iata

Training Requirements for Persons Involved in the Transportation of Lithium Batteries

Lithium ion battery for cell phoneIn case you haven’t heard, the transportation in commerce of lithium batteries of all types – and of almost all sizes – is subject to the regulations of several regulatory agencies depending on how it is to be transported.

  • Transportation to, from, or through the U.S. (including its overseas territories and states) is subject to the Hazardous Material Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation (USDOT).
  • Transportation by air anywhere in the world (including to, from, or through the U.S.) will likely be subject to the Dangerous Goods Regulations of the International Air Transport Association (IATA).
  • Transportation by vessel in international waters (which may include U.S. territorial waters if so chosen by the shipper) will be subject to the International Maritime Dangerous Goods Code (IMDG Code) of the International Maritime Organization (IMO).
  • Even the United States Postal Service (USPS) has regulations for the transportation of lithium batteries.

There is not enough space here to document all of the requirements of all of these regulations for all of the possible modes of transportation.  In an earlier article I provided information to assist you with the process of the classification of a lithium battery for transportation; the information in that article pertained to all modes of transportation.  In this article I will explain just one small – though critical – requirement of the regulations for the transportation in commerce of lithium batteries by air:  The responsibility of the employer to provide training for persons involved in the transportation of lithium batteries.

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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.

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/

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/

Lithium Metal Batteries to be Banned from Transport as Cargo in Passenger Aircraft in 2015

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.

Air Transportation of Hazardous Materials

Check with your carrier to see if they require compliance with the IATA DG Code

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.

Lithium Metal Batteries banned from passenger air transport as cargo

You must identify the type of lithium battery and how it is to be transported.

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:
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.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

 

Significant Changes and Amendments to the 55th Edition (2014) of the IATA DGR

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…)

International Standards & Regulations for the Transportation of Hazardous Materials

The US Department of Transportation (US DOT) regulates the transportation in commerce of hazardous materials within the US.  Its authority does not extend beyond our borders however and so the transportation of hazardous materials (referred to as dangerous goods in international regulations) outside US borders are subject to international standards and regulations.  At 49 CFR 171.22 the US DOT authorizes the use of international standards & regulations (with certain conditions) in lieu of compliance with the US DOT’s domestic regulations when shipping hazardous materials/dangerous goods either internationally and/or domestically.  The US DOT has reciprocal treaty agreements with four regulatory agencies and therefore authorizes the use of the following standards & regulations:

  • The International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions).
  • The International Maritime Dangerous Goods Code (IMDG Code).
  • Transport Canada’s Transportation of Dangerous Goods Regulations (Transport Canada TDG Regulations).
  • The International Atomic Energy Agency Regulations for the Safe Transport of Radioactive Material (IAEA Regulations).

The transportation of a hazardous material/dangerous good in compliance with the standards & regulations of an international agency – even one authorized by the US DOT – is not enough, you must also comply with applicable DOT regulations (those conditions mentioned earlier).  These requirements are found at §171.22(b-g) as follows:

  • HazMat/dangerous good shipment must be transported in compliance with the applicable international standards & regulations.  Therefore the  US DOT has the authority to enforce the international standards & regulations when used in domestic transportation the same as they enforce the Hazardous Materials Regulations (HMR) of 49 CFR.
  • HazMat/dangerous good shipment must also comply with these regulations:  49 CFR 171, Subpart C – Authorization and Requirements for the Use of International Transport Standards and Regulations.
  • If a material is designated as a hazardous material by the US DOT but is not recognized as a dangerous good by international standards & regulations it cannot be transported as a non-hazardous material within the US.
  • Conversely if a material is not regulated as a hazardous material by the US DOT but is regulated as a dangerous good by international standards & regulations, it may be transported as a dangerous good within the US in full compliance with the applicable international standard or regulation.
  • If a material or package is forbidden to be transported within the US by the US DOT, then it may not be transported within the US even if allowed by international standards & regulations.
  • Except for transportation by highway or rail between the US and Canada pursuant to §171.12, importers of hazardous materials into the US must provide specified information to the forwarding agent at the place of entry into the US.
  • For imports, the shipper’s certification required by §172.204 must be provided to the initial US carrier by the shipper.  A US carrier may not accept a hazardous material shipment without a shipper’s certification unless the certification is not required by US DOT regulations.
  • Shipping paper and package markings must be in English.  However, you may use both English and another language if required by the regulations of a foreign entity.
  • Shippers and carriers must retain copies of shipping papers as required at §172.201(e).
  • Additional requirements for all shipments of HazMat within the US:
      • Emergency response information required by Subpart G of part 172.
      • Train and test HazMat Employees per 49 CFR 172, Subpart H.
      • HazMat security requirements of §172, Subpart I.
      • HazMat incident reporting requirements of §171.15-16.  Includes:
        • On board vessels in the navigable waters of the US.
        • Aboard aircraft of US registry anywhere in air commerce.
      • For export shipments:
        • General packaging requirements of §173.24 & §173.24(a).
        • The requirements for the reuse, reconditioning, and remanufacture of packagings in §173.28.
      • The registration requirements of §107, Subpart G.

49 CFR 171.23 contains requirements for shipments of specific materials shipped under international regulations within the US:

  • Cylinders
  • Aerosols
  • Air bag inflators
  • Chemical oxygen generators
  • Class 1 Explosives
  • Hazardous substances
  • Hazardous wastes
  • Marine pollutants
  • Organic peroxides
  • Poisonous by inhalation materials
  • Class 7 Radioactive
  • Self-reactive materials

49 CFR 171.24, 25, & 26 contain additional requirements when using the ICAO Technical Instructions, IMDG Code,  and the IAEA Regulations, respectively.

To sum up:  the US DOT allows the transportation of hazardous materials – even entirely within the US – in compliance with international standards & regulations in lieu of 49 CFR.  However,  you are still required to comply with the applicable requirements of the US DOT for the hazardous materials shipment.  And, if you follow international standards and regulations for your shipment of HazMat, the US DOT remains the enforcement agency in US Territory for determining compliance.

The 800-pound gorilla in the room that has yet to be mentioned – and indeed is not mentioned anywhere in the HMR – is the Dangerous Goods Regulations of IATA:  The International Air Transportation Association.  IATA is a creation of the airline industry, is based on the ICAO Technical Instructions, and is not authorized for use by the US DOT.  However, since it is based on the ICAO Technical Instructions and they are authorized by US DOT, compliance with IATA – and the regulations of this Subpart – will ensure compliance with the HMR.  More on IATA in future article.

I can provide training to comply with the HMR of the US DOT and the Dangerous Goods Regulations of IATA.  Contact me for a free consultation of your training needs.