overpack

Q&A: Must I list all overpack codes separately on the Shipper’s Declaration for Dangerous Goods?

Q&A: Must I list all overpack codes separately on the Shipper’s Declaration for Dangerous Goods?

Question:

Hi, Daniel, we have an IATA  question for you.

Note:

Note: IATA is the International Air Transport Association. It’s Dangerous Goods Regulations – updated annually – contain all of the requirements of the International Civil Aviation Organization’s (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air. It is applicable to all airlines that are members of IATA and “all shippers and their agents that offer consignments of dangerous goods to these operators.” If you offer a hazardous material for transport by air, you will likely have to comply with the IATA DGR.

When we have multiple identical overpacks of the same dangerous good, could we put on the declaration “A1 through A33” instead of listing each A1, A2, etc.?

Shipper's Declaration of Dangerous Goods

Here’s how they were doing it: listing each overpack separately by its identification mark.

I think we cannot, but wanted verification.​ But if we can- it would simplify our warehouse manager’s life.

Thank you!

My reply:

Yes you can. Please see below for a more thorough answer.Dangerous Good Transport by Air

  • To facilitate identification, loading, and notification, the operator requires an overpack to show an identification mark (which may be any alpha-numeric format) and the total quantity of dangerous goods. This information must also be entered on the Declaration. The total quantity of the Declaration must match the total quantities shown on the overpack.
  • Step 7 of 8.1.6.9.2 describes the requirements for completing the second sequence of the Shipper’s Declaration for Dangerous Goods: Number and Type of Packagings, Quantity of Dangerous Goods when dangerous goods are packed in an overpack – or multiple overpacks.
  • Step 7 of 8.1.6.9.2 does not address your situation directly. It does refer to Figure 8.1.N Example 10 which does.
  • Figure 8.1.N Example 10 displays a situation of four (4) overpacks with identical contents. On the Declaration it is described as follows:

 

  • So, it is acceptable to display the overpack identification marks as a range instead of displaying each identification mark separately.
  • Also, it is not necessary to display “Marine Pollutant” on the Declaration unless it is a bulk packaging.
    • The IATA Dangerous Goods Regulations do not require any additional description for a marine pollutant.
    • USDOT/PHMSA Hazardous Materials Regulations require an additional description for a marine pollutant transported by air but only if in a bulk packaging. Since the dangerous good is not in a bulk packaging, it does not require any additional description on the Declaration.

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

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

Info@DanielsTraining.com

https://www.danielstraining.com/
Conclusion:

And that did it! If you are offering a package of a dangerous good to be transported by aircraft you must comply with the IATA Dangerous Goods Regulations (be sure you have the latest Edition!). Also, if the air transport begins and/or ends in the U.S. you must also comply with the USDOT/PHMSA Hazardous Materials Regulations (updated every six months!) Both of these regulations require that you provide training for any personnel with a direct effect on the safe transportation of the dangerous good. Let me help you to meet these training requirements!

Q&A: Is this an overpack?

October 19, 2016. An email from someone within the regulated community:

40# Jerricans are placed in an enclosure. The enclosure consists of 4 walls 4′ high 4’across and 4′ wide. The walls can be disassembled from around the Jerricans. Would walls that can be disassembled from around these packages be considered a container, package, or enclosure? Would this assembly be considered a container, package, or enclosure? Thank you.

Note:  Per 49 CFR 171.8, Jerrican means a metal or plastic packaging of rectangular or polygonal cross-section.

My reply that same day:

I will attempt to answer your question. Please see below.

  • I assume the 40# Jerricans are the authorized packaging for a hazardous material, they meet the DOT specifications and are marked to show this, and have all the required HazMat labels and markings.
  • If the above is true, then anything you use to enclose the jerricans meets the definition of an overpack. What you describe is acceptable as an overpack. You can read more about an overpack (and a salvage drum) in this article I wrote for New Pig: Salvage Packaging vs. Overpacks: What’s the difference?
  • All HazMat labels and markings on the jerricans must be visible on the outside of the overpack along with the word “Overpack”. Labels and markings should appear on at least two opposing sides of the overpack.
  • For the purposes of the USDOT regulations it would be considered an Overpack. Other terms (container, package, or enclosure, &etc.) don’t apply.

I hope this helps.

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

My answer appeared to satisfy him (10.22.16):

Thank you so much!

The use of an overpack in the transportation of hazardous materials should be a simple thing, but it isn’t.  Some of this is due to the confusion between the terms “overpack” and “salvage packaging”; a confusion I tried to clear-up in my above-referenced article.  Some is due to a hesitancy on the part of the shipper or reluctance on the part of the carrier to deal with this additional requirement of shipping a hazardous material.  Whatever your concern, contact me if you have any questions about the use of an overpack for the transportation of your hazardous materials.

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 Difference Between a Salvage Drum and an Overpack for the Transportation of a Hazardous Material

The requirements for use of a salvage drum are explained in the USDOT/PHMSA Hazardous Material Regulations at 49 CFR 173.3(c).  Those for the overpack are explained at §173.25(a).  Both salvage drum and overpack are defined at §171.8.  These are two distinct regulatory terms and yet there is a lot of confusion about which is which and when one is chosen and the other is required.  To answer these questions I refer you to an article I wrote for New Pig:

Salvage Packaging vs. Overpacks:  What’s the difference?

It has the advantage of containing links to more information about each of these packagings from New Pig’s catalog.

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/

 

Package Orientation Arrows on HazMat Packaging

So common you many notice them let alone be aware that they are a package marking required by the hazardous Material Regulations of the PHMSA/USDOT:  Package orientation arrows.  The purpose of this article is to explain the requirements for the use of the package orientation arrows at 49 CFR 172.312 and §173.25.HazMat packaging with package orientation arrows (more…)