2011 IATA Updates

By:  Arthur Mahoney, M.S., CHMM, REA

January 3, 2011

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
artServed by an Expert
Arthur Mahoney, Principal Consultant

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

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.


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