2011 has also brought about some
important changes to the IATA Dangerous
Goods regulations (DGR) which may impact
how you ship dangerous goods* by air. I
have summarized some of the changes
below.
DGR Changes in 2011:
Here are some changes in the 2011
DGR that may impact you.
"Limited Quantity" marking is now
required. This has replaced the
words "Limited Quantity" on the
outer package. In addition, the
text "Limited Quantity" is no longer
required on the Shipper's
Declaration.
Limited Quantity marking
List of Dangerous Goods. New
packaging instruction numbers for
all substances in Classes 3, 4, 5, 8
and 9 and Division 6.1. This is a
major change.
Genetically modified micro-organisms
(GMMO) and genetically modified
organisms (GMO) are to be packed
according to the new Packing
Instruction 959 and are not subject
to other requirements.
General packing requirements
have changed and now require a
secondary means of closure
for liquids. For example this could
include adhesive tape around a
bottle's lid.
Packing Instructions. These
have been renumbered and
reformatted. The maximum net
quantity per package, which was
formerly only found in the
applicable columns of the List of
Dangerous Goods (blue pages), is now
also included in the applicable
Packing Instruction. So you will
see both the maximum net quantity
for
each inner type as well as
the
complete package in one
place. This is a bit of a time
saver and should also reduce some
confusion.
Marking and Labeling. The name
and address of the shipper and
consignee should be on the same
surface as the marking for the UN
number and proper shipping name. As
previously mentioned, limited
quantity packages must bear the new
marking instead of the words
"Limited Quantity".
Emergency Responder Contract
Information:
As a reminder, since October 1,
2010, U.S. Department of
Transportation regulations require
the emergency response information
(ERI) provider (e.g., name and
contract number) to be entered in
association with (immediately
before, after, above or below) the
emergency response telephone number
on shipping papers. Also remember
that you must be registered with
the ERI provider and it is your
responsibility to provide them
with accurate and up to date
information (e.g., MSDSs or
profiles).
Training Reminder
and Services
Training Requirements
Who Must be Trained: Have you asked yourself this
question? Very often, companies will
only train and certify Shipping and
Receiving personnel and forget about
other employees who have a role in their
company's dangerous goods shipping
process.
A common situation that
puts companies out of compliance and at
risk occurs when employees (e.g., lab
personnel) without the proper training
and certification package or even
partially package a dangerous good. The
DOT has made it clear that employees who
even "partially" assemble a dangerous
goods package must be properly trained
and certified. This means that even
employees who place sealed primary
containers (e.g., a bottle of
a regulated dangerous good) in an outer
shipping box, which they provide
to Shipping and Receiving personnel
to inspect, close, and mark and label,
are themselves required to be trained
and certified.
As a reminder, per 49 CFR and HM-223**,
all employees who affect hazardous
materials/dangerous goods*
transportation safety must be properly
trained and certified. This includes
employees who:
Determine a material's hazard
class(es);
Select the packaging;
Fill and close a packaging;
Mark and label a package;
Prepare or review shipping
papers and emergency response
information;
As an importer of hazardous
materials/dangerous goods*, provide
the shipper with shipping
requirements that will apply to the
transportation of the material
within the United States;
Certify that a hazardous
material/dangerous good* is in
proper condition for transportation;
Load, block, and brace a
hazardous material/dangerous good*
package in a freight container or
transport vehicle;
Segregate a hazardous materials
package in a freight container or
transport vehicle from incompatible
cargo.
Selecting, providing, or
affixing placards for a freight
container or transport vehicle to
indicate that it contains a
hazardous material/dangerous good*.
How Often is Training Required:
Initial training is required within
90 days of the job
function. Retraining is required with
24 months (air) and
36 months (highway) of
initial training. Additionally,
employees must be retrained when there
are changes in the regulations which
impact them.
What is the Required Content of the
Training:
General familiarization training
Function-specific training
Safety training
Security awareness training
Testing and Certification:
Employees must be tested and certified.
But the testing can (and should) be
customized to the functions of the
employee. It has been my experience
that the most effective training
includes the actual packaging materials,
shipping software, etc that your
employees use.
Our Training Solution
Focused on What You Ship:
Save money and time and improve
compliance by making the training
applicable to your employees.
Employees do not need to go to a 2 or 3
day offsite training
course which may cover many irrelevant
topics and completely miss the ones that
your employees really need to know
well. The program I offer can often be
completed in a single 1-day session (or
several 3-4 hour sessions) at your
facility. In addition, the testing and
certification can also be customized to
the specific job functions and even
include applicable practical exercises
using the actual packaging, software,
etc that your employees use.
Added
Value: Find and Fix Problems
A valuable
outcome of onsite training is
discovering and fixing problems in
shipping programs during the training.
Added Value: Your Very Own Shipping
Guidelines: Included in the training can
be shipping guidelines/checklists
customized to the types of materials you
actually ship. These can also
include procedures and forms for
carriers that you use (e.g., FedEx,
World Courier, UPS, DHL). These are
included in a customized manual for your
shipping personnel.
More Added Value: Packaging Solution
Consultation:
Working with a number of packaging
vendors over the years, I can assist
your organization in developing
customized packaging solutions.
An
Easy Way to Comply
Contact me and I would be happy to
provide you a quotation for dangerous
goods/hazardous materials training
program.
What makes my program especially
valuable is that it is specific to the
dangerous goods/hazardous materials that
you ship and it is presented by me, an
expert in the field.
Other commonly requested services
include:
Chemical safety audits
Safety training, both in person
and hosted web-based
Onsite and special project
support
HMBP and chemical inventory
services (including uploads to CERS)
Hazardous waste auditing,
minimization and reporting
Bloodborne Pathogens (annual
requirement)
Hazard Communication
Chemical Hygiene Plan
Laser Safety
Biological Safety
Radiation Safety
Shop Safety
Many others, please contact me
Served
by an Expert Arthur Mahoney, Principal
Consultant
MS, CHMM, REA
For 19 years, he has been assisting
public and private companies to
comply with safety, hazardous
material management, transportation
and safety concerns. He also
provides chemical inventory database
services.
Feel free to contact us at
650-347-0417 or by
email.
Sincerely,
Arthur Mahoney
Hazard Solutions LLC
*Dangerous
goods includes articles or
substances which may be
hazardous (in air
transport). The definition
of dangerous goods is found
in the Dangerous Goods
Regulations, published by
the International Air
Transport Association (IATA)
. Dangerous goods are
synonymous to hazardous
materials, which is the term
used to describe hazardous
substances in 49 CFR.
**HM-223 clarifies the many
pre-transportation functions
which necessitate training.
Disclaimer: The information
presented above should not
be construed in any way as
legal advice or an
interpretation of
regulations. It is meant to
provide basic information
about topics that may affect
clients and colleagues.
