International Transportation of Dangerous Goods

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:

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.

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

Info@DanielsTraining.com

https://www.danielstraining.com/

The Lithium Battery Test Summary

The regulations for the transportation in commerce of lithium cells and batteries requires each cell or battery to be of the type proved to meet the requirements of specific test procedures of the United Nations. Under current regulations it is the responsibility of the battery manufacturer to perform the tests, maintain a record of satisfactory completion, and make such records available to an authorized representative upon request.  As of January 1, 2020, this responsibility expands (in some regulations) to include subsequent distributors of lithium cells and batteries.

The purpose of this article is to identify the regulatory requirements for applicable persons to test lithium a lithium cell or battery, maintain records of the test summary, and to provide a copy of the test summary upon request.
(more…)

Q&A: What are the the specifications in the IMDG Code and USDOT/PHMSA regulations for the Division 4.1 Flammable Solid placard?

This email came from India on February 12, 2019:

(India!)

Dear Sir,

Good Morning!

We are the manufacturer of Aluminium powder (UN1309, Aluminum powder, coated, 4.1, PG II). We request your help to know the details from the Hazardous material transportation regulation of IMDG, 2018 Edition 39 -18 Amendment or 49 CFR 172.546 (Class 4 placards specification). Please send the placard specification for class 4 details from the above latest regulations. Now we are following old regulatory placard specifications for the shipments. It is most Urgent. We are expecting your positive reply.

Thanking You.

Well, I’m just a guy from the Midwest so getting an email from India requesting my help is pretty cool. I had to reply right away.

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

  • Your question refers to both the International Maritime Organization and their Dangerous Goods Code (IMDG, 2018 Edition 39 -18 Amendment) and the Hazardous Materials Regulations (October 2018 Edition) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).
  • The required specifications for the Division 4.1 placard are almost – but not quite – the same for both the IMO and the USDOT/PHMSA.
  • Hazardous Materials Regulations of USDOT/PHMSA:
    • 49 CFR 172.519 for general specifications and §172.546 for the Flammable Solid (Division 4.1) placard.
    • Outer dimensions of 250 mm x 250 mm.
    • Line inside the edge 12.5 mm from outside edge.
    • Class or division symbol must be as shown at §172.546.
    • Hazard class number in bottom point of placard must be at least 41 mm high.
    • Any words that appear on placard must be at least 41 mm high.
  • IMDG Code:
    • 5.3.1.2.1 for placard specifications and 5..2.2.2 for specimen labels.
    • Outer dimensions of 250 mm x 250 mm.
    • Line inside the edge 12.5 mm from outside edge.
    • Class or division symbol shall be positioned and sized in proportion to those shown in 5.2.2.2.2.
    • Hazard class or division number in bottom point of placard must be at least 25 mm high.

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.

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There is much more information in the regulations than I am able to summarize here.

I suggest you contact ICC The Compliance Center to purchase the required placards. Indicate what you need them for and they will be able to sell you what you need.

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

That seemed to do it!

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?

Class 9 Lithium Battery label

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

Info@DanielsTraining.com

https://www.danielstraining.com/

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.

Class 9 Miscellaneous label

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.

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.

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

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

Info@DanielsTraining.com

https://www.danielstraining.com/

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.

58th edition of IATA DGRBut 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.

7.2.2.4 IATA DGR 54th Edition

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.
  • 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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His reply late that day seemed to indicate all was well:

Daniel,
Thanks for your information.
It help so much.

Conclusion:

I never did find out the end of the story but I’m hopeful once he was able to show the airport personnel the applicable regulations (for that time) he was able to get his hazardous material on its way to its destination.  This is a good example of how knowledge of the regulations not only ensures compliance but is critical in working through misunderstandings such as this.

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.

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

Info@DanielsTraining.com

https://www.danielstraining.com/

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.

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Q&A: Is stoddard solvent a marine pollutant?

A question posted to pcjr101@yahoo.com [hazmat101] hazmat101@yahoogroups.com on November 1, 2017:

Is Stoddard Solvent a marine pollutant per DOT or IMDG Code? Under what scenarios? What about a mixture with it?  References to guidance documents are appreciated.

Stoddard Solvent is sometimes referred to a White Spirit or Turbine Substitute

49 CFR Appendix B to 172.101 (List of Marine Pollutants):Marine Pollutant Mark

  • Lists “White Spirit, low (15-20%) aromatic) as a Marine pollutant.
  • Lists “Turbine” (UN299) as a Marine Pollutant
  • Does not list “Turpentine Substitute” (UN1300) as a Marine Pollutant.

The IMDG  Code Index:

  • Lists “White Spirit, low (15-20%) aromatic) (UN1300) as a Marine pollutant.
  • Lists “White Spirit” (UN1300)  as a Marine pollutant.
  • Lists “Turpentine” (UN1299) as a Marine pollutant.
  • Lists “Turpentine Substitute” (UN1300) as a Marine pollutant.
IMDG Code 2018 Edition

2018 Edition of the IMDG Code

The IMDG Code Dangerous Goods List:

  • Lists UN1299 (Turpentine) as a marine pollutant
  • Does not list UN1300 (Turpentine Substitute) as a marine Pollutant.

Thanks in advance.

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

Info@DanielsTraining.com

https://www.danielstraining.com/

Note: this group allows its members to post questions like this one and then hope for answers from others within the group.  What follows are some of those answers with mine at the end.

First to answer…

Stoddard Solvent is Mineral Spirits. UN 1268, PETROLEUM DISTILLATES , N.O.S. (Naphtha solvent), 3, PG III, combustible liquid

And…

Check the SDS for that product

And then me:

I will try to answer your question.  Please see below.

General information:

  • White spirit or mineral spirits, also known as mineral turpentine, turpentine substitute, petroleum spirits, solvent naphtha, Varsol, Stoddard solvent, or, generically, “paint thinner”.

USDOT/PHMSA:

  • To be a marine pollutant per USDOT/PHMSA regulations it must be each of the following:
    • Identified by name as a marine pollutants (appendix B to Hazardous Materials Table at 49 CFR 172.101).
    • 10% or more in solution if marine pollutant.  1% or more in solution if a severe marine pollutant (identified by ‘PP’ in column 1 of list).
    • Transported in any size packaging by vessel or transported in a bulk packaging by highway, rail, or air.
  • White Spirit, low (15-20%) aromatic is identified by name as a marine pollutant.
  • Turpentine is identified by name as a marine pollutant.
  • Read:  What is a Marine Pollutant?

It is impossible to determine if your product is a marine pollutant per USDOT/PHMSA regulations without first identifying exactly what it is and its concentration, packaging, and mode of transport.

IMO:
  • To be a marine pollutant per the IMO dangerous goods code (IMDG), it must be one of the following:
    • Display a ‘P’ in the ‘MP’ column for its entry in the Index.
    • Display a ‘P’ in column 4 of the Dangerous Goods List (DGL) for its entry.
    • Meet the criteria of the UN Recommendations (2.9.3) for an Environmentally Hazardous Substance (aquatic environment).
  • If identified as a marine pollutant in either the Index or the DGL it is not subject to regulation as a marine pollutant if it does not meet the UN criteria.
  • If not identified as a marine pollutant in either the Index or the DGL it is subject to regulation as a marine pollutant if it is proven to meet the UN criteria.
  • White Spirit, low (15-20%) aromatic, white spirit, & TURPENTINE are all identified as a marine pollutant in the Index.

Unless the shipper has data to indicate it does not meet the criteria for an environmentally hazardous substance (aquatic environment), then the above identified substances must be shipped as a marine pollutant when subject to the IMDG Code.

And…
  • 49 CFR 172.101, Appendix B (4):  if not listed as a marine pollutant but meets criteria for marine pollutant per IMDG, then may be transported as marine pollutant within U.S.
  • 49 CFR 172.101, Appendix B (5):  if listed as a marine pollutant but does not meet criteria for marine pollutant per IMDG, then may be excepted from transport as marine pollutant within U.S. with approval from PHMSA/USDOT.
  • The International Air Transport Association (IATA) uses the same UN criteria as the IMO for classifying a marine pollutant.
More information:

I hope this helps.

Please contact me with any other questions.

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You’ll look real smart recommending my articles!

Conclusion:

The classification of a marine pollutant is complicated.  It is made more so by the fact that the classification of a marine pollutant of USDOT/PHMSA within the U.S. differs from the international regulations of IATA & IMO. That means the requirements for transport of a HazMat within the U.S. may differ from those outside of the U.S.  Make certain you determine the applicable regulations and them comply with them.

General Provisions for Cargo Transport Units

General Provisions for Cargo Transport Units

A person who offers a hazardous material (HazMat) for transport to, from, or through the U.S. must comply with the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).  If a person offers for transport a dangerous good (dangerous good is the term used by international regulations to refer to what we in the U.S. call a hazardous material) for transport by vessel in international waters that person must also comply with the International Maritime Organization (IMO) and its Dangerous Goods Code (IMDG Code).

The challenge for a shipper is knowing when to comply with the HMR and when compliance with the IMDG Code is required.  To summarize the requirements: a shipper may comply with the IMDG Code – even for transport within the U.S. if all requirements of the IMDG Code are met and the shipper complies with 49 CFR 171.22 and §171.25.

The purpose of this article is to explain the general provisions for use of cargo transport units (CTUs) to transport dangerous goods by vessel in compliance with Chapter 7.3.2 of the IMDG Code.

Before we begin…

This article is based on the 2018 edition of the IMDG Code containing amendments 39-18.  This edition alone must be used to determine compliance in 2020 but is optional for use in 2019.  The 2016 edition, which includes amendments 38-16, is also optional for use in 2019. It alone was mandatory in 2018.  Confused?  Read:  The IMDG Code Amendment Cycle.

For the purposes of this article it doesn’t matter which edition is used. The effective regulations are unchanged between the two.

Scope:

The regulations of Chapter 7.3 of the IMDG Code apply to those persons responsible for the loading of the CTU.  This may be the shipper, a freight-forwarder, the motor carrier responsible for highway transport, or shore-based personnel at the port of departure; it does not have to be the person identified as the shipper on the Dangerous Goods Transport Document.

A cargo transport unit is defined at 1.2.1 of the IMDG Code.

Cargo transport unit means a road transport tank or freight vehicle, a railway transport tank or freight wagon, a multimodal freight container or portable tank, or an MEGC.

For the purposes of this article think of a CTU as a big metal box used to contain packagings of dangerous goods.cargo transport unit

General Provisions for Cargo Transport Units:

By their very nature “General Provisions” don’t get into specifics – that’s saved for later.

  • CTU must be “strong enough to withstand the shocks and loadings normally encountered during transport”.  This requires a knowledge of the conditions to be expected during the anticipated journey.
  • CTU must be constructed so as to prevent the loss of the contents.
  • Where appropriate, CTU must have devices that will assist in the securing and handling of the dangerous goods it contains.  In other words, whatever devices are necessary to secure the dangerous goods within the CTU must be available.
  • CTU must be adequately maintained.
  • If the CTU is a “container” per the International Convention for Safe Containers (CSC) 1972, then the applicable provisions of the CSC must be followed.  However, the CSC does not apply to offshore containers handled in open seas.  Those must meet requirements established by the competent authority (USDOT/PHMSA in the U.S.) An offshore container designed to be handled in open seas shall be clearly marked: “OFFSHORE CONTAINER” on the safety approval plate.

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

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Daniels Training Services, Inc.

815.821.1550

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https://www.danielstraining.com/

Conclusion:

Pretty simple and pretty vague.  Remember, compliance with chapter 7.3.2 is the responsibility of the person(s) who load the cargo transport unit with dangerous goods to be transported by vessel. If this is you, make certain all personnel are knowledgeable not only of these regulations but all of the IMDG Code applicable to their job – which includes training.

In my next article I’ll address the Packing of Cargo Transport Units

Packing of Cargo Transport Units for Transport by Vessel per the IMDG Code

Packing of Cargo Transport Units for Transport by Vessel per the IMDG Code

A person who offers a hazardous material (HazMat) for transport to, from, or through the U.S. must comply with the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).  If a person offers for transport a dangerous good (dangerous good is the term used by international regulations to refer to what we in the U.S. call a hazardous material) for transport by vessel in international waters that person must also comply with the International Maritime Organization (IMO) and its Dangerous Goods Code (IMDG Code).

The challenge for a shipper is knowing when to comply with the HMR and when compliance with the IMDG Code is required.  To summarize the requirements: a shipper may comply with the IMDG Code – even for transport within the U.S. if all requirements of the IMDG Code are met and the shipper complies with 49 CFR 171.22 and §171.25.

The purpose of this article is to explain the requirements for the loading of cargo transport units (CTUs) for transport by vessel in compliance with Chapter 7.3.3 of the IMDG Code.

Before we begin…

This article is based on the 2018 edition of the IMDG Code containing amendments 39-18.  This edition alone must be used to determine compliance in 2020 but is optional for use in 2019.  The 2016 edition, which includes amendments 38-16, is also optional for use in 2019. It alone was mandatory in 2018.  Confused?  Read:  The IMDG Code Amendment Cycle.

For the purposes of this article it doesn’t matter which edition is used. The effective regulations are unchanged between the two.

Scope:

The regulations of Chapter 7.3 of the IMDG Code apply to those persons responsible for the loading of the CTU.  This may be the shipper, a freight-forwarder, the motor carrier responsible for highway transport, or shore-based personnel at the port of departure; it does not have to be the person identified as the shipper on the Dangerous Goods Transport Document.

A cargo transport unit is defined at 1.2.1 of the IMDG Code.

Cargo transport unit means a road transport tank or freight vehicle, a railway transport tank or freight wagon, a multimodal freight container or portable tank, or an MEGC.

For the purposes of this article think of a CTU as a big metal box used to contain packagings of dangerous goods.cargo transport unit

The general provisions for cargo transport units were addressed in an earlier article

Packing of Cargo Transport Units:

  • CTU must be checked prior to use to ensure it is fit for intended purpose.
  • Interior and exterior of CTU must be inspected prior to loading to ensure their is no damage that could affect its integrity or that of the packages it is to contain.
  • Condition of packages.
    • Packages must be examined before loading.  Packages shall not be loaded in CTU if found to be damaged, leaking, or sifting.
    • Excessive water, snow, ice or foreign matter adhering to packages must be removed before packing into CTU.
    • If handling provision “keep as dry as reasonably practicable” (H1) is assigned in column 16a of the Dangerous Goods List for a dangerous good to be loaded in a CTU, then the CTU must be kept as dry as reasonably practicable.
  • Drums of dangerous goods loaded in a CTU must always be stowed in an upright postion unless otherwise authorized by the competent authority (USDOT/PHMSA in U.S.).
  • More on packages.
    • CTU must be loaded in compliance with 7.3.4 Segregation provisions within cargo transport units.  Incompatible dangerous goods – or other non-dangerous goods must be segregated.
    • Specific loading instructions such as: orientation arrows, not to be double stacked, keep dry or temperature control requirements shall be met.
    • Liquid dangerous goods must be loaded below dry dangerous goods whenever possible.
  • Securing and restraining packages within CTUs.
    • Packaged dangerous goods and unpackaged dangerous articles must be secured within the CTU to prevent any movement during transport that would change their orientation or cause them to be damaged.
    • Methods of restraint may include: fastening straps, sliding slatboards, adjustable brackets, and filling any voids by the use of dunnage or by blocking and bracing.
    • If dangerous goods are transported in the CTU with other goods (e.g., heavy machinery or crates), all goods must be secured to prevent the release of dangerous goods.
    • If restraints such as banding or straps are used they must not be over-tightened to cause damage or deformation of the package or the securing points (such as D-rings) within the CTU.
    • Packages must be packed to minimize the likelihood of damage to fittings during transport.  Fittings on packages must be adequately protected.
    • If restraints such as banding or straps with integral container fittings are used, packer must use care to ensure the Maximum Securing Load (MSL) of the fittings is not exceeded.

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  • Stacking of packages.
    • Packages must not be stacked unless designed for stacking.
    • Exercise caution when stacking packages of different stacking designs.
    • Load bearing devices must be used to prevent a stacked package from damaging the package below.
  • Cargo shall be entirely contained within the CTU without overhang or projections.  However, oversized machinery (e.g., tractors and vehicles) may overhang or project outside of the CTU if the dangerous goods within the machinery cannot leak or spill outside of the CTU.
  • Care must be taken during preparation for transport and loading of packages to prevent damage. Damaged or leaking packages shall not be transported.Cargo Vessel
  • If dangerous and non-dangerous goods are packed in the same CTU, dangerous goods should, whenever possible, be packed near the doors with marks and labels visible.
  • If the doors of a CTU are locked it shall be possible to open them without delay in an emergency.
  • When venting of the CTU is required venting devices shall be kept clear and operable.
  • CTUs containing any amount of a dangerous good shall be marked and placarded per chapter 5.3 of the IMDG Code.
  • Irrelevant marks, labels, placards, orange panels, signs and marine pollutant marks shall be removed, masked or removed before packing a CTU.
  • CTU shall be packed so that cargo (includes non-dangerous goods) is uniformly distributed consistent with the CTU Code.
  • If the CTU is packed with Class 1 Explosives, it must be “closed” as defined at 7.1.2 of the IMDG Code.
  • If the CTU is packed with Class 7 Radioactive, the transport index and, if applicable, the criticality safety index, shall be limited according to 7.1.4.5.3 of the IMDG Code.
  • The person(s) responsible for packing dangerous goods in a CTU shall provide a “container/vehicle packing certificate” per 5.4.2 of the IMDG Code. This document is not required for tanks.
  • Flexible bulk containers are not allowed to be transported in CTUs per 4.3.4 of the IMDG Code.

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

Info@DanielsTraining.com

https://www.danielstraining.com/

Conclusion:

Sometimes the regulations defy any attempts at summation and simplification and I wind up listing them almost verbatim; that is the case here. Remember, compliance with chapter 7.3.3 is the responsibility of the person(s) who load the cargo transport unit with dangerous goods to be transported by vessel. If this is you, make certain all persons receive initial and triennial training as required by the USDOT/PHMSA and the IMDG Code.

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…)