When shipping limited quantities (LQ), you do not need to use a UN specification package. But what specs should the package you want to use meet? IATA section 2.7.6 states that the shipper must do a series of drop tests and a 24 hour stacking load test before using the package. Does this then mean that the shipper is done?
Section 2.7.5.1 states that 5.0.2 through 5.0.4 must be met, except for 5.0.2.3, 5.0.2.5, 5.0.2.11(f), 5.0.2.11.(g) and 5.0.2.14.2. Section 5.0.2 is the general packing requirements. The performance test requirements for a package, also known as UN specification packaging, section 5.0.2.3 does not apply as well as 5.0.2.5. After reading these sections, does this mean the shipper can use their package? Not quite, there is another section to read – 2.7.5.5. Here it states that the outer packaging must meet the construction requirements of section 6.2. For combination packages, the most used outer packaging is the fibreboard box. In section 6.2.12, it states that the box must be subjected to the Cobb test. This is a test to determine the water absorbency of the fibreboard box, where the increase in weight cannot exceed 155 g/m2.
Are shippers aware of this requirement? And how are they to determine this when selecting a packaging to use? It might just be easier to use a UN specification package and send the shipment fully regulated.
by Jim Henry on April 25, 2011 at 9:18 am · in Jim's Blog
This year’s Forum was held in Scottsdale, Arizona at the Hilton Scottsdale Hotel.
Sunday started with a course – Safe and Compliant Transportation of Batteries presented by Tom Ferguson (COSTHA) and Brendan Sullivan (IATA).
Japan does not allow the first year of an IMDG Code amendment to be optional, it is mandatory. For the 35th Amendment, the following do not apply during 2011:
Limited quantity mark
UN3171 Battery powered equipment
UN3476 Fuel cell cartridges (packed with or in equipment)
For lithium, there are cells: cylindrical, prismatic and polymer; for batteries: laptop, camcorder, hybrid vehicles (to name a few). When looking at lithium, we need to look at cells vs. batteries. For lithium ion, we use ELC – equivalent lithium content or watt hour (Wh) rating. These can include lithium cobalt, lithium ion phosphate, etc. For lithium metal, the content of the lithium is used. Lithium cells/batteries are subject to the UN Manual of Test and Criteria, section 38.3. This section outlines the tests required, such as:
Altitude
Vibration
Shock
Short circuit, and
Overcharging
If the cells/batteries do not pass the tests, then they would require competent authority approval.
For shipping lithium batteries by air, each packing instruction has 3 sections – general, section 1 fully regulated and section 2 excepted. For shipments under section 2, the requirements are similar to SP188 of the UN Recommendations. These are excepted shipments not non-restricted; in other words, the batteries are still dangerous goods. The lithium battery label of 120 x 110 mm can be reduced in size to 74 x 105 mm for smaller packages.
Section 1 is for fully regulated batteries. In the IATA Dangerous Goods Panel, for 2013, there will be a move away from gross weight. For 2011, there are 3 new special provisions – A181, A182 and A183.
Shipping lithium batteries under the IMDG Code results in the use of packing instruction P903. Nickel metal hydride (NmH) batteries are regulated under the IMDG Code. In the 35th Amendment, SP963 and SP117 apply. In column 8a of the Code, it reads “See SP963”. For quantities > 100 kg, a shipping document MUST state “Stow away from Heat”, and column 16 applies for segregation – stow away from heat. No marks, labels or placards are required.
The battery roundtable discussed recycling, focus on the auto industry, manufacturers will start collecting alkaline batteries later this year, need for the Wh marking and which regulations to use. Geoff Leach (UK CAA) stated that when he was last in Beijing, he was handed a map on where to buy knock-off products. This indicates that there needs to be training to overcome the cultural issue, so that only OEM tested materials are shipped. There is also a need to educate the passenger who TSA is looking at doing in the waiting line and/or during the aircraft safety briefing.
Geoff continued with harmonization in which he stated that confusion results where regulations differ resulting in frustration. The air acceptance requirements need to change to have some sort of undeclared dangerous goods protocol and develop standardized risk analysis. Some problems with shipping by air are batteries:
Used batteries – not recalls but spent, holds no charge, etc.
Relabeling – OEM ships regulated, properly marked/labelled batteries to Company A who rebrands the battery but it does not have the required label markings.
Rebuilt/refurbished – some types of batteries can be rebuilt, but it still has the original label; the rebuilt battery should be retested but this does not happen
For shipping dangerous goods by air, the bottom line is safe travel.
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!
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.
by Jim Henry on December 4, 2009 at 3:10 pm · in Jim's Blog
Shipping lithium batteries has become a confusing issue. Let’s start by asking "what is a lithium battery?". There are two types of lithium batteries – metal and ion (polymer). The lithium metal battery is also termed "primary" which means non-rechargeable. Typically you find these batteries in watches, calculators, cameras, etc. Lithium ion (and polymer) are "secondary" or rechargeable batteries. These are found in mobile phones, laptop computers, satellite navigation units, etc.
