery or apparatus”.
PI Y963 – a unit load device prepared by a single shipper may contain dry ice as a refrigerant for consumer commodities.
PI 965 to PI 970:
- damaged or defective lithium cells or batteries are forbidden for air transport.
- when section II of packing instructions are followed and packages from multiple packing instructions are on one air waybill, the compliance statement may be combined into a single statement. Examples are included in 8.2.7.
PI 967 and PI 970:
- equipment must be secured against movement in the outer packaging.
- multiple pieces of equipment in a package must be packed to prevent damage due to contact with other equipment in the package.

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Section 6 – Packaging Specifications and Performance Tests

Revisions to Section 6 include:

6.0.4.1 and 6.5.3.1 – clarification of size of UN specification marks on packagings.
6.0.4.2.1(f) – clarification of the application of the year of manufacture for plastic drums and jerricans.
6.0.7 – new provision for packagings tested to more than one design type.
6.1.7.2 – revision to maximum capacity for metal aerosols.
6.2.2.7 and 6.2.7.7 – suitable internal protective coatings or treatments must be applied to aluminum and other metal drums if not compatible with contents. This provision already exists for steel drums and steel and aluminum jerricans.
6.4.2 – revisions to the ISO references for UN cylinders and closed cryogenic receptacles.

Section 7 – Marking and Labelling

7.1.4.4.1 – the height of the UN/ID number and the letters “UN” or “ID” on packages may be smaller than 12 mm depending on the size of the package.
7.1.5.5.3 – minimum dimensions of lithium battery mark have been revised.

Section 8 – Documentation

8.1.6.9.2, Step 7 – requirements for description of multiple overpacks on Shipper’s Declaration revised. An additional example is provided at Figure 8.1.Q.
8.2.1 – statement required on the air waybill when dangerous goods are offered on a Shipper’s Declaration revised to align with the language used on electronic documentation: Shipper’s Declaration is not “attached” but is “associated” with the air waybill. There is a two year transition period during which time either wording is acceptable.

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Section 9 – Handling

9.1.9 – now mandatory (previously recommended) that operators include the transport of dangerous goods as part of their safety risk assessment process.
9.6.4 – requirement to provide report to State of origin deleted.

Section 10 – Radioactive Materials

Revisions to Section 10 include:

10.0.1.1 – provisions for transport are based on Revision 1 of IAEA Safety Standards Series No. SSR-6.
replacement of “radiation level” by “dose rate”.
Table 10.3.1 – addition of new radionuclides for Germanium, Iridium, Nickel, Strontium, and Terbium.
10.8.8.1 – revision to statement on the air waybill when dangerous goods are offered on a Shipper’s Declaration.

Appendix A

Changes, deletions, and additions in the glossary include:

addition of definitions for carry-on and checked baggage.
addition of definition for detonators, electronic.
addition of definition for dose rate.
deletion of “radiation level”.
revision to the definition for self-accelerating decomposition temperature.

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Appendix C

Table C.2 – changes to the list of currently assigned organic peroxides.

Appendix D

updates to contact information for competent authorities.

Appendix E

E.1 – changes to list of UN Specification Packaging Suppliers.
E.2 – changes to list of Package Testing Facilities.

Appendix F

revisions to list of Sales Agents (F.2), IATA Accredited Training Schools (F.3 – F.5) , and IATA Authorized Training Centers (F.6).

Appendix H

guidance material on development and implementation of competency-based training for dangerous goods has been revised based on input from training providers and member airlines.
Subsection 1.5 from the 61st Edition has been moved to Attachment A in Appendix H.

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Step 1: Purchase the 62nd Edition (2021) of the IATA Dangerous Goods Regulations

Step 2: Review the regulations to identify any changes from the previous edition that affect your compliance.

Step 3: Contact me for in-depth site-specific IATA Dangerous Goods Training.

Calculating the “Q” Value for Different Dangerous Goods in a Single Outer Packaging (All Packed in One)

The Dangerous Goods Regulations (DGR) of the International Air Transport Association (IATA) at 5.0.2.11 allow for the transportation of different dangerous goods in a single outer packaging (aka: all packed in one). A particular challenge when packing different dangerous goods in a single outer packaging is to comply with the dangerous good’s per package quantity limits found in the following columns of the List of Dangerous Goods at 4.2:

Column H for limited quantity
Column J for passenger and cargo aircraft
Column L for cargo aircraft only

In order to ensure the per package quantity limits are not exceeded IATA requires the shipper/packer of the dangerous good to calculate its “Q” value. The purpose of this article is to explain how to calculate the “Q” value of a package containing different dangerous goods to ensure compliance with the per package quantity limits of the IATA Dangerous Goods Regulations. (more…)

Q&A: Must I list all overpack codes separately on the Shipper’s Declaration for Dangerous Goods?

Question:

Hi, Daniel, we have an IATA question for you.

Note:

Note: IATA is the International Air Transport Association. It’s Dangerous Goods Regulations – updated annually – contain all of the requirements of the International Civil Aviation Organization’s (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air. It is applicable to all airlines that are members of IATA and “all shippers and their agents that offer consignments of dangerous goods to these operators.” If you offer a hazardous material for transport by air, you will likely have to comply with the IATA DGR.

When we have multiple identical overpacks of the same dangerous good, could we put on the declaration “A1 through A33” instead of listing each A1, A2, etc.?

Shipper's Declaration of Dangerous Goods

Here’s how they were doing it: listing each overpack separately by its identification mark.

I think we cannot, but wanted verification. But if we can- it would simplify our warehouse manager’s life.

Thank you!

My reply:

Yes you can. Please see below for a more thorough answer.

To facilitate identification, loading, and notification, the operator requires an overpack to show an identification mark (which may be any alpha-numeric format) and the total quantity of dangerous goods. This information must also be entered on the Declaration. The total quantity of the Declaration must match the total quantities shown on the overpack.
Step 7 of 8.1.6.9.2 describes the requirements for completing the second sequence of the Shipper’s Declaration for Dangerous Goods: Number and Type of Packagings, Quantity of Dangerous Goods when dangerous goods are packed in an overpack – or multiple overpacks.
Step 7 of 8.1.6.9.2 does not address your situation directly. It does refer to Figure 8.1.N Example 10 which does.
Figure 8.1.N Example 10 displays a situation of four (4) overpacks with identical contents. On the Declaration it is described as follows:

So, it is acceptable to display the overpack identification marks as a range instead of displaying each identification mark separately.
Also, it is not necessary to display “Marine Pollutant” on the Declaration unless it is a bulk packaging.
- The IATA Dangerous Goods Regulations do not require any additional description for a marine pollutant.
- USDOT/PHMSA Hazardous Materials Regulations require an additional description for a marine pollutant transported by air but only if in a bulk packaging. Since the dangerous good is not in a bulk packaging, it does not require any additional description on the Declaration.

I hope this helps. Please contact me with any other questions.

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Read the FAA press release of January 24, 2020

Conclusion:

And that did it! If you are offering a package of a dangerous good to be transported by aircraft you must comply with the IATA Dangerous Goods Regulations (be sure you have the latest Edition!). Also, if the air transport begins and/or ends in the U.S. you must also comply with the USDOT/PHMSA Hazardous Materials Regulations (updated every six months!) Both of these regulations require that you provide training for any personnel with a direct effect on the safe transportation of the dangerous good. Let me help you to meet these training requirements!

FAA Proposes $120,000 Civil Penalty Against UPS

The Bullet:

The U.S. Department of Transportation’s Federal Aviation Administration (FAA) proposes a $120,000 civil penalty against UPS, Inc., of Atlanta, GA, for allegedly violating the Hazardous Materials Regulations.

The FAA alleges that UPS, performing a shipper function, knowingly offered a shipment containing lithium batteries to the company’s UPS Airlines for transportation by air from Ontario, CA, to Louisville, KY, on Nov. 15, 2018.

Who:

The Federal Aviation Administration (FAA) is one of thirteen (13) administrations and bureaus within the U.S. Department of Transportation (USDOT).
- FAA contact: Allen Kenitzer / 206-231-2035 / allen.kenitzer@faa.gov
United Parcel Service (UPS) is an American multinational package delivery and supply chain management company. Its headquarters are in Atlanta, GA

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What:

The FAA alleges the shipment of lithium batteries violated the following regulations of the HMR:
- Shipment of lithium batteries was not properly packaged.
- Shipment was not accompanied by a Shipper’s Declaration for Dangerous Goods, and was not properly described, marked or labeled to indicate the hazardous nature of its contents.
- The FAA also alleges UPS failed to include emergency response information with the shipment.
Employees at the UPS facility in Louisville examined the contents of the shipment and discovered that it contained multiple loosely packed lithium batteries which had no protection from short circuit, were damaged, and several of which were in a reactive state, the FAA alleges.

Where:

Consignment was offered for transport in Ontario, CA. For delivery to the UPS facility in Louisville, KY.

When:

Consignment of lithium batteries was offered for transport on November 15, 2018.
FAA press release: January 24, 2020
UPS has 30 days after receiving the FAA’s enforcement letter to respond to the agency.

Why:

Lithium ion (and lithium metal) batteries that are damaged, defective and likely to generate a dangerous evolution of heat are forbidden for air transportation on cargo and passenger carrying aircraft.

How:

The FAA does not create the Hazardous Materials Regulations – that’s the job of another administration within the USDOT: the Pipeline and Hazardous Materials Safety Administration (PHMSA) – but it does enforce the HMR when a hazardous material is transported by air.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Conclusion:

Even big companies make mistakes. Another reason why the person who offers a HazMat for transportation (the shipper) should not rely on the carrier to ensure compliance with the regulations. Only knowledge of the regulations and the biennial training required by IATA (USDOT/PHMSA requires training every three years) can keep your company from facing civil penalties like the one now faced by UPS.

Q&A: How do I classify a Class 3 Combustible Liquid for both international and domestic transport?

This e-mail was sent from a contact form on Daniels Training Services (https://danielstraining.com) on December 05, 2019

Hello,

I am trying to name a chemical for transport. It has a flashpoint of 81 C. It is not a US DOT marine pollutant, but it is an IMDG marine pollutant. We ship in both bulk and non-bulk packaging, both domestically and internationally. I believe the US DOT name would be NA1993, combustible liquids, n.o.s. (name), 3, III -is that correct?

I am having a hard time with the IATA and IMDG name. Would those still be the NA1993? I know that NA1993 isn’t recognized internationally, so I am little confused as how this should be named. Any help you can provide with the naming would be greatly appreciated!!

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My reply December 10th:

Thank you for contacting me. I apologize for my delay. I will review and reply. Please advise on the below.

What is the chemical? Do you have an SDS?
What makes it an IMDG marine pollutant?
What is the expected capacity of the packaging: <5 L / 5 kg? <119 gallons? >119 gallons?
Does transport begin or end in the U.S.?

Thank you and please advise.

Answer:

Hello Daniel,

Thanks for taking the time to help me with this!!

The product is a blend of basic epoxy resin (casRn 25085-99-8) and Oxirane, 2-(butoxymethyl)- (casRn 2426-08-6); flash point 81 °C
No, we do not have a SDS. We are trying to make one and the SDS author asked me to assist in the naming.
It is IMDG marine pollutant because it meets the UN model regulation criteria for classification as a Chronic Aquatic Toxicity Cat 2.
When we make a SDS, we include the names for each package type and mode of transport. We ship 1L to 20L/5 gallon samples, 55 gallon drums, and 275 gallon totes
- 1L to 5 gallon samples ship by ground or air both domestically and internationally
- 55 gallon drums and 275 gallon totes ship by ground domestically and by vessel internationally
Transport begins in the US

Thanks,

Interested in site specific training at your site that covers this topic, and more!

Ask me about my Onsite Training

It was after Christmas, (12.27.19) but I got him an answer:

I will try to answer you questions. Please see below.

Based on the flash point it is a Class 3 Combustible Liquid per USDOT regulations.
A material with a flash point higher than 60 degrees C is not subject to international regulations (IATA or IMO).
Based on your information it is not a marine pollutant per USDOT regulation but is a marine pollutant per international regulations.
A combustible liquid is not subject to USDOT regulation if transported by highway or rail within the U.S. and in a non-bulk packaging (and other conditions).
A non-bulk packaging of this material is not subject to USDOT regulations within the U.S. In a bulk packaging it is a Class 3 Combustible Liquid. NA1993, combustible liquids, n.o.s. (name), 3, III may be the proper shipping description if a more specific name is not available. There may be other shipping names that are more descriptive of the HazMat.
The material is subject to international regulation as a marine pollutant unless subject to the marine pollutant exception (packaging of less than 5 L or 5 Kg).
USDOT regulations allow a non-HazMat to be classified as a marine pollutant within the U.S. if subject to international regulation as a marine pollutant.

Also:

Section 14 of the SDS is not required to be completed within the U.S.

My suggestion:

Classify as marine pollutant for all transport.
Classify as Class 3 Combustible Liquid only when in bulk packaging within the U.S. All other transport is non-HazMat.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Read:

I hope this helps. Please don’t hesitate to contact me with any other questions.

His reply December 30th:

Thanks Daniel! This was very useful!!

FAQ: How can lithium batteries be effectively protected against short circuit?

All regulations pertaining to the transport in commerce of lithium cells and batteries share a requirement that the cell or battery be packaged in a manner to prevent short circuits during transportation. Left unsaid by the regulations is how this is to be accomplished.

From the IATA 2019 Lithium Battery Guidance Document, Revision 1:

Methods to protect against short circuit include, but are not limited to, the following:

Pack each battery or each battery-powered device when practicable, in fully enclosed inner packagings made of non-conductive material (e.g., a plastic bag).
Separate or pack batteries in a manner to prevent contact with other batteries, devices, or conductive materials (e.g., metal) in the packaging.

And…

Ensure exposed terminals or connectors are protected with non-conductive caps, non-conductive tape, or by other appropriate means.

It is also important the battery terminals are protected from damage.

If not impact resistant, the outer packaging must not be used as the sole means of protecting the battery terminals from damage or short-circuiting.
Batteries should be securely cushioned and packed to prevent shifting which could loosen terminal caps or reorient the terminals to produce short circuits.

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Methods to protect battery terminals in packagings include but are not limited to the following:

Securely attach covers with sufficient strength to protect terminals.
Package the battery in a rigid plastic packaging.
Construct the battery with recessed terminals or otherwise protected to prevent damage to the terminals if the package is dropped.

Are there more regulatory requirements for the packaging, hazard communication, and transportation of lithium cells and batteries. Yes. A lot more.

Q&A: Can we ship a hydrogen peroxide solution by highway? By air?

Question (March 08, 2018):

We intend to ship a hydrogen peroxide solution, 20-40% w/w, via roadways. We are getting conflicting information on the required labeling. Is an oxidizer warning label required? Thanks

My answer:

Thank you for contacting me. Please see below.

Shipping description: UN2014, Hydrogen peroxide, aqueous solutions with not less than 20 percent but not more than 40 percent hydrogen peroxide (stabilized as necessary), 5.1 (8), PG II
Per column 6 of the Hazardous Materials Table the label codes to be displayed on a package of this HazMat are: Division 5.1 Oxidizer and Class 8 Corrosive.
Division 5.1 is the primary hazard and Class 8 is the subsidiary hazard but this does not affect the display of the labels on the package.
There are no special provisions in column 7 of the Hazardous Materials Table that will change this classification if the HazMat is to be transported by highway.
Of course, there are other requirements its transportation, to include:
- Package marks.
- Vehicle placards.
- Shipping paper.
- HazMat Employee training.
- More…

I hope this helps. Please don’t hesitate to contact me with any other questions.

A follow-up question on April 04, 2018:

Thank you for your response. Can this material be shipped via air? If so, are there restrictions? Thanks again for your help.

My reply that same day:

Yes it may be shipped by air. Please see below.

Air shipments must comply with the IATA Dangerous Goods Regulations.
The IATA DGR classifies the material in the same manner as the USDOT/PHMSA does above.
It is limited to no more than 1 liter per package if transported by passenger air and no more than 5 L per package if transported by cargo aircraft only.
There are packing instructions specific to the type of aircraft.
IATA has its own training requirements separate from those of USDOT/PHMSA.

Please contact me if you have any other questions.

That seemed to do it!

It’s not uncommon for people to contact me wondering if something can be shipped – i.e., offered for transportation. Usually it can, but there will be regulations affecting its transport in commerce. As the shipper of a HazMat it is your responsibility to identify and comply with those regulations. Allow me to assist you.

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Q&A: What is the required size of the new Class 9 Lithium Battery label?

This question came to me over a year ago (January 14, 2018). A time when the Class 9 Lithium Battery label was not yet mandatory but the question of its size was still important. Since January 1st of 2019, when use of the label became mandatory for regulated shipments of lithium batteries, it is more critical still.

Hello Daniel,

I have a query about Class 9 Lithium Battery Label that what is the Size of the label to be printed?

I found somewhere mentioned 100 mm x 100 mm, is this diagonal or edge dimension? What if the box size is smaller to print this size what is the smaller size can be printed?

The mandatory Class 9 label for regulated packages of lithium batteries after 01.01.19.

Thanks & Regards,

My reply the next day (01.14.18):

I believe I have an answer for your question. The answer depends upon the mode of transportation and the applicable regulations. Please see below.

USDOT/PHMSA for the transport of HazMat within the U.S. (usually limited to highway or rail):

The Hazardous Materials Regulations of USDOT/PHMSA at 49 CFR 172.407(c)(1) require the hazmat label to be at least 100 mm (3.9″) on each side. There are 4 sides to the label, each side must be a minimum of 100 mm (3.9″).
However, §172.407(c)(1)(i) allows the dimensions of the label and its features to be reduced proportionally if the size of the package so requires. Symbol and other elements of the label must remain clearly visible.
Also, §172.406(b)(1) allows for the display of the label on a “securely affixed tag” or other suitable means if the HazMat is not a Class 7 Radioactive and the dimensions of the package are less than those of the required label.

So, per the USDOT/PHMSA regulations a label may be reduced in size as necessary to fit on the package. There is no minimum size requirement. The label can be as small as necessary to fit on the package as long as it continues to communicate the necessary information. Or, as an option, a label may be displayed on a tag secured to the package.

International Maritime Organization (IMO) for the international transport of dangerous goods by vessel:

The IMO Dangerous Goods Code at 5.2.2.2.1.1 mandates the label to be a minimum of 100 mm on a side. The image at 5.2.2.2.1.1 clearly indicates the 100 mm minimum applies to each diagonal side of the label.
5.2.2.2.1.1.3 allows for a proportional reduction in the size of the labels if the package is too small and if the symbols and other elements of the label remain clearly visible.
Also, 5.2.2.1.6 allows the label to be displayed on a “securely affixed tag” or other suitable means if the package is too small.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Read: Replacement of the Class 9 Miscellaneous label with the Class 9 Lithium Battery label

Similar to USDOT/PHMSA, the IMDG Code sets a minimum size for the label on a package. However, the label may be smaller than this minimum if required by the size of the package. The shipper also has the option to display the label on a tag or by other means if the size of the package hinders display of a full-size label.

International Air Transport Association (IATA) for the international and domestic transport of dangerous goods by air:

7.2.2.3.2(a) of the IATA Dangerous Goods Regulations establishes a minimum dimension of 100 mm for each side of a label.
7.2.2.3.1 allows for reduced dimensions of a label’s size (labels may have dimensions that are half of the 100 mm minimum, but no less), but only for the following dangerous goods and only when displayed on a package of an infectious substance that is too small to display the full-size label:
- Class 2.1 Non-flammable, non-toxic gas
- Class 6 Infectious substance
- Class 9 Miscellaneous
7.2.6.1(d) allows for the display of the label on a “strong tag(s)” but only when the package is of such an irregular shape that a label cannot be attached or printed on its surface.
7.2.6.1(e) requires the shipper to ensure the package is of such a size that there is adequate space to affix all required labels.

It should be no surprise the regulations of IATA are more strict than any other agency. In brief, the IATA Dangerous Goods Regulations do not allow for the reduction in size of the hazard label except in very limited circumstances, and then, a reduction in size of no more than half of the minimum size. IATA goes further than either of the other agencies in specifying that the shipper must use a packaging that is big enough for all required labels – and package marks.

I hope this helps. Please contact me with any other questions.

Conclusion:

That seemed to do it! If the transport of hazardous materials (aka: dangerous goods) is required for your business, make sure you are doing it in compliance with the applicable regulations. Though similar in many ways, there are significant differences between the regulations of USDOT/PHMSA, IMO, & IATA, even when dealing with something as insignificant as the display of a hazard label on a package. Contact me to assist you with compliance.

Q&A: Do the IATA Dangerous Goods Regulations allow for the display of “MISCELLANEOUS” on the Class 9 label?

A question from half a world away on November 11, 2017:

Hi Daniels Training Services

I’m <<Name>> from Vietnam. My company has used DG hazard label – class 9 Miscellaneous with word (there is word “Miscellaneous”) shipment of battery UN3480, PI965 Section IB.

My question: is this label Class 9 with word compliance with IATA’s requirement or not ?

Because I’ve seen two kind of Class 9 label :

DG hazard label – class 9 Miscellaneous with word
and DG hazard label – class 9 Miscellaneous without word

I don’t DG hazard label – class 9 Miscellaneous with word is ok to use or not ?

Thanks

My reply that same day:

Thank you for contacting me. I will try to answer your question below:

A lithium battery shipped according to PI965, Section IB must display one of the following Class 9 labels:
- Class 9 Miscellaneous is acceptable for use until 12.31.18 but may not be used after that date.
- Class 9 Lithium Battery is acceptable as of 01.01.17 and is mandatory as of 01.01.19.
7.2.2.4 of the IATA DGR allows for the display of information such as the hazard class name (e.g. Miscellaneous) in the bottom part of the label as long as the text does not obscure or detract from other required information. If used, text should be in English.
7.2.2.4 also forbids the display of text in the lower half of the Class 9 Lithium Battery label.

: Required display of Class 9 label after 01.20.21.

: Class 9 Lithium Battery label

In sum:

The label you indicate is acceptable for shipments of lithium batteries with the word “Miscellaneous” displayed but only until the end of 2018 (12.31.18). After that date the Class 9 Lithium Battery label must be used. You may continue to use the label you indicate after 12.31.18 but not for shipments of lithium batteries. It may be used for other Class 9 Miscellaneous dangerous goods.

I hope this helps. Please don’t hesitate to contact me with any questions.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

He replied gratefully the next day (but it could have been the same day in Vietnam, I’m not sure how that works):

Hello Daniel,
Thanks so much for your promptly feedback about my question.
To me, it’s excellent answer and details. It’s over my expectation.
Your explanation of Class 9 Miscellaneous with word “Miscellaneous” is clear. it help me to solve the issue we are facing with DG team at airport. They said my label Class 9 Miscellaneous with word is wrong label because there is word “Miscellaneous” on the label.
My team has used this label Class 9 Miscellaneous with word for DG shipment in many years, but now DG team airport told me it was wrong label, so i needed to find evidence or IATA document talk about this.
Again, thanks for your feedback. Specially remind time out of using old label Class 9 (31.12.2018), also point 7.2.2.4 of the IATA DGR allows for the display of information such as the hazard class name (e.g. Miscellaneous) in the bottom part of the label.

But we weren’t done! Two and one half (2 1/2) hours later the guy’s problems aren’t over so he contacts me again:

Hello Daniel,
Sorry , bother you again.
I tried to search in internet to find the state 7.2.2.4 to talk about the IATA DGR allows for the display of information such as the hazard class name (e.g. Miscellaneous) in the bottom part of the label as long as the text does not obscure or detract from other required information.

However, I just found 7.2.2.4 in 54th Edition IATA Dangerous Goods Regulations (2013) only, while version now is 58th (2017).
Is the under state 7.2.2.4 of 54th edition IATA DGR OK to show with the DG team at airport ?
I means I want to tell the DG team at airport that the 7.2.2.4 allows to show word “Miscellaneous” on lower haft of Class 9 label, and persuade them to accept this my label.

Thanks

I had to help this guy! It took me until the afternoon of the next day:

I apologize for my delay in replying to your latest question. Please see below.

Even though the regulations may not have changed since 2013, it is not acceptable to use older editions of the IATA DGR to determine compliance.
This particular regulation has changed since 2013. I know this because in the 58th Edition (see below) there is an open triangle near the entry which indicates a change from the previous (57th) edition.

: Part 1 of 7.2.2.4

: Part 2 of 7.2.2.4

You are unlikely to find any recent editions of the IATA DGR on-line since they must be purchased from IATA or some other supplier.
If you ship dangerous goods by air you must have access to the IATA DGR. I recommend you purchase yours from ICC Compliance Center.
Also, you and your employees must receive training on the IATA DGR every two years. I can provide this training.

I hope this helps.

Please don’t hesitate to contact me with any other questions.

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