2012 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 2012:
Here are some changes in the 2012 DGR that may impact you.
The provisions applicable to
limited quantities have been
restructured to bring in all of the
requirements for different dangerous
goods packed in the same outer
packaging into 2.7.5. The text
previously was referenced in
5.0.2.11 and 5.0.3.2.
Special Provisions
A44 - has been revised to
clarify that the chemical kit or
first aid kit must not contain
substances that will react
dangerously. In addition a note has
been added to clarify that if the
dangerous goods inside the kit are
not assigned a packing group, that
then no packing group need be shown
on the Shipper's Declaration.
A802 - is a new special
provision assigned to entries in
Table 4.2 that are not assigned a
Packing Group, but that must, except
when in limited quantities, be
packed in UN specification
packagings that meet Packing Group
II performance standards.
A803 - is assigned against all
Class 8 solid and liquid entries in
Packing Group III to reinforce that
the substance must, except when in
limited quantities, be packed in UN
specification packagings that meet
Packing Group II performance
standards.
A804 - is assigned to UN 2803,
Gallium and UN 2809, Mercury to
reinforce that these substances must
be packed in UN specification
packagings that meet Packing Group I
performance standards.
A805 - is assigned to UN1845,
Carbon dioxide solid, Dry ice to
clarify that it is permitted to be
placed directly within an overpack,
provided that overpack meets the
requirements of Packing Instruction
954.
Packing Instructions
953 - The requirement for the
"magnetized material" statement has
been clarified to identify that the
information must be provided in the
appropriate location on the air
waybill, when used, or otherwise on
alternative transport documentation.
954 - The requirement for provision
of information relating to the dry
ice has been clarified to provide
for an alternative when no air
waybill is used. The information
requirements when dry ice is
presented in a unit load device have
also been made more clear.
965 - 970 - For lithium ion and
lithium metal batteries. A note has
been added to reinforce that the
requirement for all lithium
batteries to have successfully
passed the UN tests applies to any
batteries that have been refurbished
or otherwise altered. In addition
for lithium batteries meeting
Section II it has been clarified
that these batteries are subject to
the restrictions applicable to
carriage in passenger baggage, as
provided for in 2.3; lithium
batteries are subject to
restrictions applicable to air mail
as set out in 2.4, and lithium
batteries shipped in accordance with
Section II are also subject to the
provisions for reporting of
incidents, accidents and occurrences
as set out in 9.6.1 and 9.6.2.
Marking and Labeling
7.1.4.1 - The requirements for
marking overpacks have been
clarified to show specifically which
markings must be reproduced when not
visible and which are not required.
Documentation
8.1.1.1 - In recognition of the
growing use of computer systems to
generate the information on the
Shipper's Declaration, text has been
added to provide alternatives to
strike out of the non-applicable
aircraft limitation and shipments
type. This alternative is set out in
more detail in 8.1.6.5, 8.1.6.8,
10.8.3.5 and 10.8.3.8.
8.1.6.9.2, Step 7 - The method
of describing multiple overpacks has
been expanded upon to align the text
with that in Section 7 for marking
of overpacks.
8.2.3 - The provisions for
information that must be provided on
the air waybill for dangerous goods
not requiring a Shipper's
Declaration has been revised to
reflect the changes that have taken
Handling
9.2.1.1 - New paragraphs have
been added recommending that the
distances shown in Tables 9.3.D and
9.3.E should be applied as a minimum
to separate persons for temporary
storage areas in cargo terminals,
warehouses, etc.
9.5.2.2 - This is a new
paragraph setting out the
recommendations for operators with
respect to the management of
dangerous goods permitted in
passenger and crew baggage where
operator approval is required.
Shipping Software
Requirements for FedEx:
Since January 10, 2011, FedEx Express
has required all Shipper's Declarations
originating in the U.S., excluding all
023 air waybill shipments, to be
prepared using only the following
methods:
FedEx approved vendor software
application
Preapproved shipper proprietary
software; or
FedEx Express Automated Shipping
Solutions that have dangerous goods
error checks.
Contact your Fed-Ex account manager
for assistance. Fed-Ex has a list of
approved software as well.
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.
