I attended the sixth Dangerous Goods Instructor Symposium (DGIS VI) hosted by LabelMaster in Memphis TN last week.
Things started on Tuesday evening with the Dangerous Goods Trainers Association (DGTA) meeting. The changes concerning NESHTA, BCSP, IHMM and others were discussed. Bob Richard has suggested the DGTA make application at the UN for consultative status. This would allow DGTA to attend the UNSCOE on TDG as observers or as a NGO (non-governmental organization). The website has been updated, see www.dtga.org/. There was also discussion on which trade shows that DGTA should attend.

Later that night some of us boarded buses to go the the FedEx world hub. Here we were given a tour of the FedEx Memphis Hub (night-side) facilities.

Some interesting points of interest:

• handles approx. 1.3 million packages daily
• averages 140 landings per night (every 90 seconds)
• averages 140 takeoffs per night
• aircraft unloaded in under 30 minutes
• fleet of more than 366 aircraft (727s to A300s to 777)
• 7,000 employees at the hub
• covers 863 acres
• approx. 42 miles (68 km) of conveyor belts

Thanks to David Jones of FedEx for arranging the tour.

The Wednesday morning session on the ABCs of Training Objectives. This workshop covered the basics in making brief, concise, clear learning objectives. After lunch, Howard Skolnik of Skolnik Industries did a hands-on session on Writing of packing and closure instructions: an exercise in authorship. Howard gave each table an exercise on writing an instruction for a simple every day function. Our table were to write a procedure for tying shoelaces. Another table got the wine bottle with corkscrew (the bottle was empty), another on how to fold a fitted sheet, and another on how to blow up a balloon. You can imagine the fun that was created with this exercise! Howard then made available different packaging examples to each table and we had to write the closure instructions. This was a great exercise, we just did not have enough time to complete the exercises. The last session dealt with our Pet Peeves in the regulations. Some examples that came up were:

• why does ICAO require 2 technical names and IATA does not?
• 49 CFR: is it basic description or shipping description or description when it comes to describing the dangerous goods that are to be shipped?
• are closure instructions necessary for compressed gas cylinders?
• IMDG: when listing several paints with different flash points, which flash point gets listed on the shipping document?
• ICAO A69: forces the shipper to recognize mercury as dangerous goods

Thursday began with an ICAO update from Geoff Leach, chair of the ICAO Dangerous Goods Panel. Over 100 papers have been submitted and each one has to be reviewed during the 8 days that have been scheduled for the 2013/2014 Technical Instructions session. Some of the issues that have been brought forward:

• when it says “not subject to the Technical Instructions”, what does this really mean?
• recurrent training going to calendar date
• oxygen generators – the ValueJet crash needs to be kept in everyone’s mind; recent incident in Australia with these
• EHS (environmentally hazardous substance): ICAO was too quick off the mark to align with the UN when other modes had not, going back to the 15th Edition to allow for transition
• gross mass will only apply to LQ, definition of net mass means the article not the dangerous goods in it
• class 6.1 subsidiary for mercury will be optional unless the content is > 5 kg
• dangerous goods in crew baggage is not addressed, it will be the same as for passengers
• undeclared vs misdeclared: undeclared means that there is no shipper’s declaration, mis-declared means it is not what it is

ICAO proposals:

• how to deal with Ebay, i.e. large lighter with 3 Li batteries flashlight in the handle
• training for the load-master and security staff
• reporting of dangerous goods that have not been loaded properly
• changes to the NOTOC to simplify the form
• Li batteries: remove section II, package according to the TIs
• dangerous goods in helicopters
• maximum spare batteries for passengers/crew is 2; this poses problems for those who have to use a nebulizer, etc.

Online shopping – whether from large internet companies such as Amazon, to individual vendors on sites such as eBay – has grown, well, explosively, in the past few years. But with this growth has come a headache for shippers, receivers and regulators. How do you handle online purchases of product that may actually be classified as dangerous goods (or, in the US, as hazardous materials)?

Often, people are not aware that common consumer products may be considered hazardous for transportation. These include:

• Aerosol sprays
• Cosmetics, such as nail polish remover or perfumes
• Flammable liquids, such as paints and adhesives
• Smoke detectors containing radioactive sources
• Fireworks
• Refrigerants (including those in equipment)
• Fire extinguishers
• Goods with internal combustion engines
• Lithium batteries, including batteries packed in or with electronic equipment

There are, of course, provisions in various regulations such as the US Hazardous Materials Regulations of 49 CFR (Title 49 of the Code of Federal Regulations), and Canada’s Transportation of Dangerous Goods (TDG) Regulations. Small packages of dangerous goods can often be shipped more easily under the provisions for Limited Quantities or Consumer Commodities. These provisions, however, do vary from country to country.

In addition, the regulations for shipment by air are much more stringent. Shipments by carriers who specialize in fast delivery may need to comply with the system for air transportation from ICAO (International Civil Aviation Organization), and IATA (International Air Transport Association). These may require additional packaging, labeling or paperwork, and in some cases will completely prohibit the transportation of goods that can be legally transported by ground.

If you plan on selling products online that may be considered dangerous goods or hazardous materials, here are some things you will need to do:

• Consult your national transportation regulations. These will identify what qualifies as dangerous goods, as well as any exemptions or special cases that you can use to reduce the regulatory burden when shipping them
• Consult with your carrier. Most national postal services will have restrictions on transport of dangerous goods, so simply boxing up those aerosol cans and popping them into the mail may be against the law. Here are some sources for information on typical carriers for online purchases:
  • The United States Postal Service has an online guide to hazardous materials mailability rules at http://pe.usps.com/text/dmm300/601.htm#1064962
  • Canada Post has guidance at www.canadapost.ca
  • UPS addresses how to set up dangerous goods service at www.ups.com
  • The FEDEX rules are given at www.fedex.com (Canada) and www.fedex.com (United States)
• If using the services of an online store such as eBay, consult their terms of service. eBay will allow some hazardous materials to be sold through their website, but only if the listing clearly describes the hazardous nature of the product, and specifies a shipping method that meets regulatory and postal service requirements
• International shipments require knowledge of other country’s regulations. Many countries will have restrictions or licensing requirements for various types of dangerous goods in addition to the actual transportation regulations. Do not assume that just because your national regulations permit a shipment, that the countries of transit or the receiving country will also do so
• Determine if the shipment will be cost-effective. It may be more money than it’s worth in extra shipping costs to ship, say, a small can of spray paint or spare lithium batteries with a larger shipment. Consider shipping without the hazardous components, and let the customer supply those at the other end

If you purchase dangerous goods online, some suggestions include:

• Only purchase from reputable suppliers, who indicate that they are aware of the regulations, and prepared to meet them
• Check your national regulations for any specific responsibilities that you will have to meet as a receiver (such as training), or government registration of materials such as explosives or radioactives
• Be aware of other regulations that may affect the shipment. For example, verify that the product is legal in your country, and meets applicable safety standards. (That great deal on white paint might just contain an unacceptable level of lead pigment in North America.)
• Be prepared for delays. That great deal on perfume may not arrive right on time for Valentine’s Day

The new online world has created many opportunities for retailers, both large and small. However, the regulations for transporting dangerous goods still apply, just as they have always done. Make sure that you take them into consideration before bidding on that “can’t miss” deal on your favourite shopping site.

If you have questions about transporting hazardous materials or dangerous goods, contact us here at ICC (1-888-442-9628 (USA) or 1-888-977-44834 (Canada)).

Many dangerous goods shippers in the United States are finding themselves using new software to complete their IATA shipper’s declaration for air shipments. A new operator variation for Federal Express (FX-18) requires shipper’s declarations be completed using an approved error checking software.

Most of these programs have rules built in to them that force the user to complete specific areas of the declaration with limited options, sometimes based on previous choices. the options given will always be ones that are authorized by the regulations, but the user must still consider their specific product when making choices. Just because the regulations (and software) allow something, doesn’t make it the best choice.

For example, when shipping hydrochloric acid, PG III on cargo aircraft, you must use IATA packing instruction 856. The packing instruction allows the use of metal single packagings. An error checking software will allow a declaration to show metal drums, but it will not, in most cases, alert the shipper that the metal drum must be corrosion resistant, as specified in the packing instruction.

If you find yourself using a new software system to complete your declarations, make sure you know the limitations of the program and make sure that you understand how to use the regulations. Error checking is not the same thing as fully automated!