International Transportation of Dangerous Goods

Significant Changes to the IATA Dangerous Goods Regulations for 2016

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

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

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

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

      A unit load device used by UPS

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

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

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

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

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

https://youtu.be/1fFQsx64TXU

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

The IMDG Code Amendment Cycle – 2010 thru 2019

The IMDG Code Amendment Cycle – 2010 thru 2019

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.

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.

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

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

 

 

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

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

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

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

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

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

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

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

International and Domestic

Daniels Training Services
815.821.1550
Info@DanielsTraining.com
https://www.danielstraining.com/

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

 

Air Shipment of Samples with Ethanol

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

Hi Daniel,

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

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

(a) specimens are:

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

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

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

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

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

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

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

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

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

Thank you for your help.

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

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

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

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

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

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

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

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

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

Required Information on the Shipper’s Declaration of Dangerous Goods

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

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

Or…

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

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

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

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

2.3—Dangerous Goods Carried by Passengers or Crew

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

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

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

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

4—Identification
4.2—List of Dangerous Goods

Amendments to the List of Dangerous Goods include:

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

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

5—Packing

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

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

8—Documentation

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

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

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

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

General Requirements for the Shipping Paper When Transporting Dangerous Goods by Vessel

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…)

Changes to the International Maritime Dangerous Goods Code – 2014 Edition

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:Vessel transporting dangerous goods

  • 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?

An Overview of New Regulations in the 56th Edition (2015) of the IATA Dangerous Goods Regulations

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.

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/