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ICC Compliance Center Blog



ICC The Compliance Center Blog » 2010 » August

HM-215K Notice of Proposed Rulemaking

by ICC The Compliance Center on August 30, 2010 at 8:46 am · in Regulations

PHMSA has published HM-215K "Hazardous Materials: Harmonization with the United Nations Recommendations, International Maritime Dangerous Goods Code, and the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air; Proposed Rule."

The rule maintains alignment with international standards by incorporating amendments which include changes to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, air transport quantity limitations, and vessel stowage requirements.

The amendment’s intention is to enhance the safety of international hazardous materials transportation through better understanding of the regulations, an increased level of industry compliance, the smooth flow of hazardous materials from their points of origin to their points of destination, and effective emergency response in the event of a hazardous materials incident.

Shippers of hazardous materials should review all changes for a complete understanding of the various amendments.

The comment period is open until October 25, 2010. The document can be accessed online at http://edocket.access.gpo.gov/2010/pdf/2010-19952.pdf

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Reformatting of the Packing Instructions

by Suzanne Levac on August 27, 2010 at 12:56 pm · in Products, Suzanne's Blog

The packing instructions in the International Civil Aviation Organization (ICAO’s) Technical Instructions for the Safe Transport of Dangerous Goods by Air and consequently the IATA Dangerous Goods Regulations have been the subject of an extensive review by the ICAO Dangerous Goods Panel (DGP) over the last four years. This will result in significant revisions to their design and content.

These reformatted packing instructions:

  • Removed the inconsistencies apparent in the existing packing instructions
  • Introduce a systemic allocation of substances and articles to packing instructions within each class or division. This included for the majority of substances a clear separation of substances by packing group, passenger aircraft or CAO, liquid or solid. Some substances had characteristics that set them apart from these standard groupings, e.g. mercaptans, chloroform, wetted explosives. These substances were assigned to a “special” packing instruction
  • Removed the PPR and instead introduced, when required, clear "Additional Packing Requirements" that apply to all substances or articles in that packing instruction

This information is provided in the 2009-2010 edition of the ICAO Technical Instructions and in the 51st edition of the IATA DGR. The DGP agreed to a 3-month transition period to allow shippers to take care of any "in-stock" dangerous goods shipments. The transition period will allow for shipments prepared on or before December 31st, 2010 to be accepted for transport until March 31st, 2011.

IATA Dangerous Goods Regulations, 52nd Edition

Available as of October 2010 and recognized by the world’s airlines for over 50 years, the latest versions of IATA’s DGR are the most complete, and up-to-date reference materials available to the industry.

Staying in compliance with the latest regulations is critical for safely shipping dangerous goods by air. This year’s changes to the regulations incorporate substantial changes that will have a direct impact to all involved in the transport of dangerous goods by air. These changes include:

  • All new reformatted packing instructions for Classes 3, 4, 5, 8 and 9 and Division 6.1, as well as changes to the new and existing packing instructions;
  • New entries in the list of dangerous goods;
  • Revisions to the provisions for magnetized materials;
  • Provisions to allow for the air transport of solid environmentally hazardous substances in intermediate bulk containers (IBC);
  • Completely revised marking for limited quantity packages to more closely align to the provisions for surface transport as set out in the UN Model Regulations.

Emergency Airworthiness Directive

by Jim Henry on at 9:34 am · in Jim's Blog, Regulations

Transport Canada has issued an EMERGENCY AIRWORTHINESS DIRECTIVE for the certain Bell helicopters. This EAD is marked urgent.

Please see this PDF provided by Transport Canada for more information.

Do I need to display UN number for a 4000 kg shipment?

by Suzanne Levac on at 8:58 am · in Regulations, Suzanne's Blog

In the last two weeks, I have received several calls about the requirement to add a UN number when shipping more than 4000 kg of one UN number.

There has been a change made by Amendment 6 to the TDG Regulations which was published in February 2008 in the table of 4.15 1(b). The word "must" has been changed to "may".

Therefore whenever a consignor is shipping more than 4000 kg of one UN number, the consignor may display the UN number.

See this page on Transport Canada’s website for complete text of section 4.15.

Hot Air Balloons

by Jim Henry on August 16, 2010 at 12:36 pm · in Jim's Blog, Regulations

On June 28, 2010, Transport Canada issued an Advisory Notice about hot air balloons. This notice addresses two (2) issues with the Regulations:

  1. an exemption
  2. cylinder compliance

1. Exemption: Section 1.27 Operation of a Means of Transport or a Means of Containment Exemption of the TDG Regulations does provide an exemption for propane cylinders. The catch is that the hot air balloon must be flight-ready and the cylinders are attached to the hot air balloon. Once the cylinders are removed from the hot air balloon for refill or the hot air balloon is not flight ready, such as when transporting the hot air balloon in a trailer, the exemption no longer applies.

2. Cylinder compliance: in TDG, Section 5.10 Means of Containment for Class 2, Gases requires the selection and use of cylinders in accordance with the Canadian Standards Association (CSA) standard B340. In addition, the manufacture of the means of containment (cylinder) must be done in accordance with CSA B339.

CSA B340 Selection and Use of Cylinders, Spheres, Tubes, and Other Containers for the Transportation of Dangerous Goods, Class 2:  this standard covers the safety requirements for selecting and using cylinders for the transportation of dangerous goods in Class 2. It also covers the requirements for filling and handling of cylinders for Class 2 dangerous goods.

CSA B339 Cylinders, Spheres, and Tubes for the Transportation of Dangerous Goods: this standard outlines the requirements for manufacturing, inspecting, testing, and marking of means of containment for Class 2 Gases, dangerous goods.

Please keep in mind that in TDG, Section 5.10 Means of containment for Class 2, Gases, that clauses 4.1.1.1, 5.1.3(a)(ii) and 5.1.4(a) of CSA B340 do not apply. In other words, equivalent means of containment are not permitted, the means of contaiment must meet CSA B340.

For more information see Transport Canada’s website.

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