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

    

    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.
• 10 – 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.

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.

If you ship HazMat/Dangerous Goods by vessel in international waters, then you must comply with the regulations of the International Maritime Organization (IMO) and its International Maritime Dangerous Goods Code (IMDG Code).  But to comply you must make certain that you are using only the latest approved edition of the IMDG Code which is updated every two years.

[slideshare id=41291019&doc=imdgcodeamendmentcycle-141108065539-conversion-gate01]

From the above graphic you can see that the 2012 Edition of the IMDG Code acceptable for use through the end of 2015 must be replaced by the 2014 Edition which is then acceptable through the end of 2017.

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”.

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.

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,

You can tell I was impressed (3.14.15):

Here’s what I sent to him later that day.  (Yeah, I work Saturdays.):

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?

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…)

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.

The International Air Transport Association (IATA) is an organization of air carriers that regulates the worldwide transportation of people and property.  IATA’s regulations pertaining to the transportation by air of dangerous goods (hazardous materials or HazMat within the U.S.) is known as the Dangerous Goods Regulations or DGR.  The IATA DGR is updated annually; a new edition becomes effective January 1, 2015.  Though not directly authorized by its regulations. the PHMSA/USDOT accepts compliance with the IATA DGR within the U.S. as compliance with its Hazardous Material Regulations (HMR).  There are changes to the HMR scheduled to take affect in April of 2015 that will harmonize it with the IATA DGR, creating compatibility between these regulations for air transport of lithium batteries within the U.S. and internationally.

The correct transportation of any dangerous good requires the following:

1. Identify the substance or article
2. Classification of the dangerous good.
3. Determination of packaging instructions.
4. Identification of available packaging exceptions.
5. Identification and use of required labels, markings, and the shipping paper.

Substance or article offered for transportation by air by Micro Q Technologies:

Lithium ion battery contained in equipment (e.g. cell phone, camera, lap top computer)

Battery specs: Single Battery consist of 25 cells of 3.7 Volt 2.6 amp hour ( 9.62 watt ) 18650 lithium ion cells configured 5 in series to achieve 18.5 Volts and 5 in parallel to achieve 13 amp hours, total battery power in watts 18.5 V x 13 amp hour = 240 watts

Classification:

UN/ID no.:  3481

Proper Shipping Name/Description:  Lithium ion batteries contained in equipment (including lithium polymer batteries)

Class or Div. (Sub Risk):  9 MISCELLANEOUS

Packing Group: PGII

Packaging:

• Not eligible for the following packaging exceptions:
  • Excepted Quantity
  • Limited Quantity
• Maximum net quantity/package if transported by passenger aircraft = 5 kg
• Maximum net quantity/package if transported by cargo aircraft = 35 kg
• Packaging Instructions by passenger and cargo aircraft = 967

Special Provisions of column M:

• A48 – Packaging tests are not considered necessary.
• A99 – Maximum net quantity/package by cargo aircraft may exceed 35 kg if approved by PHMSA/USDOT.
• A154 – Damaged batteries are forbidden for air transport.
• A164 – Special packing requirements if potential for dangerous evolution of heat.
• A181 – If “batteries contained in equipment” are packaged with “batteries packed with equipment” must be identified as “batteries packed with equipment”.  Must identify lithium ion batteries and lithium metal batteries separately if packaged together.  However, button cell batteries installed in equipment need not be considered.
• A185 -Vehicles only powered by lithium metal batteries or lithium ion batteries must be shipped as UN 3171, Battery-powered vehicle.

Packaging Instructions 967:

• Operator variations for FedEx or UPS are not present or don’t apply.  Other Operator variations are present.
• No State variation identified.
• PI 967 applies to lithium polymer cells & batteries contained in equipment (UN3481) for both passenger and cargo aircraft.
• There are three sections to PI 967 that must be considered:
  • General Requirements apply to all lithium ion cells & batteries contained in equipment prepared for transport according to PI 967
  • Section I applies if the equipment contains lithium ion cells of >20 Wh or lithium ion batteries of >100 Wh.  These must be shipped as a Class 9 MISCELLANEOUS dangerous good.
  • Section II applies if the equipment contains lithium ion cells of ≤20 Wh or lithium ion batteries of ≤100 Wh.

The lithium ion batteries of Micro Q Technologies have a Watt-hour rating of 240 Wh.  Therefore the General Requirements and Section I of PI 967 are applicable; whereas the requirements of PI 967 Section II do not apply.

General Requirements:

• Cells and batteries must be manufactured under a quality management program as described in 3.9.2.6(e) of the IATA DGR.
• Cells and batteries that are damaged, defective, or that can produce dangerous heat or fire are forbidden from air transport.  e.g. cells and batteries returned to the manufacturer for safety reasons.
• Cells and batteries must be protected so as to prevent short circuits.
• Equipment must be equipped to prevent accidental activation.
• Equipment containing lithium ion batteries must be packed in strong outer packaging per 5.0.2.4, 5.0.2.6.1, and 5.0.2.12.1 of the IATA DGR.
• Equipment containing lithium ion cells or batteries must be secured within the outer packaging and packed so as to prevent accidental operation during air transport.

Section I:

• Each cell or battery must comply with 3.9.2.6 of the IATA DGR (summarized below).
• Equipment must be packed in strong outer packagings, such as:
  • Drums:  steel, aluminum, plywood, fiber, plastic, or other metal.
  • Jerricans:  steel, aluminum, or plastic.
  • Boxes:  steel, aluminum, wood, plywood, reconstituted wood, fiberboard, plastic, or other metal.
• Batteries manufactured after December 31. 2011 must have the Watt-hour rating marked on the outside case.

There are no other packaging exceptions available for Lithium ion batteries contained in equipment under PI 967.

Section II:

• If packaged per Section II, lithium ion cells and batteries are not subject to the remainder of the IATA DGR, except for the following:
  • Limits on dangerous goods in passenger and crew baggage.
  • Limits on dangerous goods in air mail.
  • Reporting of dangerous goods accidents, incidents, and other occurrences.
• Cells and batteries must meet provisions of 3.9.2.6(a) and (e).
• Some devices (eg. radio frequency identification tags, watches, and temperature loggers) if not capable of generating dangerous heat may be transported when intentionally active.  If active, must meet defined standards for electromagnetic radiation.
• Equipment must be packed in strong outer packagings.  Type of packaging is not specified as it is for Section I.
• If package contains >4 cells or >2 batteries, then must be labelled with the Lithium Battery Handling Label.  button cell batteries installed in equipment are not counted towards the battery threshold.
  

  Question:  “Answer to question G at the bottom of page 19 and followed on page 20 (IATA Lithium Battery Guidance Document, Revised for the 2014 Regulations) is rather confusing, (number of cells contained inside the lithium Ion battery are NOT counted towards the 4 cell limitation)  Does this mean a loop hole to avoid Class 9?”

  Answer:  No. The exception referred to in question G applies only to the requirement to use the Lithium Battery Handling Label under PI 967 Section II.  Question G also explains that the number of cells in a battery are not counted towards the 4 cell threshold when determining if this exception is available; rather it is the battery itself that is counted.

• A Shipper’s Declaration for Dangerous Goods is not required.
• Each shipment of packages bearing the Lithium Battery Handling Label must be accompanied by a document indicating:
  • The package contains lithium ion cells or batteries.
  • The package must be handled with care.
  • Special procedures to follow if the package is damaged.
  • A telephone number for additional information.
• Each shipment of packages bearing the Lithium Battery Handling Label must include the following on the air waybill, if an air waybill is used (air waybill is not required):  “Lithium ion batteries in compliance with Section II of PI 967”
• Persons preparing cells or batteries for transport must receive adequate instruction on these requirements.

3.9.2.6 of the IATA DGR:

• Each cell or battery must be tested per the UN Manual of Tests and Criteria Part III Subsection 38.3.
• Each cell and battery must incorporate a safety venting device or be designed to preclude a violent rupture under conditions normally incident to transport.
• Each cell and battery must be equipped with an effective means of preventing external short circuits.
• Each battery containing cells or series of cells connected in parallel must be equipped with effective means as necessary to prevent dangerous reverse current flow (e.g., diodes, fuses, etc.).
• Cells and batteries must be manufactured under a quality management program specified at 3.9.2.6(e).  In-house quality management programs may be accepted.

 Requirements of the HMR:

The following are requirements of the HMR that are not found in the IATA DGR; they apply to the transportation of any hazardous material within the U.S.  There are no other requirements of the HMR that will impact the shipment of this HazMat/dangerous good.

• Emergency response information
• HazMat Employee training
• HazMat Security
• HazMat incident reporting
• For export only:
  • General packaging requirements
  • Requirements for reuse of packaging
• Registration as shipper or carrier.

 Conclusion:

The lithium ion batteries contained in equipment (UN 3481) of the Watt-hour rating you describe must be shipped as a Class 9 MISCELLANEOUS dangerous good per the IATA DGR.  The General Requirements and Section I of Packaging Instructions 967 (PI 967) must be followed for its packing.  No packaging exceptions are available for this dangerous good in transportation.

Disclaimer:

This document represents my interpretation of the IATA DGR (2015, 55th Edition) based on the information provided by Micro Q Technologies.  It is meant to be a summary of the main features of the applicable regulations and is not a complete re-statement of them.  As the Shipper of a HazMat/Dangerous Good, you must ensure compliance with the applicable Federal and International regulations.  Please confirm all of the information presented here through your own thorough review of the IATA DGR and the HMR.

Chapter 5.4 of the International Maritime Dangerous Goods Code (2012 Edition) indicates the requirements of the International Maritime Organization (IMO) for the description of a dangerous good on a shipping paper (referred to in the IMDG Code as a dangerous goods transport document) to be offered for transportation by vessel in international waters.  The purpose of this article is to summarize the general requirements for a Shipper preparing a dangerous goods transport document. (more…)

The International Maritime Organization (IMO) publishes a new edition of its International Maritime Dangerous Goods Code (IMDG Code) every two years, with the current edition (2012, incorporating amendment 36-12) published in the Fall of 2012.  Each new edition of the IMDG Code has an interesting life-cycle as indicated below:

• The first calendar year after its publishing (2013 for the 2012 edition) is a transition year where either the current edition or its predecessor is valid.
• The second calendar year after its publishing (2014 for the 2012 edition) is the year when only that edition is valid.
• The third calendar year after its publishing (2015 for the 2012 edition) is a transition year again where either the current edition or its replacement (2014, incorporating amendment 37-14) is valid.
• The end of the third calendar year after its publishing (December 31, 2015 for the 2012 edition) is the end of the validity of the edition.

If you’re confused by the amendment cycle of the IMDG Code and unsure if you are referring to the correct edition to determine compliance, refer to this simple infographic:  The IMDG Code Amendment Cycle

The 2014 edition of the IMDG Code is expected to be published soon, below are some of the significant changes from the 2012 edition it contains:

• Updates have been made to provisions reflecting the regulations of the International Atomic Energy Agency for the safe transport of radioactive material.
• Column 16 “Stowage and Segregation”of the Dangerous Goods List has been split into two new columns:  16a “Stowage and Handling” and 16b “Segregation”.  Instead of descriptive text, these two columns now contain codes that are defined in Chapter 7 of the IMDG Code.
• Significant changes to Chapter 7.2, including more stringent segregation and stowage requirements for Class 4.3 Dangerous when wet and other water-reactive materials.
• Updates to the Dangerous Goods List include:
  • Proper shipping name for UN3268 has been changed from “AIR BAG MODULES, AIR BAG INFLATORS or SEAT-BELT PRETENSIONERS” to “SAFETY DEVICES”.
  • Proper shipping name and UN Number for asbestos is now UN2212 “ASBESTOS, AMPHIBOLE” or UN2590 “ASBESTOS, CHRYSOTILE”.
  • The entry for “CAPACITORS” has been divided into “CAPACITOR, ELECTRIC DOUBLE LAYER” UN3499 and “CAPACITOR, ASYMMETRIC” UN3508.
  • “PACKAGING DISCARDED, EMPTY, UNCLEANED” un3509 HAS BEEN ADDED BUT CAN NOT BE USED FOR TRANSPORT BY VESSEL.
  • A series of shipping names for various adsorbed gases have been assigned UN Numbers between UN3510 and UN3526.
• Special Provisions have been aded:
  • SP 367 through SP 376 (excluding SP 374 and SP 375).
  • SP 968 through SP 970.
• Special Provisions for shipping certain common items have been added or revised:
  • SP 376 through SP 377 for lithium batteries damaged/defective or for recycling or disposal.
  • SP 961, SP 962 (Vehicles or Internal Combustion Engines; see also SP 970).

The transportation of dangerous goods by vessel outside of the US and its territorial waters must comply with the IMDG Code.  It is possible that a carrier transporting dangerous goods by vessel within the US will comply with the IMDG Code as well, thus requiring your understanding and use of it.  Of course, any transportation of dangerous goods (referred to as hazardous materials by US regulations) within the US must comply with the Hazardous Material Regulations of the Pipeline and Hazardous Materials Safety Administration (PHMSA).

Regulations, both international and domestic require that you train all personnel who are involved in the transportation of the dangerous good/HazMat.  Contact me for this training.

More Questions?

• Where can I purchase a copy of the 2014 Edition of the IMDG Code?
• What is the Amendment 37-14?
• Is the IMDG Code available for my company’s intranet?
• Is the IMDG Code available on the web?

http://youtu.be/C_I12kEIEKg

The transportation of hazardous materials (aka: Dangerous Goods) by air will likely have to comply with the Dangerous Goods Regulations of the International Air Transport Association.  I say “likely” because compliance with the DGR of IATA is a requirement of most air carriers – though not all.

If you must comply with the IATA DGR, subsection 1.5 requires you to provide training for applicable personnel initially and every two years thereafter.

Please contact me for a free consultation on the HazMat/Dangerous Goods regulations of the PHMSA/USDOT, IATA, or the International Maritime Organization.