Does FedEx require a Shipper of hazardous materials (HazMat) or dangerous goods who uses their services to attend FedEx Training?

Answer:  No

From the FedEx website:

The federal government requires every dangerous goods shipper to have job-specific dangerous goods training before tendering a dangerous goods shipment to FedEx or any air carrier. Shippers are directly responsible for the correct transport of dangerous goods by air.

Also from the FedEx website…

 The government regulations state:

• Each person involved in the shipping and/or handling of dangerous goods must be trained.
• Recurrent training must occur every two years. Exception: In the U.S., the Department of Transportation (DOT), as competent authority, allows training for shippers every three years.
• An enforcement agency may review your training records at any time.

Note that while FedEx references the Federal training requirement of the USDOT – more specifically, it is the Pipeline & Hazardous Materials Safety Administration (PHMSA) that requires the training – they do not state that the training must be provided or authorized by FedEx.  As long as the HazMat Employee training meets the requirements of the PHMSA, you will be good-to-go to ship your HazMat or dangerous goods with FedEx.

The same is true of the Dangerous Goods Regulations of IATA/ICAO and the IMO.  In either case, FedEx may encourage you to take the training they offer or authorize, but it is not required.

The catch, however, is that FedEx, just like any other Carrier, may reject a material or article that it is offered for transportation without cause.  So, if they were to require you to attend their training – which they don’t – you would have no choice but to comply or find another Carrier.

What should you do?  Make sure you get the best HazMat Employee or Dangerous Goods Training available at the best price and the least inconvenience.  Contact me for a free training consultation.

FedEx Dangerous Goods & HazMat Employee Training

Understanding the Dangerous Goods Regulations (DGR) can be challenging – though IATA, the International Air Transport Association does a pretty good job of keeping it simple.  Sometimes compliance with the DGR can hinge on just one word.  Sometimes a “should” means something very different than a “Shall”.  The purpose of this brief article is to describe what it means when the IATA DGR uses terms such as:  “shall”, “must”, “should”, & “may”. (more…)

The Bullet:

Lithium metal batteries transported as cargo will be restricted to Cargo Aircraft Only from 1 January 2015. The prohibition on the carriage on passenger aircraft only applies to lithium metal batteries when shipped by themselves, and does not apply to batteries packed with equipment or contained in equipment.

Who:

ICAO:  International Civil Aviation Organization.  A United Nations organization whose regulatory authority over the international transportation of dangerous goods is recognized by the USDOT/PHMSA at 49 CFR 171.24 for domestic compliance.

IATA:  International Air Transport Association.  A creation of the airline industry as a simplified version of the ICAO Technical Instructions.  Required by most air carriers in the world, including those in the US.  Though its regulations are not officially recognized for domestic compliance by the USDOT/PHMSA, since its regulations are based on – and in some cases more strict than – the ICAO Technical Instructions, compliance with the IATA DGR is seen as compliant with ICAO for both international and domestic transportation.

What:

• Lithium ion batteries (rechargeable, also called Li-ion)
• Lithium metal batteries (often non-rechargeable)

• Cargo Aircraft.  Any aircraft, other than a passenger aircraft, which is carrying goods or property.
• Passenger Aircraft.  An aircraft that carries any person other than a crew member, an operator’s employee in an official capacity, an authorized representative of an appropriate national authority or a person accompanying a consignment or other cargo.

It is important to note that this announced ban only applies to lithium metal batteries being transported as cargo on passenger aircraft.

Also, the prohibition only applies to lithium metal batteries when shipped by themselves.  The prohibition does not apply to the following:

• Lithium metal batteries packed with equipment.
• Lithium metal batteries contained in equipment.

Where:

ICAO Technical Instructions must be complied with for air transport outside of the US.  Compliance with the IATA DG Code will likely be required by any air carrier you use for both international and domestic transportation.

When:

Announced by ICAO April 16, 2014.

Unless the decision is overturned by the Air Navigation Council or the ICAO Council, the ban will become effective January 1, 2015.

Why:

Numerous fires caused by lithium batteries while being transported by air have proven a challenge to fire suppression and airline safety systems for over a decade.

How:

As noted above, the USDOT/PHMSA, through its acceptance of the ICAO Technical Instructions for compliance with domestic regulations, permits compliance with the IATA DG Code as substitute for compliance with its HMR.  It is likely that your carrier will require compliance with the IATA DG Code as a condition of accepting your HazMat for Transportation.

For More Information:

• The IATA Lithium Battery Update for 2015
• IATA Lithium Battery Shipping Guidelines
• IATA Website:  Lithium Batteries
• USDOT/PHMSA Guidance:  Shipping Batteries Safely by Air – What you need to know

Conclusion:

The IATA Dangerous Goods Code is – in many ways – similar to the Hazardous Material Regulations of the USDOT/PHMSA.  However, there are some differences, one of them is the requirement to train personnel involved in the transport of dangerous goods/hazardous materials.  If subject only to the domestic regulations of the USDOT/PHMSA, then you must provide initial training (within 90 days of employment) and a full training course every three years.  If shipping dangerous goods by air, the IATA DG Code requires training before personnel engage in regulated activities and recurrent training within 24 months.

I can provide all the training required to ship hazardous materials/dangerous goods both domestically and internationally.  Contact me for a free training consultation.

The Dangerous Goods Regulations of the International Air Transportation Association (IATA) are the standards used by most of the airline industry throughout the world.  If you intend to ship hazardous materials (aka: Dangerous Goods), either domestically (within the US) or internationally by air, you will likely be required to comply with the IATA DGR.  A challenge to compliance is that it is updated annually; therefore the 54th Edition, in use in 2013, is no longer acceptable for compliance in 2014.  So, throw out your 2013 version of the International Air Transportation Association Dangerous Goods Regulations and replace it with the 55th Edition.  Each new Edition includes changes from the previous, and it is up to you to ensure you are in compliance with the latest Edition.  The purpose of this article is to summarize the main changes to the 2014 IATA DGR and direct you to a more thorough evaluation of the changes. (more…)