IATA Classification of Substances with Multiple Hazards

My reply the same day:

I can assist you. Please advise on the following:

Will transportation be by air or vessel?
If by air, what is the air carrier?
What is the volume of ethanol you intend to ship? Per inner packaging? Per outer packaging?

I look forward to assisting you.

More information was quickly provided:

Dear Daniel,

Thank you very much for your swift reply.

So, on the way there, right now it looks like I will have to take 5 to 6 bottles of 1L “with me” when travelling by plane to West Africa. Is that allowed, what arrangements should be made?

On the way back, it gets a bit more complicated:

we are looking at perhaps 5 to 10 samples of lion tissue in 50mL tubes (so ethanol < 500ml) per box
but with many more (~100) faecal samples in same tubes but with silica beads (I’m specifying this as I believe this will impact your answer)

Many thanks for your time,

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

My reply later that day:

Please see below.

That quantity of dangerous good you indicate: 5-6 x 1L of Ethanol, cannot be transported by air as a passenger’s checked or carry-on baggage per 2.3 of the International Air Transport Association Dangerous Goods Regulations (IATA DGR). It must be shipped as a fully-regulated dangerous good.
You must contact a commercial air carrier (UPS, FedEx, other) to arrange for its transport by air as a dangerous good.
The samples coming back may be easier as they may be transported as passenger baggage without air carrier approval if it can meet the requirements of 2.3.5.12 of the IATA DGR:
- Non-infectious specimens.
- Wrapped in paper or cloth and then heat-sealed bag w/ no more than 30 mL of free liquid or vials or rigid container in heat-sealed bag of no more than 30 mL free liquids.
- Placed in another plastic bag with absorbent.
- Finished bag placed in strong outer packagings with suitable cushioning.
- No more than 1 L of ethanol in completed packaging.
- Package marked: “scientific research specimens, not restricted”

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

The next day, October 20, 2020 (maybe it was the same day in Europe, I don’t know.):

Dear Daniel,

Thank you very much for all the info, this is very helpful!

Not a heat sealed bag

Any chance zip-lock bags can be accepted instead of heat-sealed ones? I think I know your answer but I have to ask just in case.
You also say no more than 1L of ethanol in completed packaging. Does this also mean that just a 1L bottle ethanol, maybe in particular packaging, in passenger baggage is fine? Just checking where the limits are.

Many thanks for your time and help,

My reply:

Please see below.

The regulations require a heat-sealed bag (and more) for the samples as baggage.
The limit of no more than 1 L of ethanol (or other flammable liquid used as preservative) is just for the samples as baggage. It requires the inner packagings within the completed package to contain no more than 30 mL of ethanol as free liquid. You may not transport a 1 L bottle of ethanol as baggage on an aircraft, no matter the packaging.
The 1 L bottles you intend to bring to Africa must be packaged and shipped as a dangerous good with a commercial air carrier.
Depending on its Packing Group it may be eligible for the limited quantity exception which will make transportation by air somewhat easier and perhaps less expensive.
- Packing Group II may be transported as a limited quantity pursuant to packing instructions Y341.
- Packing Group III may be transported as a limited quantity pursuant to packing instructions Y344.

Please note, my email was only a brief summary of the complete regulations. You must research and comply with the complete regulations.

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

That seemed to make things crystal clear (10.21.20):

Dear Daniel,

Thank you very much, crystal clear. This has been incredibly helpful!

Have a nice day,

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That should help international relations!

It’s important to remember that the transportation of hazardous materials (aka: dangerous goods) takes place all around the world. Transportation by air will likely be subject to the Dangerous Goods Regulations of the International Air Transport Association (IATA). IATA has a biennial training requirement for shippers and packers of dangerous goods.

Q&A: Why does the E3 code indicate a dangerous good is not eligible for the De Minimus exception?

Just two days before Christmas 2020 and I’m still getting questions like this:

Greetings Mr. Stoehr,

I hope this email finds you well and celebrating the holidays.

I read the following requirement for shipping de minimis: “If the code isE1, E2, E4 or E5, the goods can be shipped as de minimis. If the code is E0 or E3 your dangerous goods cannot be shipped using this provision.

What is the the reason why we cannot ship if the code is E3? I understand if it is E0. E3 is similar to E2, only the maximum net quantity per outer package is less.

Thank you and have a wonderful holiday.

Daniels Training Services, Inc.

815.821.1550

My reply the same day (12.23.20):

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

I presume you are referring to the De Minimis Quantities exception of the International Air Transport Association (IATA) at 2.6.10 of the IATA Dangerous Goods Regulations. While there is a similar De Minimis Quantities exception at 49 CFR 173.4b in the Hazardous Materials Regulations of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA), the domestic regulations do not use the “E codes” as do those of IATA.
The “E codes” (E0, E1, E2, E3, E4, & E5) are found in column F of the List of Dangerous Goods. Their primary purpose is to identify the limits of the Excepted Quantity exception.
Once the E code is determined for a dangerous good the shipper or packer is directed to 2.6 of the IATA Dangerous Goods Regulations to determine the inner and outer packaging quantity limits and packaging requirements for transport as an Excepted Quantity.
Within 2.6 at 2.6.10 are the requirements for transport subject to the De Minimis exception. There, as noted above, the De Minimis exception is limited solely to dangerous goods associated with the E codes of E1, E2, E4, & E5.

Why not E3?

I don’t know for certain why E3 is excluded from eligibility for the De Minimis exception.
However, I can surmise it is not due to the quantity limits but more likely due to the type of dangerous good that is assigned the E3 code. It is possible that the dangerous good assigned E3 as an excepted quantity is not acceptable to ship by air as DeMinimis.
I did a quick review of most of the List of Dangerous Goods and discovered that every E3 code in column F was associated with a Class 3 Flammable Liquid in Packing Group I.

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

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The reply:

Thanks for giving this a shot – we kinda went in a circle – I did the same. Have wonderful holiday

Conclusion:

Not every answer has a satisfactory answer in the regulations. Though I couldn’t answer this “why?” question, I’m sure I’ll be able to answer and “how” question you may have about the transportation of dangerous goods or hazardous materials.

Significant Changes and Amendments to the 62nd Edition (2021) of the IATA Dangerous Goods Regulations

The International Air Transport Association (IATA) publishes a new edition of its Dangerous Goods Regulations for each calendar year. In effect for the remainder of calendar year 2020 is the 61st edition. Beginning January 1, 2021 all transport of dangerous goods subject to IATA’s Dangerous Goods Regulations must be in compliance with the 62nd edition. The purpose of this article is to summarize the significant changes in store for 2021 in the 62nd edition.

Before we begin…

UPDATE: On January 18, 2021 IATA posted it’s first Addendum to the 62nd Edition of the IATA Dangerous Goods Regulations. These revisions are effective as of January 1, 2021.
UPDATE TO THE UPDATE: On February 23, 2021 IATA posted Addendum II to the 62nd Edition of the IATA Dangerous Goods Regulations. These revisions are effective January 1, 2021.
The IATA Dangerous Goods Regulations is a “field manual” of the Technical Instructions of the International Civil Aviation Organization (ICAO).
The ICAO Technical Instructions are updated every two years. However, the IATA Dangerous Goods Regulations are updated every calendar year due to frequent changes within the airline industry and a desire for greater safety and efficiency in air transportation of dangerous goods.
What’s inside the IATA Dangerous Goods Regulations? Good question:
The 62nd Edition of the IATA Dangerous Goods Regulations is effective from January 1, 2021 to December 31, 2021
- Section 1 – Applicability: shipper and operator responsibilities, training, security, incident reporting
- Section 2 – Limitations: forbidden and hidden goods, storage and transport quantities, transport by post, transport by passengers/crew, limited quantity exception, excepted quantity exception, State and operator variations
- Section 3 – Classification: defining criteria of hazard classes and divisions, multiple hazards, Packing Group
- Section 4 – Identification: list of dangerous goods (blue pages), numerical cross-reference list, special provisions
- Section 5 – Packing Instructions (yellow pages): Packing instructions – fully regulated and limited quantity – for all dangerous goods by passenger and cargo aircraft (PAX) and cargo aircraft only (CAO)
- Section 6 – Packaging Specifications: inner packaging, UN, construction and testing, limited quantity
- Section 7 – Marking and Labeling (pink pages): package marks, hazard labels, handling labels
- Section 8 – Documentation (more pink pages): shipper’s declaration for dangerous goods, air waybill
- Section 9 – Handling: storage, loading, inspection, information provision, reporting, training, document retention for operators (air carriers)
- Section 10 – Radioactive material (a few more pink pages): transport, limitations, classification, identification, packing, testing, labelling, documentation, handling
- Appendices: A-I
- Index

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

International and Domestic

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If a visual will help, watch this short video describing the IATA Dangerous Goods Regulations.

Scope and Applicability:

As noted above, this article will only address the significant changes to the 62nd Edition of the IATA Dangerous Goods Regulations for 2021.
This article is only a summary of a document available on the IATA website: Significant Changes and Amendments to the 62nd Edition (2021). Read it for a more thorough description of these changes and amendments for 2021.
Even the document available from IATA is not meant to be an exhaustive listing of all changes to the 62nd Edition. Make sure you do your research to confirm compliance.
This short video explains the reference marks used in the IATA Dangerous Goods Regulations to indicate changes to the DGR from the previous edition.

Significant Changes and Amendments to the 62nd Edition of the IATA Dangerous Goods Regulations for 2021:

Section 1 – Applicability

1.5 – Training Requirements. The training requirements have been revised to implement a competency-based approach to dangerous goods training and assessment. These changes were originally shown in Appendix I – Impending Changes of the 61st Edition (2020) and are now found in subsection 1.5 of the 62nd Edition for 2021. During a two-year transition period (until December 31, 2022) the training requirements from the 61st Edition may continue to be used. For this reason subsection 1.5 from the 61st Edition has been moved to Attachment A of Appendix H in the 62nd Edition.

Competency-based training is an effort by IATA to provide training focused on the key competencies and skills that each employee needs in order to perform specific tasks in the packaging, loading, and shipping of dangerous goods by air. What it means is that as of 12.31.22 your IATA Dangerous Goods training will have to change.

Other changes were made to the list of exceptions at 1.2.7 to include dangerous goods required for preservation of organs intended for transplant and pest management activities and new entries were added to the indicative list of high consequence dangerous goods in Table 1.7.A.

Section 2 – Limitations

Subsection 2.3 – revised to allow for passengers to carry the following dangerous goods:

Nickel-metal hydride or dry batteries
Self-inflating safety device and spare gas cartridges
Portable electronic devices (PED) and spare batteries for PED

Subsection 2.4 – revised to clarify the packing instructions (PI 954) required when dry ice is used as a refrigerant for UN3373 (Biological substance, category B) when the dangerous good is to be transported by post.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Section 3 – Classification

3.6.2.5 – revised to add a new criteria to address solid medical waste containing Category A infectious substances.
3.8.2 – revisions to the criteria for assignment of Packing Groups to corrosive substances and mixtures.

Section 4 – Identification

Several amendments to the List of Dangerous Goods in subsection 4.2. Including:

Addition of UN0511, UN0512, & UN0513 for Detonators, electronic in divisions 1.1B, 1.4B, and 1.4S respectively
Addition of new proper shipping name, Dangerous goods in articles to UN 3363
Addition of UN3549 for Medical waste, Category A, affecting animals or humans
UN2216, Fish meal, stabilized is no longer forbidden. It is now permitted on both passenger aircraft and cargo aircraft only
Packing instruction number for UN3291, Biomedical waste, n.o.s., Clinical waste, unspecified, n.o.s., Medical waste, n.o.s., and Regulated medical waste, n.o.s. has been changed from PI 622 to PI 621
“Stabilized” was added to the proper shipping name for UN2522, 2-Dimethylaminoethyl methacrylate

Amendments to special provisions in subsection 4.4 include:

Inclusion of the State of the operator as an approving authority (previously it was only the State of origin) for lithium batteries shipped under special provisions A88 (prototypes) and A99 (more than 35 kg OK for cargo aircraft only).
Special provisions A88 and A99 revised to require the packing instruction number shown on the Shipper’s Declaration be the one identified in the special provision from the Supplement to the ICAO Technical Instructions: PI 910 for A88 and PI 974 for A99.
To reflect the addition of a new proper shipping name to UN3363 (Dangerous goods in articles), the words “machinery or apparatus” in special provision A107 were replaced by “article”.
Revisions to A145 for waste gas cartridges and waste receptacles, small, containing gas.
Significant revisions to A154 to address transport of damaged and defective lithium batteries.
Revision to A201 to allow for the transport of lithium batteries as cargo on passenger aircraft if urgent medical need and with approval of State of origin and operator.

New special provisions:

A215 permits shipper to use a listed proper shipping name as the technical name for UN3077 and UN3082.
A219 (assigned to UN2216, Fish meal, stabilized) specifies antioxidants must be added to fish meal to prevent spontaneous combustion.

Section 5 – Packing

5.0.2.5 – new text added clarifies a packaging may meet more than one tested design type and may bear more than one UN specification mark.

Revisions to packing instructions include:

PI 378 and PI 972 – permits fuel tanks of machinery to have up to 1/4 of a tank of fuel where the machinery cannot be loaded other than upright.
PI 457, PI 463, PI 465, PI 470, PI 471, PI 479, PI 482, PI 490, PI 491, and PI 555 – single packagings permitted by these packing instructions now align with those permitted in the UN Model Regulations and elsewhere in the DGR.
PI 492, PI 870, PI 971, and PI 972 – cells and/or batteries must be packed directly into the outer packagings.
PI 622 – renumbered to PI 621 to align with the UN Model Regulations.
PI 650 and PI 959 – diamond-shaped mark with the UN number must appear on one side of the package.
PI 956 – includes reference to UN 2216, Fish meal, stabilized.
PI 957 – allows for both combination and single packagings.
PI 962 – includes reference to the new proper shipping name Dangerous goods in articles and to use “article’ or “articles” in place of “machinery or apparatus”.
PI Y963 – a unit load device prepared by a single shipper may contain dry ice as a refrigerant for consumer commodities.
PI 965 to PI 970:
- damaged or defective lithium cells or batteries are forbidden for air transport.
- when section II of packing instructions are followed and packages from multiple packing instructions are on one air waybill, the compliance statement may be combined into a single statement. Examples are included in 8.2.7.
PI 967 and PI 970:
- equipment must be secured against movement in the outer packaging.
- multiple pieces of equipment in a package must be packed to prevent damage due to contact with other equipment in the package.

Daniels Training Services, Inc.

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Section 6 – Packaging Specifications and Performance Tests

Revisions to Section 6 include:

6.0.4.1 and 6.5.3.1 – clarification of size of UN specification marks on packagings.
6.0.4.2.1(f) – clarification of the application of the year of manufacture for plastic drums and jerricans.
6.0.7 – new provision for packagings tested to more than one design type.
6.1.7.2 – revision to maximum capacity for metal aerosols.
6.2.2.7 and 6.2.7.7 – suitable internal protective coatings or treatments must be applied to aluminum and other metal drums if not compatible with contents. This provision already exists for steel drums and steel and aluminum jerricans.
6.4.2 – revisions to the ISO references for UN cylinders and closed cryogenic receptacles.

Section 7 – Marking and Labelling

7.1.4.4.1 – the height of the UN/ID number and the letters “UN” or “ID” on packages may be smaller than 12 mm depending on the size of the package.
7.1.5.5.3 – minimum dimensions of lithium battery mark have been revised.

Section 8 – Documentation

8.1.6.9.2, Step 7 – requirements for description of multiple overpacks on Shipper’s Declaration revised. An additional example is provided at Figure 8.1.Q.
8.2.1 – statement required on the air waybill when dangerous goods are offered on a Shipper’s Declaration revised to align with the language used on electronic documentation: Shipper’s Declaration is not “attached” but is “associated” with the air waybill. There is a two year transition period during which time either wording is acceptable.

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Section 9 – Handling

9.1.9 – now mandatory (previously recommended) that operators include the transport of dangerous goods as part of their safety risk assessment process.
9.6.4 – requirement to provide report to State of origin deleted.

Section 10 – Radioactive Materials

Revisions to Section 10 include:

10.0.1.1 – provisions for transport are based on Revision 1 of IAEA Safety Standards Series No. SSR-6.
replacement of “radiation level” by “dose rate”.
Table 10.3.1 – addition of new radionuclides for Germanium, Iridium, Nickel, Strontium, and Terbium.
10.8.8.1 – revision to statement on the air waybill when dangerous goods are offered on a Shipper’s Declaration.

Appendix A

Changes, deletions, and additions in the glossary include:

addition of definitions for carry-on and checked baggage.
addition of definition for detonators, electronic.
addition of definition for dose rate.
deletion of “radiation level”.
revision to the definition for self-accelerating decomposition temperature.

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Appendix C

Table C.2 – changes to the list of currently assigned organic peroxides.

Appendix D

updates to contact information for competent authorities.

Appendix E

E.1 – changes to list of UN Specification Packaging Suppliers.
E.2 – changes to list of Package Testing Facilities.

Appendix F

revisions to list of Sales Agents (F.2), IATA Accredited Training Schools (F.3 – F.5) , and IATA Authorized Training Centers (F.6).

Appendix H

guidance material on development and implementation of competency-based training for dangerous goods has been revised based on input from training providers and member airlines.
Subsection 1.5 from the 61st Edition has been moved to Attachment A in Appendix H.

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Step 1: Purchase the 62nd Edition (2021) of the IATA Dangerous Goods Regulations

Step 2: Review the regulations to identify any changes from the previous edition that affect your compliance.

Step 3: Contact me for in-depth site-specific IATA Dangerous Goods Training.

Q&A: How can I ship a combustible liquid by air?

A question from the regulated community (10.24.17):

Good afternoon Daniel. I am shipping a combustible liquid and wanted to know if I can ship overnight by air if it falls under excepted quantity. It has a flashpoint of 80 Celsius. Will it require dangerous goods paperwork and placarding? If under 500mL I can ship by excepted quantity without placarding and paperwork correct? If over 500mL would it have to go ground only? I do not see combustibles in section 4.2 in the IATA book.

Thanks for your help sir.

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I knew this was going to be a tough question to answer because it referenced a classification unique to the U.S. (Combustible Liquid), a complicated packaging exception (excepted quantity), and two distinct sets of regulations (the USDOT/PHMSA Hazardous Materials Regulations for transport within the U.S. and the IATA Dangerous Goods Regulations for transport by air). So, I asked for more information and more time:

Thank you for contacting me.

This is a very tough question which is taking me some time to research. If you can provide some additional information, that would be helpful:

What is the material? Does it have a classification other than combustible liquid?
Is the maximum net quantity of the inner packaging no more than 30 g or 30 ml?
Is the maximum net quantity of the outer packaging no more than 500 g or 500 ml?

Thank you and please advise.

He replied the next day (10.25.17):

Here is the SDS (SDS was attached to the email). Inner packaging would be 500mL. Maximum net quantity of the outer packaging would be 500mL.

The following relevant data was obtained from the SDS:

Contains: 95% N-MethylAminoPropylTriMethOxySilane and <5% Methanol
Flash point: 82 °C (179.6 °F)
Section 14 indicates classification as UN1993, Combustible liquid, n.o.s.
No classification per international regulations (IATA or IMO) is indicated.
No other information in SDS indicates material meets defining criteria of other HazMat / dangerous good.

Ball was back in my court. I replied later that day:

I think I have an answer for you. Please see below.

Based on the SDS it is a hazardous material (HazMat) as defined by USDOT/PHMSA as a Class 3 Combustible Liquid.
The international regulations – including IATA – do not have a classification for, and do not regulate, a Combustible Liquid. Therefore, this material is not regulated per IATA.
49 CFR 171.22(c) of the Hazardous Materials Regulations (HMR) requires a HazMat not subject to international regulations – e.g., a Class 3 Combustible Liquid – be subject to the HMR when transported to, from, or through the U.S. regardless of international regulations. This USDOT letter of interpretation confirms it (LOI 13-0020).
A Combustible Liquid transported within the U.S. is subject to the combustible liquid exception if it is not transported in a bulk packaging and is not classified as a hazardous substance, hazardous waste, or marine pollutant. Based on the information provided I presume this HazMat is none of those.
To be be eligible as an excepted quantity per USDOT/PHMSA and IATA regulations the maximum net quantity of the inner packaging must be no more than 30 g / 30 mL and the maximum net quantity of the outer packaging must be no more than 500 g / 500 mL. Based on your earlier email your HazMat exceeds the maximum net quantity for the inner packaging and therefore can’t be transported as an excepted quantity.

In summary:

Based on the information provided the material as described is not subject to the regulations of either USDOT/PHMSA or IATA when transported within the U.S. or internationally by any mode as long as the requirements of the Combustible Liquid Exception are met.

I hope this helps.

Please don’t hesitate to contact me with any other questions.

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That appeared to satisfy him.

Great! Thanks Daniel. Some of these chemicals can be tricky when shipping.

Conclusion:

The transport of a hazardous material (aka: dangerous good) within the U.S. while subject to international regulations can be a challenge! The classification of a Class 3 Combustible Liquid and the application of the Combustible Liquid Exception are only two examples where international and domestic regulations must be made to work together. Other shipping challenges include: marine pollutants, hazardous substances, & lithium cells or batteries to name a few. And of course, all regulations require periodic training for applicable personnel to ensure knowledge and compliance.

Daniels Training Services, Inc.

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Summary of Significant Changes and Amendments to the 59th Edition of the IATA Dangerous Goods Regulations

The International Air Transport Association (IATA) publishes a new edition of its Dangerous Goods Regulations for each calendar year. In effect for the remainder of calendar year 2017 is the 58th edition. Beginning January 1, 2018 all transport of dangerous goods subject to IATA’s Dangerous Goods Regulations must be in compliance with the 59th edition. The purpose of this article is to summarize the significant changes in store for 2018 in the 59th edition.

What follows is only my summary of the full document issued by IATA (Significant Changes and Amendments to the 59th Edition – 2018). And, IATA includes this disclaimer in their document:

The following list is intended to assist the user to identify the main changes introduced in this edition and must not be considered an exhaustive listing.

So, there’s no substitute for doing the necessary research into the regulations to ensure your transport of dangerous goods by air complies with the IATA Dangerous Goods Regulations. That being said, I hope my summary below will assist you in identifying where in the 59th edition you should focus your research – if at all.

Section 2 – Limitations:

Subsection 2.3 – Dangerous Goods Carried by Passengers or Crew

2.3.5.9 – Now includes limitations – with some exceptions – on the number of portable electronic devices (PED) and the number of spare batteries for the PED allowed to be carried by passengers or crew.

Subsection 2.8 – State and Operator Variations

2.8.3 – Several additions, deletions, and amendments to operator variations.

Interesting note!

There is no indication of changes to state variations at 2.8.1.

Section 3 – Classification:

3.9.2 – This subsection has been restructured to bring in all substances and articles assigned to Class 9 Miscellaneous with their respective UN numbers and proper shipping names.

Section 4 – Identification:

Subsection 4.4 – Special Provisions

A70 – Has been revised to require the shipper to provide documentation stating that a flushing and purging procedure for flammable liquid powered engines has been followed.

A203 – Identifies that vehicles powered by an engine using both a flammable liquid and flammable gas must be assigned to the entry Vehicle, flammable gas powered.

Section 5 – Packing:

5.0.1.5.1 – Has been revised to include new restrictions for some lithium batteries (UN3090 and UN3480) placed into an overpack with most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.

5.0.2.11 – A note has been added: some lithium batteries (UN3090 and UN3480) are not permitted in the same outer packaging with most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.

Packing Instructions:

PI 951 – Has been revised to require a vehicle powered by an engine using both flammable gas and flammable liquid fuels to meet relevant requirements of PI 950.

PI Y960 – A note has been added to reinforce that dangerous goods in Packing Group I are not permitted.

PI 965 and PI 968 – Text has been added to identify the restrictions on packing some lithium batteries (UN3480 and UN3090) in the same outer packaging with most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1. Restrictions are also identified on placing packages of the same lithium batteries into an overpack with most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.

Section 7 – Marking and Labeling:

7.1.5.5.2 – Text has been added recommending that the UN number(s) on the lithium battery mark be of a minimum size.

Out with the old…

59th edition of the IATA Dangerous Goods Regulations

…and in with the new.

Section 9 – Handling:

9.3.2 – Has been revised to introduce segregation requirements for some lithium batteries (UN3480 and UN3090) and most Class 1; and Division 2.1, Class 3, Division 4.1, or Division 5.1.

Appendix B – New Cargo IMP codes have been added for UN3090, Section IA and IB of PI 968-RBM and UN3480, Section IA and IB of PI 954-RBI.

Appendix D – Contact details for competent authorities have been updated.

Appendix E – Changes have been made to the list of UN Specification Packaging Suppliers and the Package Testing Facilities.

Appendix F – Changes have been made to the list of Sales Agents, IATA Accredited Training Schools, and IATA Authorized Training Centers.

Appendix I – This new appendix was added to describe the changes that will come into effect as of January 1, 2019 (i.e. the 60th edition). These changes include:

Replacement of most instances of the word “risk” by the word “hazard”.
Significant changes to the provisions for the classification of corrosive substances.
A new requirement for manufacturers and subsequent distributors of lithium cells or batteries to make available a summary of the UN 38.3 tests.
New provisions for the classification of articles containing dangerous goods, n.o.s.
A number of new and modified special provisions.
Removal of the lithium battery handling label.

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Step 1: Purchase the 59 the edition of the IATA Dangerous Goods Regulations

Step 2: Review the regulations to determine if their were any changes that effect your compliance.

Step 3: Contact me for in-depth site-specific Onsite Training.

Q&A: Do I Describe the Inner Receptacle of a Combination Packaging on the Shipper’s Declaration for Dangerous Goods?

A question from an attendee of my Onsite Training (12.01.16):

Hello Daniel,The question is: On the DGD is it proper to put the outer packaging in the Quantity and type of packaging column. (This is how we have been filling it out since you trained us with no problems from any shipping company)

The forwarder is stating it should say Plastic (Which in the inner packaging) instead of Fiberboard Box (Which is the outer packaging).

Thank you!

I got right on it and had to return to her for some clarification (12.01.16):

I am researching an answer.

Can you provide a description – or a picture – of what the package in question looks like?

Is it two fiberboard boxes inside a third fiberboard box that makes the outer packaging?
Or is it two plastic inner receptacles inside a fiberboard box?
Or something else?

Please advise.

Her reply the next day (12.02.16):

It is nine plastic inner receptacles inside a fiberboard box.

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

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I had a reply ready by December 5th:

I have an answer for you, thank you for your patience. Please see below.

For all packed in one there is no requirement to describe the inner packagings.
All that is required is to show the net quantity of each of the different dangerous goods in the packaging followed by the statement “all packed in one (type of packaging)” and then the Q value.
Some examples of this are shown in the IATA Dangerous Goods Regulations: Figure 8.1.G and Figure 8.1.H.
Figure 8.1.G and Figure 8.1.H.

This matches the overall intent of the DGR when describing dangerous goods on the Shipper’s Declaration for Dangerous Goods: To describe the packages one will see when viewing the consignment, i.e. the outer packagings, and not the inner packagings or receptacles.

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

That did it!

Thank you!

The transportation of dangerous goods (aka: HazMat) requires initial training before performing a regulated function and new training within 24 months (i.e. biennial). Please don’t hesitate to contact me if you require this training or if you just have a question. I’m here to help.

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.

Daniels Training Services, Inc.

815.821.1550

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

International and Domestic

Daniels Training Services

815.821.1550