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Changes for IATA & IMDG Code for 2013

by James Henry, CDGT, CET on September 4, 2012 at 9:40 am · in Jim's Blog

Based on the information available to date, the following are some of the changes that will be in the 2013 editions of the IATA Dangerous Goods Regulations and the IMDG Code.

  • lithium ion batteries > 100 Wh but < 160 Wh may be carried as spare batteries in carry-on baggage
  • portable electronic devices containing batteries should be in carry-on baggage and be protected to prevent short circuits
  • medical devices or equipment that contains or may contain infectious substances are not subject to the regulations provided that the item is packed so that there will not be any leakage
  • packages containing medical devices or equipment must be marked “Used Medical Device” or “Used Medical Equipment”
  • lithium cells and batteries must be of a type proved to meet the UN Manual of Tests and Criteria
  • dangerous goods list additions:
    • UN3496 batteries, nickel metal hydride
    • UN3497 krill meal
    • UN3498 iodine monochloride, liquid
    • UN3499 capacitor
    • UN3500 chemical under pressure, n.o.s.
    • UN3501 chemical under pressure, flammable, n.o.s.
    • UN3502 chemical under pressure, toxic, n.o.s.
    • UN3503 chemical under pressure, corrosive, n.o.s.
    • UN3504 chemical under pressure, flammable, toxic, n.o.s.
    • UN3505 chemical under pressure, flammable, corrosive, n.o.s.
    • UN3506 mercury contained in manufactured articles
  • dangerous goods list deletions:
    • UN3492 toxic by inhalation liquid, corrosive, flammable, n.o.s.
    • UN3493 toxic by inhalation liquid, corrosive, flammable, n.o.s.
  • the excepted quantity code for the various silanes has changed to E0
  • special provision 240 applies to vehicles powered by batteries, such as, scooters, e-bikes, wheelchairs, etc. Hybrid vehicles must be consigned under one of the following: UN 3166 Vehicle, flammable gas powered or UN 3166 Vehicle, flammable liquid powered, as appropriate. Vehicles which contain a fuel cell shall be consigned under the entries UN 3166 Vehicle, fuel cell, flammable gas powered or UN 3166 Vehicle, fuel cell, flammable liquid powered, as appropriate.
  • special provision 304 is now about transporting non-activated batteries
  • special provision 360 is for lithium battery powered vehicles consigned under UN3171
  • special provision 361 is for electric double layer capacitors with energy storage capacity > 0.3 Wh
  • special provision 362 is for liquids, pastes or powders that are pressurized with a propellant
  • special provision 363 is for dangerous goods in equipment where the dangerous goods are in excess of the limited quantity index
  • new packing instructions for chemicals under pressure (et al) UN3500 – UN3505
  • the marking of the identification number on packages must be a minimum of 12 mm in height, including the prefix UN, except for packages of < 30 L/ kg, where the info must be 6 mm in height
  • new warning mark for containers that use dangerous goods for cooling or conditioning purposes
  • for UN0336 and UN0337, the shipping document must include the classification reference issued by the competent authority
  • in addition, there are editorial updates – i.e. punctuation changes, spelling corrections, etc. that are too numerous to list.

 

Please keep in mind that as of January 1, 2013, the IATA Dangerous Goods Regulations, 54th Edition, will come into force – no transition period. The IMDG Code, Amendment 35-10 will still be in force for 2013. Amendment 36-12 is optional for 2013, but becomes mandatory in 2014. In other words, 2013 is the transition period for Amendment 36-12.

2013 IATA DGR (54th Edition)
IATA Publications
IMDG Code
IMDG Publications

ICAO Addendum No. 5

by James Henry, CDGT, CET on July 20, 2012 at 12:01 pm · in Jim's Blog, Regulations

This addendum consists of additions and changes to state and operator variations.

The following states have added variations:

  • BR -Brazil: 8 variations dealing with the state Civil Aviation Regulations, monthly reporting, exemptions/approvals, use of Portuguese for domestic shipping, training requirements and radioactive approvals,
  • HR – Croatia: 5 variations dealing with dangerous goods approvals, Croatian Civil Aviation Agency approvals, approvals for radioactive materials, and prior approvals for explosives.
  • OM – Oman: 1 variation re: prohibition to/from/over Oman unless approved, required to apply 5 days prior to transport.

The following states have changed variations:

  • CA – Canada: the link to the TDG web page has changed
  • IR – Islamic Republic of Iran: radioactive material is subject to prior approval, segregation rules for Class 6.1 from Class 8, Class 4.1 from Class 4.3, SP A1 or A2 require prior permission
  • NL – Netherlands: NL2 Not used, prior permission required from the Civil Aviation Authority, application for a dangerous goods licence to be 6 weeks before first flight
  • RO – Romania: permit required for cargo of weapons, ammunition, explosives, radioactive materials and other dangerous goods, RO4 Not used.
  • SG – Singapore: operators must obtain a dangerous goods permit, Air Navigation Order defines munitions of war (MOW) – permit required for MOW
  • VC – Sri Lanka: application for permission must be made at least 10 days before first flight

The following operators have filed variations:

  • Air Caraibes – TX
  • Air Caraibes Atlantique – 8X
  • Air Tahiti – VT
  • Air India – AI
  • JSC Siberia Airlines – S7
  • Llc GloBus – GH
  • SriLankan airllines – UL
  • TAM Linhas Aereas – JJ is now TAM Airlines – JJ

Operators that have removed their variations:

  • Continental Airlines – CO
  • Indian Airlines – IC
  • Mexicana Airlines – MX
  • Southern Air Transport – SJ

There are 35 changes to the operator variations which include the above. Issues that are common to these variations are:

  • requirement for a 24 hour number for emergencies
  • provision for MSDS inclusion
  • radioactive materials: what’s permitted, permissions required
  • lithium ion and lithium metal batteries
  • package types for class 8 and class 6.1
  • requirements for absorbent for liquids
  • single packaging vs combination packagings
  • requirement for overpacking

The full document from ICAO can be found on ICAO’s website

See all ICAO publications from ICC: US · Canada

Derailment in Columbus, Ohio

by James Henry, CDGT, CET on July 12, 2012 at 9:17 am · in Jim's Blog, Safety

At about 2 a.m. Wednesday, approximately 11 cars of a Norfolk Southern train derailed southeast of the Ohio State University campus. This track location is north of the downtown area in an industrial section just blocks from residences.

Emergency responders imposed a mile wide evacuation zone, as flames shot skyward. Authorities stated that three of the burning rail cars contained ethanol. In the daylight, authorities decided to let the fire burn itself out. There is no immediate cause known for the derailment. Two people were injured as they ran toward the accident scene before the flammable vapor ignited in an explosion. They were able to get themselves to the hospital.

The American Red Cross opened an evacuation center at the state fairgrounds and was assisting about 50 individuals.

Norfolk Southern said two locomotives and three of the 98 freight cars were removed from the scene without incident.

Ethanol (also known as ethyl alcohol) is a flammable liquid made by fermentation of a biomass. The flash point for ethanol is -114°C. Although flammability is a major hazard, it is also classified as a depressant drug when ingested. The level of intoxication is determined by the alcohol concentration in the brain. Ethanol is used for a variety of purposes, including, but not limited to: solvent for resins, dyes, pharmaceuticals, cosmetics, beverages, antifreeze, explosives and cleaning preparations.

GHS – What is it?

by James Henry, CDGT, CET on June 6, 2012 at 11:04 am · in Jim's Blog, Regulations, Safety

Many people are asking “What is GHS and what does it mean for me?” GHS is an acronym for Globally Harmonized System of Classification and Labelling of Chemicals. The concept of GHS is to have a globally harmonized system in place for the classification of chemicals, the content of labels and safety data sheets (SDS). This concept is not new as the transportation sector has in place a global system for the transport of dangerous goods that covers classification of chemicals, packaging, labels, placards and shipping documents. The transport sector is governed by the United Nations Committee of Experts on the Safe Transport of Dangerous Goods (UNCETDG). As there was no harmonization in the workplace or consumer sectors, the UN expanded the UNCETDG and created the UNSCEGHS – United Nations Sub-Committee of Experts on GHS. The UNCETDG was re-named UNSCETDG and both committees report to the Committee of Experts on the Transport of Dangerous Goods and Globally Harmonized System of Classification and Labelling of Chemicals (CETDGGHS).

The first edition of GHS appeared in December 2002. The first revised edition was available in 2005 and contained amendments for items such as: aspiration hazards, guidance on pictograms, precautionary statements and preparation of SDSs. The second revised edition came out in 2007 containing amendments for: explosives, toxic by inhalation, skin sensitizers, respiratory sensitizers, building block approach and codification of precautionary and hazard statements. The third revised edition (2009) contained amendments for: labelling of small packages, chronic toxicity for aquatic environments and new provisions for the allocation of hazard statements. The fourth revised edition (2011) contains amendments for: new hazard categories for unstable gases and non-flammable aerosols, clarification of precautionary statements and further clarification of some of the criteria.

Some of the countries that have implemented GHS are: European Union, Japan, Korea, Brazil, Mexico, New Zealand, Taiwan, Indonesia and China. And coming to your workplace in the United States, under OSHA (Occupational Safety and Health Administration). OSHA promulgated a final rule affecting 29 CFR Parts 1910, 1915 and 1926.
OSHA is modifying the Hazard Communication Standard (HCS) to meet GHS (3rd revised edition). These modifications will improve the HCS (or Hazcom 2012) by ensuring that employees (or workers) will be better informed of the chemical hazards that they will be exposed to in the workplace, and reducing the incidents of chemical related illnesses and injuries.

And how will all this be done? This will be accomplished by three things – training, labels, and safety data sheets.

First issue is training. Employers must train their employees on the new requirements by December 1, 2013. This training will involve the changes regarding classification, labels, MSDSs, pictograms, hazard and precautionary statements and signal words. Employers may comply with the HCS, Hazcom 2012 or use both. There is no requirement to keep two sets of labels or MSDSs. The effective date for full compliance of the new Hazcom 2012 is June 1, 2015. Distributors will have until December 1, 2015 to ensure that all containers are in compliance before shipping.
The second issue under Hazcom 2012 is the label which will be standardized. There will be two labels – the container label and a workplace label. The container label will consist of:

  • Product identifier
  • Signal word
  • Hazard statement
  • Pictogram(s)
  • Precautionary statement
  • Name, address, telephone number of manufacturer/importer/distributor

The workplace label can have the above elements displayed on it or a label that has the product identifier on it with words, pictures, symbols or a combination, which will provide employees with specific information on the hazards of the chemicals.

Container Labels Workplace Labels
Container labels Workplace Labels

The third issue is the current material safety data sheet (MSDS) becomes the safety data sheet (SDS). The SDS will be 16 sections in a standard format:

  1. Product identification
  2. Hazard identification
  3. Composition/ingredients
  4. First aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological data
  13. Disposal information
  14. Transportation information
  15. Regulatory information
  16. Other information including date of last revision

Sections 12, 13, 14 and 15 are not mandatory to OSHA, but are necessary to have a compliant SDS. Enforcement for compliance for these four sections will not be done by OSHA, as they are outside the jurisdiction of OSHA.

The result of Hazcom 2012 is improved safety, global harmonization of standards and annual savings of millions of dollars. Through GHS, chemicals that are imported will have the same standards for labels and SDSs resulting in less confusion in the workplace.

And where is Canada on GHS? Recently Health Canada (HC) issued a working document outlining the changes that are intended for the Controlled Products Regulations under the Hazardous Products Act. The changes would implement GHS in the workplace under WHMIS. HC has indicated that they are not going to change the name of Canada’s chemical classification and hazard communication standard, also known as, WHMIS. They have indicated that it will continued to be called WHMIS and that the relevant sections will change to meet the GHS requirements. Expectation is that HC will introduce proposed regulations in Canada Gazette I at the end of the federal fiscal year – March 2013.

Stay tuned – there’s lots more to come.

New Limited Quantity Mark

by James Henry, CDGT, CET on at 8:00 am · in Jim's Blog, Products, Regulations

Transport Canada announced at the COSTHA annual forum that they are moving quickly to update the regulations to permit the use of the new limited quantity mark:

New limited Quantity Mark

Click here to see our limited quantity labels.

Marie-France Dagenais, Director-General of the Dangerous Goods Directorate at Transport Canada told the forum that equivalency certificates will be issued to shippers that apply for them, to allow them to use the new mark. It is expected that an amendment on dangerous goods safety marks will be published in the Canada Gazette, Part I, sometime in June of this year.

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