International Air Transportation Association (IATA)

Q&A: How can I ship a combustible liquid by air?

A question from the regulated community (10.24.17):

Good afternoon Daniel. I am shipping a combustible liquid and wanted to know if I can ship overnight by air if it falls under excepted quantity. It has a flashpoint of 80 Celsius. Will it require dangerous goods paperwork and placarding? If under 500mL I can ship by excepted quantity without placarding and paperwork correct? If over 500mL would it have to go ground only? I do not see combustibles in section 4.2 in the IATA book.

Thanks for your help sir.

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I knew this was going to be a tough question to answer because it referenced a classification unique to the U.S. (Combustible Liquid), a complicated packaging exception (excepted quantity), and two distinct sets of regulations (the USDOT/PHMSA Hazardous Materials Regulations for transport within the U.S. and the IATA Dangerous Goods Regulations for transport by air).  So, I asked for more information and more time:

Thank you for contacting me.

This is a very tough question which is taking me some time to research. If you can provide some additional information, that would be helpful:

  • What is the material? Does it have a classification other than combustible liquid?
  • Is the maximum net quantity of the inner packaging no more than 30 g or 30 ml?
  • Is the maximum net quantity of the outer packaging no more than 500 g or 500 ml?

Thank you and please advise.

He replied the next day (10.25.17):

Here is the SDS (SDS was attached to the email). Inner packaging would be 500mL. Maximum net quantity of the outer packaging would be 500mL.

The following relevant data was obtained from the SDS:

  • Contains: 95% N-MethylAminoPropylTriMethOxySilane and <5% Methanol
  • Flash point: 82 °C (179.6 °F)
  • Section 14 indicates classification as UN1993, Combustible liquid, n.o.s.
  • No classification per international regulations (IATA or IMO) is indicated.
  • No other information in SDS indicates material meets defining criteria of other HazMat / dangerous good.

Ball was back in my court.  I replied later that day:

I think I have an answer for you. Please see below.

  • Based on the SDS it is a hazardous material (HazMat) as defined by USDOT/PHMSA as a Class 3 Combustible Liquid.
  • The international regulations – including IATA – do not have a classification for, and do not regulate, a Combustible Liquid. Therefore, this material is not regulated per IATA.
  • 49 CFR 171.22(c) of the Hazardous Materials Regulations (HMR) requires a HazMat not subject to international regulations – e.g., a Class 3 Combustible Liquid – be subject to the HMR when transported to, from, or through the U.S. regardless of international regulations. This USDOT letter of interpretation confirms it (LOI 13-0020).
  • A Combustible Liquid transported within the U.S. is subject to the combustible liquid exception if it is not transported in a bulk packaging and is not classified as a hazardous substance, hazardous waste, or marine pollutant.  Based on the information provided I presume this HazMat is none of those.
  • To be be eligible as an excepted quantity per USDOT/PHMSA and IATA regulations the maximum net quantity of the inner packaging must be no more than 30 g / 30 mL and the maximum net quantity of the outer packaging must be no more than 500 g / 500 mL. Based on your earlier email your HazMat exceeds the maximum net quantity for the inner packaging and therefore can’t be transported as an excepted quantity.

In summary:

Based on the information provided the material as described is not subject to the regulations of either USDOT/PHMSA or IATA when transported within the U.S. or internationally by any mode as long as the requirements of the Combustible Liquid Exception are met.

I hope this helps.

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

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That appeared to satisfy him.

Great! Thanks Daniel. Some of these chemicals can be tricky when shipping.

Conclusion:

The transport of a hazardous material (aka: dangerous good) within the U.S. while subject to international regulations can be a challenge! The classification of a Class 3 Combustible Liquid and the application of the Combustible Liquid Exception are only two examples where international and domestic regulations must be made to work together. Other shipping challenges include: marine pollutants, hazardous substances, & lithium cells or batteries to name a few.  And of course, all regulations require periodic training for applicable personnel to ensure knowledge and compliance.

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When the Shipper’s Declaration for Dangerous Goods is not required

When the Shipper’s Declaration for Dangerous Goods is not required

Most shipments of a dangerous good by air will be subject to the dangerous goods regulations of the International Air Transport Association (IATA). One of the shipper responsibilities of the IATA Dangerous Goods Regulations is the completion of the Shipper’s Declaration for Dangerous Goods, i.e. “The Declaration”. The Declaration is a document – either paper or electronic – with a specified format that describes the consignment of dangerous goods and – though required to be completed by the shipper – is used primarily by the personnel of the air carrier. Some dangerous goods, however, do not require completion of The Declaration. This article will identify those articles or substances that do not require a Shipper’s Declaration for Dangerous Goods. (more…)

Use of the New Hazard Class 9 Lithium Battery Label

The transportation in commerce of a package containing a lithium battery is subject to both domestic and international transportation regulations.  Depending on the classification of the lithium battery package several types of hazard communication methods (labels and/or package marks) may be mandatory.  One significant change to the hazard communication regulations for lithium batteries or cells is the phase in of the new Hazard Class 9 Lithium Battery label to replace the currently used Class 9 Miscellaneous label.

This short Power Point presentation will summarize these changes and the deadlines for compliance.

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It is important to note that the changes summarized here will become effective in all modes of transportation (highway, rail, vessel, air) and both domestic (PHMSA/USDOT) and international (ICAO/IATA and IMO) in the same way at the same time.

Use of the New Lithium Battery Mark

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Summary of Significant Changes and Amendments to the 59th Edition 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 2017 is the 58th edition.  Beginning January 1, 2018 all transport of dangerous goods subject to IATA’s Dangerous Goods Regulations must be in compliance with the 59th edition.  The purpose of this article is to summarize the significant changes in store for 2018 in the 59th edition.

What follows is only my summary of the full document issued by IATA (Significant Changes and Amendments to the 59th Edition – 2018).  And, IATA includes this disclaimer in their document:

The following list is intended to assist the user to identify the main changes introduced in this edition and must not be considered an exhaustive listing.

So, there’s no substitute for doing the necessary research into the regulations to ensure your transport of dangerous goods by air complies with the IATA Dangerous Goods Regulations.  That being said, I hope my summary below will assist you in identifying where in the 59th edition you should focus your research – if at all.

Section 2 – Limitations:

Subsection 2.3 – Dangerous Goods Carried by Passengers or Crew

2.3.5.9 – Now includes limitations – with some exceptions – on the number of portable electronic devices (PED) and the number of spare batteries for the PED allowed to be carried by passengers or crew.

Subsection 2.8 – State and Operator Variations

2.8.3 – Several additions, deletions, and amendments to operator variations.

Interesting note!

There is no indication of changes to state variations at 2.8.1.

Section 3 – Classification:

3.9.2 – This subsection has been restructured to bring in all substances and articles assigned to Class 9 Miscellaneous with their respective UN numbers and proper shipping names.

Section 4 – Identification:

Subsection 4.4 – Special Provisions

A70 – Has been revised to require the shipper to provide documentation stating that a flushing and purging procedure for flammable liquid powered engines has been followed.

A203 – Identifies that vehicles powered by an engine using both a flammable liquid and flammable gas must be assigned to the entry Vehicle, flammable gas powered.

Section 5 – Packing:

5.0.1.5.1 – Has been revised to include new restrictions for some lithium batteries (UN3090 and UN3480) placed into an overpack with most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.

5.0.2.11 – A note has been added: some lithium batteries (UN3090 and UN3480) are not permitted in the same outer packaging with most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.

Packing Instructions:

PI 951 – Has been revised to require a vehicle powered by an engine using both flammable gas and flammable liquid fuels to meet relevant requirements of PI 950.

PI Y960 – A note has been added to reinforce that dangerous goods in Packing Group I are not permitted.

PI 965 and PI 968 – Text has been added to identify the restrictions on packing some lithium batteries (UN3480 and UN3090) in the same outer packaging with most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.  Restrictions are also identified on placing packages of the same lithium batteries into an overpack with most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.

Section 7 – Marking and Labeling:

7.1.5.5.2 – Text has been added recommending that the UN number(s) on the lithium battery mark be of a minimum size.

IATA Dangerous Goods Regulations

Out with the old…

59th edition of the IATA Dangerous Goods Regulations

…and in with the new.

Section 9 – Handling:

9.3.2 – Has been revised to introduce segregation requirements for some lithium batteries (UN3480 and UN3090) and most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.

Appendix B – New Cargo IMP codes have been added for UN3090, Section IA and IB of PI 968-RBM and UN3480, Section IA and IB of PI 954-RBI.

Appendix D – Contact details for competent authorities have been updated.

Appendix E – Changes have been made to the list of UN Specification Packaging Suppliers and the Package Testing Facilities.

Appendix F – Changes have been made to the list of Sales Agents, IATA Accredited Training Schools, and IATA Authorized Training Centers.

Appendix I – This new appendix was added to describe the changes that will come into effect as of January 1, 2019 (i.e. the 60th edition).  These changes include:

  • Replacement of most instances of the word “risk” by the word “hazard”.
  • Significant changes to the provisions for the classification of corrosive substances.
  • A new requirement for manufacturers and subsequent distributors of lithium cells or batteries to make available a summary of the UN 38.3 tests.
  • New provisions for the classification of articles containing dangerous goods, n.o.s.
  • A number of new and modified special provisions.
  • Removal of the lithium battery handling label.

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Step 1: Purchase the 59 the edition of the IATA Dangerous Goods Regulations

Step 2: Review the regulations to determine if their were any changes that effect your compliance.

Step 3:  Contact me for in-depth site-specific Onsite Training.

Use of the New Class 9-Lithium Batteries Label

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Q&A: The Marine Pollutant Exception

This is a question from a customer of mine.  I had provided them with HazMat Employee Training (to meet USDOT regulations), training for the shippers and packers of dangerous goods by air as required by the International Air Transport Association (IATA) and also training for shore-based personnel for dangerous goods by vessel per the International Maritime Organization (IMO).  Afterwards, they had some questions for me about specific shipping challenges.  Like all of my customers, I happily answered their questions at no cost.  For this particular question the customer had already sent me a Safety Data Sheet (SDS) for the product they wished to ship.  We had had a brief telephone conversation where I informed them the product was a marine pollutant and was subject to an exception.

Marine Pollutant MarkThe question (01.09.17):

Daniel –

During our conversation, you said that the IMO and IATA laid out an exception for the product I sent you the SDS for, where as long as it’s in an inner packaging ≤ 5L, it isn’t regulated per IATA.
A) Did I understand you correctly (is that true)?
B) Where did you see that? I’m just looking over the SDS and can’t find anything that would have tipped you off to that information, and I would like to read that exception myself.
C) Is that exception (if it is as I understand it) for the raw material itself, or for the UN 3082 entirely?
Also, did that exception also remove the Ltd. Qty. ‘G’ limitation?
Thanks for your help.
My reply the same day:
Please see below:
  • USDOT, IMO, & IATA have an exception from regulation specific to Marine Pollutants if they are below 5 kg/5 L per package.
  • The exception is not referenced in the SDS.  It can be found as follows:
    • 49 CFR 171.4 of the USDOT HMR.
    • Special Provision A197 of the IATA DGR, referenced from 7.1.5.3.
    • 2.10.2.7 of the IMO Dangerous Goods Code.
  • The exception would apply to any substance that meets the criteria for a marine pollutant.  The exception only applies to it as a a marine pollutant and does not except it from any other regulations.  For example, if a marine pollutant is also a Class 3 Flammable Liquid, it may be subject to the above marine pollutant exception but would remain regulated as a Class 3 Flammable Liquid.
  • The marine pollutant exception has nothing to do with the limited quantity exception.  The ‘G’ in the Dangerous Goods List only applies if you are shipping the HazMat as a limited quantity.
I hope that helps.
Please don’t hesitate to contact me with any other questions.
Some follow-up from the customer:

Daniel –

Thank you so much for your thorough response.
Correct me if I’m wrong, but wouldn’t the Special Provision A197 supersede the Limited Quantity exception in regard to relief of shipping limitations? Basically, as long as we are following the Special Provision, and not shipping it Ltd. Qty., my understanding is that the special provision allows us to ship the product un-regulated, therefore not being subject to any gross weight limitations as long as it’s being shipped below 5kg/L. Is that true?
I just want to make sure that I’m interpreting all of this accurately before I make my case to UPS HazMat. 🙂
Thanks again for your patience with us on this.
My reply:

You are correct.  Sequence is:

  1. Classify to determine if HazMat/dangerous good.
  2. If yes, determine if exception applies.  In this case, both the marine pollutant exception and the limited quantity exception apply.
  3. Choose exception to use or ship as fully regulated HazMat.
  4. If shipping per marine pollutant exception, then material is not regulated (i.e. not HazMat/dangerous good) as long as you comply with the requirements of the exception.
  5. The gross package weight limits of the limited quantity exception only apply if you choose to use that exception.  You are not doing that in this case.
Please don’t hesitate to contact me with any other questions.

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

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Conclusion:
This exchange represents a common challenge of complying with the Hazardous Materials Regulations: that of taking things step-by-step in an orderly process.  As my last email to the customer details, there is a process to compliance.  An action taken out of sequence – even if a correct action – could lead to a non-compliance.  One thing I strive for in my training is not to simply tell trainees what to do but to show them how it is done, and more importantly, to have them perform the actions themselves.  Identifying hazardous materials by their proper shipping name in the hazardous materials table, determining the proper packaging including what – if any – packaging exception is available, applying the four hazard communication methods (labels, marks, shipping papers, and placards)…it all must be done in the proper sequence.
General Requirements and Provisions for the Transportation of Lithium Batteries

General Requirements and Provisions for the Transportation of Lithium Batteries

The transportation of a lithium cell or battery requires the shipper to ensure it meets certain standards of testing and production before its transportation in commerce can be considered. The purpose of this article is to identify and explain the general requirements applicable to all transportation of a lithium cell or battery.

The regulations this article seeks to explain can be found as follows (current as of August 2017):

  • The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the USDOT at 49 CFR 173.185(a).
  • The Dangerous Goods Regulations (58th Edition) of the International Air Transport Association (IATA) at 3.9.2.6.
  • The International Maritime Dangerous Goods Code (IMDG) at 2.9.4
  • Section 349 of Publication 52 of the United States Postal Service (USPS).

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Regulation:  Cell or Battery Proven to Meet UN Criteria:

Applicability:

  • PHMSA/USDOT:  yes
  • IATA:  yes
  • IMO:  yes
  • USPS:  yes.  USPS contains a specific reference to this requirement and blanket statement: “All packaging must meet all applicable requirements specified in 49 CFR 173.185.”

And…

  • All lithium cells and batteries regardless of lithium content or Watt-hour rating.
  • It is the responsibility of the shipper of the lithium cell or battery to ensure compliance with this regulation.

What it Requires:

  • Each cell or battery must be of a type proven to meet the criteria in part III, sub-section 38.3 of the UN (United Nations) Manual of Tests and Criteria.
  • Cells and batteries – including those that have been refurbished or otherwise altered – must meet the above-referenced UN criteria regardless of whether the cells used to construct the battery are composed of a tested type.
  • A battery or cell manufactured according to a type that meets the requirements of sub-section 38.3 of the UN Manual of Tests and Criteria, Revision 3, Amendment 1 or any subsequent revision and amendment applicable at the date of the testing may continue to be transported, unless otherwise provided in the regulations.
  • A battery or cell type that only meets the requirements of the UN Manual of Tests and Criteria, Revision 3, are no longer valid.  However, a battery or cell manufactured in conformity to the UN Manual of Tests and Criteria, Revision 3 before July 2003 may continue to be transported if all other applicable requirements have been met.

Comments:

  • It is the responsibility of the shipper to obtain confirmation from the battery manufacturer or supplier this requirement has been met.
Regulation:  Maintain a Record of Completion of Testing:

Applicability:

  • PHMSA/USDOT:  yes
  • IATA:  no
  • IMO:  no
  • USPS:  yes, “All packaging must meet all applicable requirements specified in 49 CFR 173.185.”

And…

  • All lithium cells and batteries regardless of lithium content or Watt-hour rating.
  • It is the responsibility of the manufacturer of the lithium cell or battery to ensure compliance with this regulation.

What it Requires:

  • Create a record of satisfactory completion of the required testing (i.e. the UN Manual of Tests and Criteria referred to above).
  • Maintain the record for as long as the lithium cell or battery design is offered for transportation and for one year thereafter.
  • Make the record available to an authorized representative of Federal, state, or local government upon request.

Comments:

  • This regulation – unique to PHMSA/USDOT and, by incorporation, USPS – specifically applies to the manufacturer of the cell or battery.

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Regulation:  Lithium Battery or Cell Design:

Applicability:

  • PHMSA/USDOT:  yes
  • IATA:  yes
  • IMO:  yes
  • USPS:  yes, “All packaging must meet all applicable requirements specified in 49 CFR 173.185.”

And…

  • This requirement does not apply to a lithium cell or battery subject to the “smaller lithium battery exception”.
  • It is the responsibility of the shipper of the lithium cell or battery to ensure compliance with this regulation.

What it Requires:

Each cell or battery must:

  • Incorporate a safety venting device or be designed to prevent a violent rupture under normal transportation conditions.
  • Be equipped with effective means of preventing external short circuits.
  • Be equipped with effective means of preventing dangerous reverse current flow (e.g. diodes or fuses).  This requirement is applicable solely to a battery that contains cells or a series of cells connected in parallel.

Comments:

  • Refer to this table for threshold lithium content for classification of a “smaller lithium battery”.
StatusLithium Ion Battery
(Watt-hour (Wh) Rating)		Lithium Metal Battery
(Lithium Content (g))
BatteryCellBatteryCell
Subject to "smaller battery exception"Does not exceed 100 WhDoes not exceed 20 WhDoes not exceed 2 gDoes not exceed 1 g
Subject to full regulationExceeds 100 WhExceeds 20 WhExceeds 2 gExceeds 1 g
Subject to "smaller battery exception" by highway or railDoes not exceed 300 WhDoes not exceed 60 WhDoes not exceed 25 gDoes not exceed 5 g
Regulation:  Manufactured Under a Quality Management Program:

Applicability:

  • PHMSA/USDOT:  no
  • IATA:  yes
  • IMO:  yes
  • USPS:  no, “All packaging must meet all applicable requirements specified in 49 CFR 173.185.”

And…

  • All lithium cells and batteries regardless of lithium content or Watt-hour rating.
  • It is the responsibility of the shipper of the lithium cell or battery to ensure compliance with this regulation.

What it Requires:

Lithium cell or battery must be manufactured under a quality management program that includes:

  1. A description of the organizational structure and responsibilities of personnel with regard to design and product quality.
  2. The relevant inspection and test, quality control, quality assurance and process operation instructions that will be used.
  3. Process controls that should include relevant activities to prevent and detect internal short circuit failure during manufacture of cells.
  4. Quality records, such as inspection reports, test data, calibration data and certificates.  Test data must be kept and made available to the appropriate national authority upon request.
  5. Management reviews to ensure the effective operation of the quality management program.
  6. A process for control of documents and their revision.
  7. A means for control of cells or batteries that are not conforming to the UN criteria (referred to earlier in this article).
  8. Training programs and qualification procedures for relevant personnel.
  9. Procedures to ensure that there is no damage to the final product.

Also…

  • An in-house quality management program may be accepted.
  • Third party certification of the quality management program is not required.
  • The procedures listed above (1 – 9) must be properly recorded and traceable.
  • A copy of the quality management program must be made available to the appropriate national authority (i.e. USDOT within the U.S.) upon request.

Comments:

  • Interestingly, there is no reference to the quality management program, or anything like it, in the Hazardous Materials Regulations of PHMSA/USDOT.
  • The reference in the last bullet point to “a copy of…” the quality management program implies that it be in the form of a document.
  • The requirements of the quality management program listed above (1 – 9) are almost verbatim as they appear in the dangerous goods regulations of IATA and IMO.  I could find no way to summarize them.

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There you have it!  As a shipper of lithium cells or batteries, don’t overlook the general requirements of the regulations and focus solely on the packaging requirements.  Compliance with these general requirements is what makes the safe transportation of lithium cells and batteries possible.

Quick Take: Determination of Packing Group for a Class 8 Corrosive

Quick Take: Determination of Packing Group for a Class 8 Corrosive

Whether shipping a hazardous material or dangerous good by highway, air, rail or vessel; whether transported internationally or within the U.S.; the shipper of a hazardous material is responsible for its classification.  This includes – among other things – determining the applicable hazard class – or division – and the packing group, if it has one.  This is a requirement of all three regulatory agencies that regulate the transportation in commerce of hazardous materials/dangerous goods:

  • The Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation (USDOT).
  • The International Air Transport Association (IATA) whose regulations are based on those of the International Civil Aviation Administration (ICAO).
  • The International Maritime Organization (IMO).

The purpose of this article is to provide the regulatory standard for determining the packing group of a Class 8 Corrosive.

The good news is that all three regulatory agencies for the transport of hazardous materials use the same criteria for the classification of a Class 8 Corrosive.  This includes the determination of its packing group.  Unlike IATA and the IMO, however, PHMSA does not tabulate its data and instead requires the reader to find their way through some confusing text.  The table below can be seen in almost exactly this form in the regulations of IATA and the IMO and neatly clarifies those of PHMSA.

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Packing GroupExposure TimeObservation TimeEffect
I - Greatest DangerUp to but no more than 3 minutesUp to but no more than 60 minutesFull thickness destruction of intact skin
II - Moderate DangerMore than 3 minutes and up to but no more than 60 minutesUp to but no more than 14 daysFull thickness destruction of intact skin
III - Lowest DangerMore than 60 minutes and up to but no more than 4 hours Up to but no more than 14 daysFull thickness destruction of intact skin
III - Lowest DangerN/AN/ACorrosion rate on steel or aluminum more than 6.25 mm/year at test temperature of 55 degrees Celsius

Remember:  there are eight other hazard classes, some of them with their own criteria for determining the packing group.  Make certain you consider each of them and a lot more when you classify your HazMat/dangerous good prior to offering it for transportation.

Class 8 Corrosive PlacardsPlease don’t hesitate to contact me if you require any assistance in the classification of your hazardous material.

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Q&A: Can a limited quantity of a hazardous material be transported by air in a non-specification packaging?

A follow-up question from one of my recent Onsite Training customers (11.18.16):

Hello Daniel,

Can you please confirm that a Limited Quantity Air Shipment can go in a non-specification package?

Thank you,

My reply that same day:

Correct.

The IATA regulations at 2.7.1.1 for a limited quantity includes the following:

It is recognized that many dangerous goods can be safely carried in good quality combination packagings which meet the construction requirements of Subsections 6.1 & 6.2 but which have not been marked and tested in accordance with the requirements of 6.0.4.

6.1 = Requirements for inner packagings
6.2 = Specifications for UN Outer Single and Composite Packagings.
6.0.4 = Markings of UN Specification Packagings.
In other words, the packaging must be able to meet the construction requirements of specification packaging but do not have to be tested and marked as such.
Package performance tests for limited quantity packaging by air are documented in 2.7.6 which include a drop test and a stacking test.
I hope this helps.
Please don’t hesitate to contact me with any other questions.

The transportation of a hazardous material (aka: dangerous good) by air – even within the U.S. – will likely be subject to the regulations of the International Air Transport Association (IATA).  These regulations are authorized for use within the U.S. by PHMSA/USDOT (at least, the technical instructions of the International Civil Aviation Administration are authorized for use by PHMSA/USDOT and since the IATA Dangerous Goods Regulations are very similar to the ICAO technical instructions and are even a little bit more strict, compliance with IATA results in compliance with ICAO and PHMSA/USDOT.  Got it?) and are adhered to by most of the world’s airlines.

Questions like this arise because, while similar in many ways – the regulations of IATA and PHMSA/USDOT differ in several key areas.

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Contact me if you have questions about how to ship HazMat by air, highway, rail, or vessel.