International Transportation of Dangerous Goods

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.

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

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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

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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

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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.

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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.

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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…)

Q&A: Using the Marine Pollutant Marking by Land and Water

Here’s a question someone posted to Hazmat101, a Yahoogroup on December 1, 2015:

To  compare notes.

  1. Are marine pollutant placards required on a truck that contains non-bulk packages on its way to the port per 49 CFR? What if the truck has placards for Flammable packages?
  2. Are marine pollutant placards required on a freight  container with non-bulk packages shipped by water from the continental  U.S. to Hawaii  under 49 CFR (not the IMDG code)? What if the freight containers has placards for Flammable packages?
  3. Are marine pollutant placards required on a freight  container with non-bulk packages shipped by water under  the IMDG code? What if the freight container has placards for Flammable packages?

Citations appreciated.

Thanks in advance.

My reply that day (I must have been in the office!):
  • Just a point of clarification, the Marine Pollutant marking is not a label nor a placard even if it is the size of one or the other.  It is a marking (49 CFR 172.322).
  • Marine Pollutant MarkingThe marine pollutant marking is not required on a vehicle that is transporting non-bulk packagings by highway since per 49 CFR 171.4 the hazardous material regulations do not apply to a Marine Pollutant transported by highway (or rail or air) in a non-bulk packaging.  It might be OK to display the Marine Pollutant marking on the vehicle even if it is not required, but I am not certain.  The presence of the Flammable Liquid placard does not impact display of the Marine Pollutant marking.
  • A non-bulk packaging of a Marine Pollutant shipped by vessel is subject to the hazardous material regulations and therefore the non-bulk packaging and the freight container must bear the Marine Pollutant marking.  Marine Pollutant marking is not required on some non-bulk packagings of less than or equal to 5 L or 5 Kg (172.322(d)), however, a freight container of non-bulk packagings that do not have the Marine Pollutant marking due to 49 CFR 172.322(d) will still need to be marked with a placard-sized Marine Pollutant marking on all four sides (172.322(c)).The presence of the Flammable Liquid placard does Marine Pollutant Marking and Class 3 Placardnot impact display of the Marine Pollutant marking.
  • IMDG code requirements are the same as USDOT/PHMSA.  Non-bulk packaging of 5 liters or less or 5 Kg or less need not display the Marine Pollutant marking (5.2.1.6).  However, the freight container they are packed in must display the Marine Pollutant marking (5.3.2.3).  The presence of the Flammable Liquid placard does not impact display of the Marine Pollutant marking.
I hope this helps.  Please don’t hesitate to contact me with any other questions.
Daniel Stoehr
Daniels Training Services

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Cargo tank truck with Class 9 placards and the Marine Pollutant markingAnd a post from someone else in the group that same day as well:
PC:
-The 49CFR never calls it a placard but in 49CFR 172.322(c) it talks about a truck being labeled with the marine pollutant mark.-49CFR 171.4 As long as you are on the road and not the water marine pollutants in non-bulk packaging don’t have to follow the rules for marine pollutants.-49CFR 172.322 has rules for Marine Pollutants.

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

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Use of Package Orientation Arrows in the IATA Dangerous Goods Regulations

Logo of the International Air Transport AssociationThe 57th Edition of the Dangerous Goods Regulations (DGR) of the International Air Transport Association (IATA) specifies the requirements for, and exclusions from use of, package orientation arrows on certain packages of dangerous goods when transported by air.

The IATA DGR is a creation of the airline industry.  It is based on - and in some instances more strict than - the Technical Instructions of the International Civil Aviation Administration.  Compliance with the IATA DGR is required for most dangerous goods transportation by air for both domestic and international transportation.

The purpose of this article is to explain the use of package orientation arrows – and the conditions when they are not required – as regulated by the 57 Edition of the IATA DGR at 7.2.4.4 and 5.0.2.13.3.

Make certain you are referring to the current edition of the IATA DGR for compliance.  The 57th Edition is effective only for calendar year 2016 (January 1, 2016 to December 31, 2016).

Package orientation arrows, or as they are referred to in the DGR: “Package Orientation ” (This Way Up) labels, are required – with some exclusions – on only two types of packaging, and then, only if they contain liquid dangerous goods:

  • Combination packaging
  • Overpack
The requirement for an overpack with liquid dangerous goods to display orientation arrows differs slightly from that of the USDOT/PHMSA which only requires orientation arrows on an overpack if it contains packagings that are required to display orientation arrows.  Read:  Orientation Arrows on HazMat Packaging.
REQUIREMENTS FOR DISPLAY OF PACKAGE ORIENTATION LABELS:
  • Must meet the specifications of Figure 7.4.D or Figure 7.4.E of the DGR (see below).
  • Must be displayed on two opposite sides of the package or overpack.
  • Must show the proper package orientation for the closures of the inner packaging to be in the upright position.
  • From 7.4.4 and 7.4.5:
    • Minimum dimensions:  74 x 105 mm
    • Color:  Red (Pantone Color No. 186U) or Black on a contrasting background

Figure 7.4.D

Package Orientation Figure 7.4.D

Figure 7.4.E

Package Orientation Figure 7.4.E

ADDITIONAL OPTIONS FOR DISPLAY OF PACKAGE ORIENTATION LABELS:20151119_113303
  • The words “Dangerous Goods” may be inserted below the line at the bottom of the label.
  • The words “THIS END UP” of “THIS SIDE UP” may also be displayed on the top of the package or overpack.

PACKAGE ORIENTATION LABELS ARE NOT REQUIRED ON THE OUTER PACKAGING OF COMBINATION PACKAGINGS CONTAINING:

  • Inner packagings each of 120 mL or less if there is sufficient absorbent material between the inner and outer packagings to completely absorb the liquid contents.
  • Inner packagings of 500 mL or less that are gas tight such as:  tubes, bags, or vials and that are opened by breaking or puncturing.
  • Division 6.2 Infectious Substances in primary receptacles of 50 mL or less.
  • Hazard Class 7 Radioactive.

The above exclusions only apply to combination packaging.

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transportation of HazMat by air

An Operator may have their own variations to the IATA DGR

ARE WE DONE?  NO.  WE STILL MUST CONSIDER STATE AND OPERATOR VARIATIONS:

Paragraph 2.8.0 of the DGR reads:

States and operators may submit variations to these Regulations.  These variations are listed in 2.8.2 and 2.8.4 respectively.

States (that’s nations to you and I) and operators (them that fly the planes) may manage dangerous goods transportation differently than the DGR.  Under certain conditions these variations have the same force as the DGR themselves.  The regulations pertaining to Package Orientation labels have three Operator Variations to consider:

  • ME-09 for Middle East Airlines:  Package orientation (This Way Up) labels must be used on any combination and single packaging containing dangerous goods (See 5.0.2.13.3 and 7.2.4.4).
  • SV-04 for Saudi Arabian Airlines:  Package Orientation (THIS WAY UP) labels must be used on any combination and single package containing liquid dangerous goods, excluding Infectious Substances if primary receptacles contain less than 50 mL and Radioactive Material (See 5.0.2.13.3 and 7.2.4.4).
  • VT-07 for Air Tahiti:  All dangerous goods packages must show the package orientation label (“This way up” label) and two hazard label(s) on two opposite sides (see 7.2.4.4).
A shipper of dangerous goods must comply with these operator variations only if said operator is used for the transport of dangerous goods.

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

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If the transport of your dangerous goods (aka: hazardous materials) is to be transported by air you must comply with the regulations of the International Air Transport Association.  Learn what you need to know to ship dangerous goods by air and meet the biennial (every two years) training requirement of IATA for shippers and packers of dangerous goods (found at subsection 1.5 of the DGR) by scheduling my Onsite Training.

Q&A: Segregation of Limited Quantities

A question from a customer of my ONSITE TRAINING on October 15th, 2015:

Hey Daniel,

I just had a quick question regarding limited quantities.  If I have 2 different hazmat items that normally could not be shipped together per the shipping regs but one qualifies under the limited quantities provision then are they able to be shipped together?  The way I interpret the regulations is that if an item is being shipped as a limited quantity it no longer has to be segregated due to the amount since we are also not having to label it as the hazardous material.

Thank you for your input.

(10.15.15)  I was certain he was right about the segregation requirements for a Limited Quantity but I wanted a little more information:

What mode of transportation?  What is the HazMat?

I believe you are right, but I’d like a little more information to be certain.
Dan
And the next day (10.16.15) I got it:

Hey Dan,

So the items are being shipped via ocean.  The 2 hazmat items that I am wanting to put on the same pallet are Nitric Acid(UN2031) and a limited quantity of Silver Nitrate (UN1493).  They will be in their own boxes but on the same pallet.

The International Maritime Organization

The International Maritime Organization regulates the international transportation of dangerous goods by vessel.

Thanks,

With that information I replied with “The Big Answer” on October 17th:

Sorry for the delay, I hope I’m not too late, but my answer confirms yours:

  • Nitric Acid UN2031 may not be shipped as a limited quantity or any other exception under the HMR.
  • Silver Nitrate UN1493 may be shipped as a limited quantity according to 49 CFR 173.152.
  • Interestingly, there is no mention in 49 CFR 173.152 of a limited quantity not being subject to the HazMat segregation requirements.
  • However, 49 CFR 176.80(b) contains an exception for limited quantities from the segregation requirements of the HMR.
  • Nitric Acid UN2031 may or may not be shipped as a limited quantity per the IMDG Code depending on its concentration.
  • Silver Nitrate UN1493 may be shipped as a limited quantity per the IMDG Code.
  • Per 3.4.4.2 of the IMDG Code, the segregation provisions of chapter 7.2 do not apply to packagings of limited quantities.
Therefore, I believe you are correct that the Silver Nitrate UN1493 as a limited quantity is not subject to the segregation requirements of the HMR or the IMDG Code.  However, Nitric Acid UN2031 may not be shipped as a limited quantity within the U.S. (though it may outside of the U.S in some situations) and will be subject to the segregation requirements of the HMR and the IMDG Code.
Non-bulk packaging of HazMat - Limited Quantity

The Limited Quantity marking

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

His final reply:
Thanks.  I’m only shipping the Silver Nitrate as the limited quantity with the acid which will be classified as hazardous.
Conclusion/Summary:
Notice from my answer on the 17th that I first determined compliance with the domestic regulations of PHMSA and then those of the International Maritime Organization in the IMDG Code.  The transportation to, from, or through the U.S. is subject to the Hazardous Material Regulations of PHMSA.  If it will also be shipped internationally – in this case on a vessel – then it will be subject to international regulations as well.  Here, the regulations of both PHMSA and the IMO were similar but that may not always be the case.

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/

It’s not uncommon that person who have received my Onsite Training follow-up with questions once they begin to apply the information from the training on their job.

Contact me to schedule Onsite Training required by the International Maritime Organization (IMO) every three years, the International Air Transport Association (IATA) every two years, or the Pipeline and Hazardous Materials Safety Administration (PHMSA) every three years.

Significant Changes to the International Maritime Dangerous Goods Code for 2016

Significant Changes to the International Maritime Dangerous Goods Code for 2016

December 31, 2015 is the end of the transition year for the 2012 Edition (36-12 Amendment) of the IMDG Code of the International Maritime Organization.  The code is updated every two years but is optional for its first and last year and mandatory for a third year that falls between the two voluntary compliance years.  Confused?  Check out the infographic contained in this short article and I think it will make more sense:  The IMDG Code Amendment Cycle.

The result is that as of midnight on December 31, 2015 the 2012 Edition of the IMDG Code is worthless and must be replaced with the 2014 Edition, Incorporating Amendments 37-14.

I bought my 2014 Edition of the International Maritime Dangerous Goods Code from Air Sea Container, Inc.  If - like me - you can't get the spiral bound copy, take it to a printer who can cut the spine and place it in a spiral binder.  It lies flat and is easier to work with.

There are many changes from the 2012 Edition to the 2014.  Significant changes are summarized below and explained further at this IMO publication:  Summary of Significant Changes to the Code 2014 Edition.  Or, if you wish to see all 217 pages of amendments:  IMDG Code Amendments 37-14.

  • Caution Radioactive MaterialsProvisions regarding the transportation by vessel of Class 7 Radioactive Materials have been revised to reflect the IAEA Regulations for the Safe Transport of Radioactive Material – 2012 Edition (IAEA Safety Standards Series SSR-6), which supersedes the IAEA 2009 Edition.
  • The format of the 4.2 Dangerous Goods List has been modified to replace column 16 Stowage and Segregation with two new columns:  16a Stowage and Handling and 16b Segregation.  Instead of descriptive text, the new columns now contain codes that are defined in Chapter 7 of the IMDG Code.
  • There are significant changes in Chapter 7.2, including more stringent segregation and stowage requirements for Class 4.3 and other water-reactive materials.
  • Updates of the Dangerous Goods List in 4.2 include:
    • The proper shipping name for UN 3268 has been changed from AIR BAG MODULES, AIR BAG INFLATORS or SEAT-BELT PRETENSIONERS to SAFETY DEVICES.
    • Asbestos is now to be shipped as UN 2212 ASBESTOS AMPHIBOLE or UN 2590 ASBESTOS, CHRYSOTILE.
    • The entry for CAPACITORS has been divided into CAPACITOR, ELECTRIC DOUBLE LAYER (UN 3499) and CAPACITOR, ASYMMETRIC (UN 3508).
    • PACKAGING DISCARDED, EMPTY UNCLEANED (UN 3509) has been added but can’t be used for sea transport (!?!).
    • A series of shipping names for various adsorbed gases have been assigned between UN 3510 and UN 3526.
  • The following Special Provisions have been added:
    • SP 367 through 376 (excluding 374, 375).
    • SP 968 through 970
  • Special Provisions for shipping certain common items have been added or Transportation of dangerous goods by vesselrevised:
    • SP 376 through 377 for lithium batteries damaged/defective or for recycling/disposal.
    • SP 961, 962 for vehicles or internal combustion engines (see also SP 970).