International Air Transportation Association (IATA)

Video From IATA: What are the Dangerous Goods Regulations?

Here is a short video produced by the International Air Transport Association (IATA) that succinctly describes IATA and its Dangerous Goods Regulations for the transport of dangerous goods by air.

I couldn’t say it any better myself!

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
Things to consider about IATA Dangerous Goods Training:
  • It is not required for employees who receive dangerous goods that were transported by aircraft unless they work at an airport or aircraft unloading facility.
  • Initial training must be provided before performing a regulated function.
  • Full renewal training must be provided within 24 months of initial training.
  • Employees must be tested as part of the training.  Successful completion of the test must be confirmed.

Also…

The IATA Dangerous Goods Regulations are updated each calendar year.  For 2017, the 58th Edition should be your only source for determining compliance.

Compliance with the Dangerous Goods Regulations of IATA are mandatory if you ship hazardous materials/dangerous goods by air either international or domestic.  In its Hazardous Material Regulations, the Pipeline and Hazardous Materials Safety Administration of the US Department of Transportation (PHMSA/USDOT) authorizes the use of the IATA Dangerous Goods Regulations – with certain additional requirements and limitations – for the transport of HazMat/dangerous goods to, from, or through the U.S.  Make certain you comply with both the domestic and international regulations when you ship hazardous materials/dangerous goods by air.

Articles or Substances that do not Require a Shipper’s Declaration for Dangerous Goods

The Dangerous Goods Regulations of the International Air Transport Association (IATA) are recognized by most of the world’s airlines as the standard for the transportation of dangerous goods by air.  In practice, anyone offering a dangerous good for transport by air must comply with the IATA Dangerous Goods Regulations as it will be required by the operator (aka: the air carrier) as a condition of accepting the dangerous good (aka: hazardous material or HazMat) for transportation.  Similar to the Hazardous Material Regulations of the PHMSA/USDOT, IATA assigns responsibilities to a shipper of dangerous goods by air to include, but not limited to, the following:

  • Identify and classify the dangerous good.
  • Provide necessary information to employees.
  • Ensure dangerous good is not forbidden for air transport.
  • Packaging must be authorized for dangerous good.
  • Markings and labels must be affixed to package.
  • All relevant personnel must receive training per Subsection 1.5 of the IATA DGR.
  • Required documentation, e.g. the Shipper’s Declaration for Dangerous Goods must be completed.

For a full description of the above, refer to Subsection 1.3 – Shipper’s Responsibilities of the IATA Dangerous Goods Regulations.

The purpose of this article is to identify the shipments of articles or substances that do not require a Shipper’s Declaration for Dangerous Goods when transported by air. (more…)

Training Requirements for Persons Involved in the Transportation of Lithium Batteries

Lithium ion battery for cell phoneIn case you haven’t heard, the transportation in commerce of lithium batteries of all types – and of almost all sizes – is subject to the regulations of several regulatory agencies depending on how it is to be transported.

  • Transportation to, from, or through the U.S. (including its overseas territories and states) is subject to the Hazardous Material Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation (USDOT).
  • Transportation by air anywhere in the world (including to, from, or through the U.S.) will likely be subject to the Dangerous Goods Regulations of the International Air Transport Association (IATA).
  • Transportation by vessel in international waters (which may include U.S. territorial waters if so chosen by the shipper) will be subject to the International Maritime Dangerous Goods Code (IMDG Code) of the International Maritime Organization (IMO).
  • Even the United States Postal Service (USPS) has regulations for the transportation of lithium batteries.

There is not enough space here to document all of the requirements of all of these regulations for all of the possible modes of transportation.  In an earlier article I provided information to assist you with the process of the classification of a lithium battery for transportation; the information in that article pertained to all modes of transportation.  In this article I will explain just one small – though critical – requirement of the regulations for the transportation in commerce of lithium batteries by air:  The responsibility of the employer to provide training for persons involved in the transportation of lithium batteries.

(more…)

FAA Proposes Civil Penalties Against Amazon for Alleged Violations of HazMat Transportation Regulations

The Bullet:

The Federal Aviation Administration (FAA) alleges that Amazon, Inc. violated USDOT regulations for the transportation of hazardous materials by air on several occasions.  It has proposed fines as a civil penalty for those alleged violations.

The information for this article regarding the alleged violations is derived from three FAA press releases.  Links to these press releases are at the end of this article.
Who:

Amazon.com, Inc., often referred to as simply Amazon, is an American electronic commerce and cloud computing company with headquarters in Seattle, Washington. Wikipedia

The Federal Aviation Administration (FAA) is the national aviation authority of the United States, with powers to regulate all aspects of American civil aviation. These include the construction and operation of airports, the management of air traffic, the certification of personnel and aircraft, and the protection of US assets during the launch or reentry of commercial space vehicles.  Wikipedia

Federal Aviation AdministratinoThe FAA is one administration or bureau of many within the U.S. Department of Transportation.  Another USDOT administration, PHMSA or the Pipeline and Hazardous Materials Safety Administration, is responsible for all regulations regarding the transportation of hazardous materials in commerce within the U.S.  In this situation the FAA is the investigation and enforcement agency for the PHMSA Hazardous Materials Regulations (HMR).

Unmentioned in the press release is an international agency Logo of the International Air Transport Associationknown as IATA, the International Air Transport Association, and its Dangerous Goods Regulations.  IATA is a creation of the airline industry – not of any government body – to set standards and regulate all transportation by air.  Its Dangerous Goods Regulations, though not officially adopted by PHMSA, is based on – and even a little more strict than – the Technical Instructions of the International Civil Aviation Administration (ICAO).  The ICAO Technical Instructions are adopted by PHMSA

If you like this article, please share it using any of the social media platforms identified at the bottom of this article.

You’ll look real smart recommending my articles!
What:

FAA alleges that in three separate incidents dating from 2014, Amazon did not comply with the HMR.  Though each incident involved different hazardous materials (from acid drain cleaners to a compressed gas) and different outcomes (injured UPS employees, leaking packages), the alleged violations were sadly similar.  They include:

  • Not classifying the intended shipments to determine if they were a hazardous material as defined at 49 CFR 171.8.
  • Not using the authorized packaging for the HazMat.  Authorized packaging is identified for each HazMat in part 173 of the HMR, referenced from column 8 of the Hazardous Materials Table at §172.101.
  • Not using packaging designed, manufactured, tested, and marked to indicate it meets the United Nations packaging standards.
  • Packages offered for transport were not marked or labeled to indicate the contents and its potential hazards.  The package marking and labeling requirements are at §172, subpart D and E, respectively.
  • Not preparing and providing to the carrier (Fed Ex or UPS) two copies of the shipping paper which is meant to describe the entire hazardous materials shipment.  One of the press releases refers to the Shipper’s Declaration of Dangerous Goods, which is the name for a shipping paper used exclusively by IATA.
  • Failing to provide emergency information.  Actually, a shipper of HazMat is required to provide two separate types of emergency information on or with the shipping paper.  Required emergency information includes:
    • Emergency Response Information that provides emergency responders and trained HazMat Employees critical information in the first few minutes of a spill, fire, or other HazMat incident.  Read:  The Shipper Must Provide Emergency Information.
    • Emergency Response Telephone is a phone number to call 24/7 whenever a HazMat is in transportation.  Its purpose is to provide emergency responders and trained HazMat Employees with immediate contact with a person who is knowledgeable about the hazards of the shipment and has basic emergency response awareness.  Read:  Providing the Emergency Response Phone Number.
    • “Amazon employees who handled the package had not received required hazardous materials training.”  You’ll forgive my bias but this is the big one.  Not providing initial and triennial HazMat Employee Training is bad enough.  But, if done right, training would have provided Amazon employees with the information and the tools necessary to properly classify and package the HazMat, apply the correct HazMat labels and markings, and complete the Shipper’s Declaration of Dangerous Goods – with the applicable emergency information.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

The three proposed civil penalties are:

  • $350,000 for alleged violations of October 15, 2014
  • $78,000 for alleged violations of May 24, 2014
  • $52,000 for alleged violations of June 2, 2014
Where/When:
  • In a press release dated June 15, 2016, FAA alleged:  on October 15, 2014 Amazon offered to United Parcel Service (UPS) a package containg a one-gallon container of “Amazing! LIQUID FIRE,” a corrosive drain cleaner for transport from Louisville, KY to Boulder, CO.
  • In a press release dated June 22, 2016, FAA alleged:  on June 2, 2014, Amazon offered UPS a non-specification cardboard box containing a flammable gas for air transportation from Whitestown, IN to Glendale, CA.
  • In a press release also dated June 22, 2016, FAA alleged:  on May 24, 2014, Amazon offered Federal Express (FedEx) two cardboard boxes containing corrosive rust stain preventer for air transportation from Plainfield, IL to Davenport, FL.
Why:

Transportation of dangerous goods by airThe purpose of the HMR is to ensure the safe transportation in commerce of hazardous materials.  One of the responsibilities of the FAA is to ensure that HazMat transported by air within the U.S. is done in compliance with the HMR and the IATA Dangerous Goods Regulations.

Amazon has a history of violating the Hazardous Materials Regulations.  From February 2013 to September 2014 alone, Amazon was found to have violated the Hazardous Materials Regulations 24 other times.  FAA press release of June 13, 2016
How:

The FAA has the authority to enforce the Hazardous Materials Regulations of PHMSA when the mode of transportation is by aircraft.  The FAA will, in addition, enforce the IATA DGR if it is used within the U.S. by a carrier or shipper.

In 2015, the FAA handed out more than $4.5 million in civil penalties for improper shipments of hazardous materials aboard airplanes, up from $3.4 million in 2014.  Dallas Morning News
Conclusion:
  • Don’t assume that big companies have huge budgets to spend on regulatory compliance and therefore have all the answers when it comes to shipping HazMat.  Unless they have personnel dedicated to researching the regulations, and staying on top of new regulations – such as those for the transportation of lithium batteries – they can be just as in the dark as a small start-up.
  • One mainstream news article on this issue quoted an expert who stated regarding Amazon, “Before, when they were smaller, they didn’t have to make as many distinctions between ground and air.”  In fact, the Hazardous Materials Regulations of PHMSA apply to these HazMat no matter how they are transported in commerce (air, rail, highway, or vessel).  It’s just that the regulations for transportation by air are more strict than those by highway and rail (the regulations for transportation of HazMat by vessel are also pretty strict, just not as strict as those by air).
  • Another mainstream media article referred to these hazardous materials in these instances as “prohibited dangerous goods…”.  Without more information on the actual hazardous material and the volume of their packaging, it is impossible to know if it is “prohibited” for transportation by air or merely subject to the requirements of the HMR.  Many hazardous materials – including Class 1 explosives – may be transported by air if they are correctly classified, packaged, marked and labeled, and a shipping paper is prepared with the necessary emergency information.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
More Information:
Classification of Lithium Batteries for Transportation in Commerce

Classification of Lithium Batteries for Transportation in Commerce

Persons involved in the transportation in commerce of lithium batteries are subject to the regulations of at least one – or perhaps all – of the following regulatory agencies:

  • The Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation (USDOT) for any transportation from, through, or to the United States.
  • The International Air Transport Association (IATA) for any transportation by air – international or domestic – if the carrier airline is a member of IATA.
  • The International Maritime Organization (IMO) for international transportation by vessel.
Note:

Though the dangerous goods regulations of IATA are not authorized for use within the U.S. by USDOT/PHMSA, compliance with its regulations is acceptable since the IATA DGR are based on the Technical Instructions of the International Civil Aviation Administration (ICAO) – and are more strict in some cases.  The ICAO Technical Instructions are authorized for use within the U.S. by USDOT/PHMSA.

Each of these regulatory agencies have very similar regulations applicable to the transportation of lithium batteries.  They each, thankfully, also have very similar – but not the same – requirements for the classification of lithium batteries.  The classification of a lithium battery for transportation requires knowledge of four things:

  1. Is it a cell or battery?
  2. The type of lithium cell / battery.
  3. Its packaging configuration.
  4. The amount of lithium in the cell / battery.
  5. Net weight of cell / battery in the package.
  6. Number of cell / battery in the package.
  7. Number of cell / battery in the consignment.
  8. The condition of the cell / battery.
  9. The mode of transport.
  10. Applicable regulations.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

The purpose of this article is to identify and explain the process of classifying lithium batteries for transportation by both domestic and international regulations. (more…)

Significant Changes to the IATA Dangerous Goods Regulations for 2016

Each year the Dangerous Goods Regulations of the International Air Transport Association are published anew.  That means that when the ball drops on 12.31.15 any copies of the 56th Edition of the Dangerous Goods Regulations are worthless and must be replaced by the 57th Edition which will be in effect for calendar year 2016.

I just bought mine on-line from Air Sea Containers, Inc.  Take my advice and pay the few extra bucks for the spiral bound copy as it lies flat and is easier to work with.

I have summarized below the significant changes from the 56th to 57th Editions published by IATA.  For the full IATA publication read Significant Changes and Amendments to the 57th Edition (2016).

  • Section 1 – Applicability
    • 1.3.3 – Dangerous Goods in Consolidations has been slightly revised and a definition of “consolidation” added.
  • Section 2 – Limitations
    • 2.3 – Dangerous Goods Carried by Passengers or Crew has been revised regarding portable electronic devices, including medical devices containing lithium batteries and spare batteries:
      • Portable oxygen concentrators (POC) are specifically referred to as a portable medical electronic device (PMED).
      • The list of portable electronic devices (PED) has been revised to include reference to more common items, including power banks, which must be treated as spare lithium batteries
    • Table 2.3.A has been restructured:
      • Items are now listed in alphabetical order.
      • Columns for qualifying conditions applicable, approval of the operator, permitted in checked baggage, carry-on baggage and information to the pilot-in-command, moved to right side of table to improve readability.
    • 2.8 – State and Operator Variations:
      • State variations revised by France.
      • State variations now submitted by Nepal and Venezuela.
      • Many additions, deletions, and amendments to operator variations.
  • Section 5 – Packing
    • 5.0.1.3 identifies the few dangerous goods that are allowed to be shipped in freight containers and unit loa
      Unit Load Device

      A unit load device used by UPS

      d devices.  The list of excepted dangerous goods has been expanded and revised to align the list and format to 9.1.4 – Acceptance of Freight Containers and Unit Load Devices.

    • 5.0.1.5 has been expanded to include an additional paragraph to clarify that an overpack of dangerous goods may also contain non-dangerous goods.
    • 5.2.0.6 Packing instructions for Class 2 – Gases has been revised to move the content of 5.2.0.6 regarding filling limits for cylinders to Packing Instruction 200.
  • Packing Instructions
    • PI Y963 Packing instructions for ID 8000, Consumer commodities has been revised to add text identifying substances that are permitted to be classified as ID 8000 and to state that other dangerous goods must not be packed in the same outer packaging with consumer commodities.
    • PI 965 through PI 970 Packing instructions for lithium ion, lithium metal, or lithium polymer cells and batteries that are shipped alone, with equipment, or in equipment has been revised to require the outer packagings to be rigid.  Changes have also been made to the permitted packagings table for each.
    • PI 966 and PI 969 Packing instructions for lithium batteries packed with equipment (UN 3481 or UN 3091) has been revised to clearly identify what is meant by “equipment”.  The same clarifying text has been added to PI 967 and PI 970.
    • PI 967 and PI 970 Packing instructions for lithium batteries contained in equipment has been revised to limit the exception from use of the lithium battery handling label on certain packages.
  • 8 – Documentation
    • 8.1.6.9.2 has had text added to clarify that it is acceptable to identify the number of packages on the Shipper’s Declaration of Dangerous Goods by use of number or words.
  • 9 – Handling
    • 9.4.4 has been revised to include recommendations on actions to take when packages with GHS markings are found to be damaged or leaking and there may be a risk to persons or the environment.
  • Packaging for Radioactive Material10 – Radioactive Materials
    • 10.7.1.3 – the text of the requirement for packages to bear the permissible gross weight has been clarified.
  • Appendix
    • Appendix D – contact details for competent authorities has been updated.
    • Appendix E – Changes have been made to the list of UN Specification Packaging Suppliers (E.1) and the Package Testing Facilities (E.2).
    • Appendix F – The list of Sales Agents (F.2), IATA Accredited Training Schools (F.3-F.5) and IATA Authorized Training Centers (F.6) have been revised.
    • Appendix H is new to the IATA Dangerous Goods Regulations.  It has been added to provide details of changes to go into affect as of January 1, 2017 in the 58th Edition of the IATA Dangerous Goods Regulations.  Changes include:
      • Allowance for Shipper to classify a substance differently than shown in the List of Dangerous Goods if based on testing and approved by the National Authority.
      • Inclusion into Division 4.1 of classification criteria for polymerizing substances.
      • The entries for “engines” currently assigned to UN 3166 have been assigned to new UN numbers:  Division 2.1, Class 3, or Class 9; depending on the type of fuel or fuel cell.  New packing instructions have been added for these entries.
      • A number of new and modified special provisions.
      • Replacement of the existing lithium battery handling label with a multi-modal lithium battery mark and the introduction of a new Class 9 label specifically for lithium batteries.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Below is a short YouTube video (just 5 minutes) prepared by IATA that summarizes these significant changes.

https://youtu.be/1fFQsx64TXU

If you ship dangerous goods by air IATA regulations at 1.5.0 require training every two year (biennial) for all Shippers and Packers of dangerous goods.  Contact me to provide you with this training.

The Size Requirements for Package Marks in the IATA Dangerous Goods Regulations

If you ship HazMat/dangerous goods by air, you are likely familiar – or should be – with the Dangerous Goods Regulations of the International Air Transport Association (IATA).  Though not officially recognized by PHMSA/USDOT, its basis on the International Civil Aviation Administration (ICAO) Technical Instructions – and that it is even more strict in some cases – ensures that the IATA DGR are acceptable for compliance when shipping HazMat/dangerous goods within the U.S. (note that you must still comply with the Hazardous Material Regulations of the PHMSA/USDOT whenever you transport or offer for transport a HazMat/dangerous good within the U.S.)

One important requirement of the IATA Dangerous Goods Regulations is to mark packages to indicate the type and quantity of dangerous goods within and to communicate other information required by the DGR.  Package mark requirements include but are not limited to the following:

  • Identification number.
  • Proper shipping name.
  • Name and address of shipper (consignor).
  • Name and address of receiver (consignee).
  • Technical name of dangerous good if a star appears near the proper shipping name in the Dangerous Goods List.
  • Net quantity of dangerous good in each package.
  • More…

Just as important as providing the required marking on the outside of the package or overpack is to ensure it meets the minimum size requirements of the Dangerous Goods Regulations.

This table summarizes the Size Requirements of the IATA Dangerous Goods Regulations for Package Markings.

Note the impending deadline (January 1, 2016) for the minimum size requirement for both “Overpack” and “Salvage”.

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
815.821.1550
Info@DanielsTraining.com
https://www.danielstraining.com/

Make certain the dangerous goods packages you ship are marked correctly and that the markings meet the minimum size requirements of the IATA Dangerous Goods Regulations.

 

Air Shipment of Samples with Ethanol

Not every question I receive comes from an industrial facility embedded on the outskirts of some major city or from a busy transportation hub in the nation’s heartland.  Some, like this one on March 14th, 2015, come from exotic locations I can only hope to visit some day.

Hi Daniel,

I am currently on a research cruise and accumulated a large amount of samples preserved in 95% ethanol. By the end of the cruise I will have around 20 samples of 250 ml of ethanol for a total of 5L. The samples need to be shipped in dry ice (preferably by air) from San Diego to Hawaii. I was wondering if you knew of a way to do this. It clearly exceeds the excepted and limited quantity, and I don’t have access to a trained haz-mat officer at port.
Thank you in advance for your help.
You can tell I was impressed (3.14.15):
Wow!  What an interesting question.  I happen to be in the office today (it’s Saturday morning here in Illinois) so I will do my best to shoot you an answer later today.
Here’s what I sent to him later that day.  (Yeah, I work Saturdays.):
First of all, I made the determination based on the available information that the ethanol is a Class 3, Packing Group II.  Also, I assume you intend to ship this per the IATA Dangerous Goods Regulations even though the transportation you describe could be subject solely to PHMSA/USDOT regulations if you could find an air carrier that does not require compliance with the IATA DGR.
Note from Dan:  The domestic transportation of a hazardous material is always subject to the Hazardous Material Regulations of the the PHMSA/USDOT.  A domestic shipper of HazMat by air will likely also have to comply with the Dangerous Goods Regulations of IATA; this depends on your air carrier since most - but not all - require compliance with the IATA DGR.  The international transportation of a HazMat (called dangerous goods) by air must comply with the IATA DGR.  The direct transportation of a HazMat from San Diego, CA to Hawaii is not international transportation and therefore is only required to comply with the HMR unless the carrier requires compliance with the IATA DGR as well.  Got it?
Based on that assumption and the information you provided, I agree with you that the total quantity of 5 L exceeds the limits for shipping Ethanol, PG II as a Limited Quantity (max net quantity of 1 L) and as an Excepted Quantity (max inner packaging of 30 g/30 ml and max outer packaging of 500 g/500 ml) and therefore may not take advantage of those exceptions.  It is within the quantity limits for shipment as fully regulated dangerous good on a passenger aircraft and, of course, on cargo aircraft.
Special Provision A180 (Column M of the List of Dangerous Goods) reads as follows:

A180 Non-infectious specimens, such as specimens of mammals, birds, amphibians, reptiles, fish, insects and other invertebrates containing small quantities of UN 1170, UN 1198, UN 1987, or UN 1219 are not subject to these Regulations provided the following packing and marking requirements are met:

(a) specimens are:

1. wrapped in paper towel and/or cheesecloth moistened with alcohol or an alcohol solution and then placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30 mL; or

2. placed in vials or other rigid containers with no more than 30 mL of alcohol or an alcohol solution;

(b) the prepared specimens are then placed in a plastic bag that is then heat–sealed;

(c) the bagged specimens are then placed inside a another plastic bag with absorbent material then heat sealed;

(d) the finished bag is then placed in a strong outer packaging with suitable cushioning material;

(e) the total quantity of flammable liquid per outer packaging must not exceed 1 L; and

(f) the completed package is marked “scientific research specimens, not restricted Special Provision A180 applies”.

The words “not restricted” and the special provision number A180 must be included in the description of the substance on the Air Waybill as required by 8.2.6, when an Air Waybill is issued.

Note here that the total quantity of flammable liquid per outer packaging cannot exceed 1 L which is less than your proposed total quantity of 5 L and the max allowed quantity of ethanol inside the package is 30 mL which also exceeds your 250 mL/vial.
It appears that you will be required to ship the samples as a dangerous good subject to full regulation under the IATA DGR unless you can reduce the size of both the inner and outer packaging.
Also, must follow packing instruction 954 for the Dry Ice.
I wish I had better news for you.  If you could just collect smaller samples, they might not be subject to the regulations and then the dry ice would not be either.
As for shipping it as a dangerous good, that should not be too difficult.  Contact Fed Ex or UPS.
Please don’t hesitate to contact me with any other questions.
He fired back on March 16th:
Hi Daniel, I apologize for the ongoing requests for advice.So would it help if I don’t use dry ice AND reduce the sample volume
from 250ml of ethanol per bottle to 30ml of ethanol per vial?How would I have to pack this then? Can I place 30 vials with 30ml
ethanol in a bag with absorbent material, then place the bag into a
box, and then place that box into another box that is aligned with
absorbent material and a plastic bag?

Thank you for your help.

A quick reply the same day:
If you are able to reduce the volume of ethanol in each vial to 30 ml and you don’t use dry ice, then I believe your best option is to meet the packaging requirements of Special Provision A180 (read them carefully, what you propose is not quite what the regulations require).  If you are able to do this, then your consignment is not subject to the Dangerous Goods regulations of IATA.

A problem I just discovered is that – based on a quick review of the regulations – USDOT does not recognize the same Special Provision for UN1170 as IATA.  It appears that even at 30 ml/vial you would need to ship it as a Limited Quantity which provides some relief from the HazMat regulations, but not as much as SP 180 offers.  If you are shipping to, from, or w/i the U.S. you must comply with USDOT regulations.
I don’t mind the questions, keep them coming.
Whatever you decide, please keep me in mind the next time you need HazMat/IATA/IMO training.
Some more information was needed (3.17.15):
Hi Daniel,

thank you for the detailed answer. I really appreciate it.
Ok, so what are the packing regulations for Limited Quantity (30mL vials for up to 1L)? I hate to ask these trivial things, but the internet in the middle of the Pacific is not the greatest and hence it is quite hard to google these things.
This cruise is called ABYSSLINE cruise and its onboard the R/V Thomas Thompson. We have 3 different cruise blogs:
You can also follow all the activities under the twitter hashtag #AB02
We are currently at 12deg 01.642′ N , 117deg 19.513′ W.
Thanks for the help.
My reply that same day:
Packaging requirements for a Limited Quantity of ethanol can be found at 49 CFR 173.150 and are fairly simple:

  • Non-bulk packaging (i.e. <119 gallons).
  • Combination packaging (i.e. inner packaging and outer packaging).
  • “strong outer packaging”
  • Limits on volume of inner packaging based on packing group of HazMat.
  • Shipment by air has additional general packing requirements.
  • Shipment by air requires labels and markings in addition to Limited Quantity marking.

However, you will likely also have to comply with requirements of IATA Dangerous Goods Regulations (depending on the requirements of your air carrier).  I have access to those regulations but cannot print and send them as I can the USDOT.  IATA regulations are similar to USDOT but may have more restrictions and may also have Carrier variations not included in USDOT.

I am sharing this email with someone (Ron Harvey of Echelon Environmental) who may be able to help you out with the actual shipment of this HazMat.
Thanks for the information about your cruise.
And that’s where my involvement ended.  My inquisitor contacted Ron who assisted him through the final steps of packaging and shipping the hazardous material/dangerous good.

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

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Please don’t hesitate to contact me with your questions about the transportation of dangerous goods/hazardous materials.

Required Information on the Shipper’s Declaration of Dangerous Goods

Section 8 of the International Air Transport Association (IATA) Dangerous Goods Regulations require the shipper of a dangerous good to provide the information specified by the regulations for each and every consignment of dangerous goods unless an exception is provided at 8.0.1.2.  This information may be provided in one of two formats:

  • By EDP (electronic data processing) or EDI (electronic data interchange) techniques, if the operator agrees.

Or…

  • By the use of the “Shipper’s Declaration of Dangerous Goods”.

The purpose of this article will be to identify the information that a shipper must provide to the operator when offering a dangerous good for transportation by air.  The same information must appear on the Shipper’s Declaration of Dangerous Goods or in the form of an EDP or EDI. (more…)

Changes to the 56th Edition of the IATA DGR Related to Lithium Batteries

The 56th Edition of the Dangerous Goods Regulations of the International Air Transport Association (2015) contains many significant changes.  None of them followed with more widespread interest than those related to the transportation by air of lithium batteries.  Below is a summary of the changes to the IATA DGR related to the transportation of lithium batteries.

2.3—Dangerous Goods Carried by Passengers or Crew

The provisions applicable to portable electronic devices, including medical devices containing lithium batteries and spare batteries have been restructured to set the requirements out in three parts:

1. Spare lithium batteries above a specified size, which are permitted only with the approval of the operator, and that must be in carry-on baggage;

2. Lithium battery powered electronic devices containing batteries above a specified size, which are permitted only with the approval of the operator; and

3. Portable electronic devices (PED) and spare batteries for such devices where the batteries are at or below the specified size which are permitted without operator approval. PED may be in checked or carry-on baggage. All spare batteries must be in carry-on baggage.

4—Identification
4.2—List of Dangerous Goods

Amendments to the List of Dangerous Goods include:

  • Removal of the packing group from all of the entries for articles that had been assigned a packing group, e.g. batteries, containing sodium, lithium batteries; mercury in manufactured articles.
  • The entry UN 3090, Lithium metal batteries has been amended to show “forbidden“ across columns I/J to identify that these batteries are now restricted to Cargo Aircraft Only. There is no change to the entries for UN 3091, lithium metal batteries packed with equipment or lithium metal batteries contained in equipment.
4.4—Special Provisions

A201 —is a new special provision assigned against UN 3090 Lithium metal batteries to identify that lithium metal batteries may be carried on a passenger aircraft subject to specific limitations on the size and quantity of lithium metal batteries in a package and per consignment. The detail of these limitations are set out in the Supplement to the ICAO Technical Instructions.

5—Packing

PI 966 and PI 969 —These packing instructions apply to lithium ion and lithium metal batteries packed with equipment respectively. The provisions have been revised to clarify that the number of lithium batteries in a package must not exceed the number for the equipment’s operation plus two spares.

PI 968 —In accordance with the change in Table 4.2 to limit UN 3090, Lithium metal batteries to cargo aircraft only, the provisions of PI 968 have been revised to identify that these batteries are not permitted on passenger aircraft. This includes a requirement that packages prepared in accordance with Section II must bear a Cargo Aircraft Only label in addition to the lithium battery handling label, and also that packages in Section II are subject to the conditions for consolidations and removes the allowance for these packages to be placed in a unit load device, except by the operator.

8—Documentation

8.1.6.11.7 —A paragraph has been added to clarify that for shipments of lithium batteries prepared under Section IB of PI 965 and PI 968 that the information required on the additional document may be included on the Shipper’s Declaration or may be on an additional document.

That’s it for changes referenced in the Introduction to the 56th Edition of the IATA Dangerous Goods Regulations.  Please note that the list is intended to assist the Shippers, Packers, and Operators to identify the main changes introduced in the 56th Edition for 2015 and must not be considered an exhaustive listing.

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

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/