2014 has 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. Consult the 55th edition of the DGR for actual regulations.
DGR Changes in 2014:
Here are some changes in the 2014 DGR that may impact you.
Applicability
1.4-Operator Responsibilities. A recommended practice for how operators should provide information to the pilot-in-command for certain items of dangerous goods permitted in passenger and crew baggage has been inserted in 1.4.2.
1.5-Training Requirements. Table 1.5.A and 1.5.B has been modified to clarify "category" of staff, rather than "key". Category 10 has also been modified to include flight operations officers/flight dispatchers who require specific information in accordance with 9.5.1.1.1 as of 1 January 2014 and therefore require dangerous goods training.
Limitations
2.3-Dangerous Goods Carried by Passengers or Crew. A clarification from ICAO on portable electronic devices, including medical devices containing lithium batteries has been made. Medical devices using the higher limits are not permitted in checked-baggage.
Classification
3.3.3.1-Clarification on the requirements that apply for viscous flammable liquids that are assigned to Packing Group III in accordance with the provisions of 3.3.3.1.
Identification
4.2-List of Dangerous Goods. New entries have been added to the list of dangerous goods which are currently assigned UN numbers, but had not previously appeared in the air transport Regulations for completeness. In the absence of provisions for transport by air, these "new" entries are all forbidden for transport by air.
4.4-Special Provisions. Special provisions A4 and A5 have been modified to mandate their inclusion on the Shipper's Declaration when items are transported in accordance with those provisions.
A806-applicable to Batteries, nickel metal hydride has been added to clarify that the UN Number UN3496 is only applicable for sea transport. This UN number has been added to the list of dangerous goods for completeness as indicated above.
Packing Instructions
The packing instructions for lithium batteries 965-970, have been revised to remove duplicate content to clarify the applicable provisions.
PI 965 and PI968-The documentation provisions for lithium ion and lithium metal batteries in Section IB of PI 965 and PI 968 have been revised to mandate the use of a Shipper's Declaration. To assist shippers there is a three-month transition period until 31 March 2014, during which time the information required may still be provided on an air waybill.
Marking and Labeling
7.1.5.5- Clarification that packages prepared in accordance with the limited quantity provisions in surface transport and bearing the surface limited quantity mark, are acceptable for air transport provided that the packages are in full compliance with the marking and labelling requirements for air transport.
7.2.4.7.1- Clarification on the dimensions applicable to the lithium battery handling label, including the dimensions of the reduced size lithium battery handling label.
7.1.7-The provisions for overpack markings have been moved to follow the more logical package marking workflow.
Documentation
The documentation requirements have been modified to reflect the new requirement for Section IB lithium batteries to use a Shipper's Declaration for Dangerous Goods.
8.1.6.9.2- Clarification that alternative spelling is acceptable for other than proper shipping names has been added.
8.1.P- A new example of a completed Shipper's Declaration for lithium ion batteries shipped in compliance with Section IB of Packing Instruction 965.
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.
Select,
provide, or
affix
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 attend a
2 or 3 day
offsite training
course which may spend
much of the time
on 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
Ultimately
companies should
be focused on
compliance. And
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
commonly ship.
These can also
include
procedures and
forms for
carriers that
you use (e.g.,
FedEx, World
Courier, UPS,
DHL).
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:
Onsite
EHS support
and services
on an
as-needed
basis
Regulatory
compliance
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 ExpertArthur
Mahoney,
Principal
Consultant
MS, CHMM
For 20
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.
