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.

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 35^th 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 35^th 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.

(To be continued: Tuesday April 26, 2011)

As we approach the start of another new year, we also approach the start of new regulatory requirements. Both the IATA Dangerous Goods Regulations and the IMDG Code have new editions for 2011. The IATA regulations go into effect on January 1, while the IMDG Code has a 1 year transition period before becoming mandatory. If you ship using either of these regulations, you must ask yourself “Am I ready?”

IATA has made significant changes for 2011, and as a regulatory specialist, I am expecting A LOT of panicked phone calls from shippers (and carriers) who were unaware of the changes. In addition to the typical minor changes that happen on a yearly basis, IATA has completely revamped the limited quantity requirements as well as the packing instructions in section 5. The limited quantity requirements even have a new section number assigned to them. I can’t even begin to imagine how much confusion there is going to be with the new packing instructions!

The IMDG Code changes are not as drastic as IATA’s, but that doesn’t mean there won’t be questions. The limited quantity changes have made their way into the IMDG Code, so people who deal with those shipments are going to have to brush up on both regulations.

If you haven’t already checked out the new regulations, make sure that you do so as soon as possible. And don’t forget, if you do run into any problems or questions with any regulatory requirements, you can give us a call and we will help you out.

An errata and corrigenda has been published by the IMO for the 2008 Edition of the International Maritime Dangerous Goods Code. This errata makes a number of changes to the Code:

• reference changes
• minor word changes, i.e. "this data" changes to "these data"
• deletion of single words
• punctuation corrections
• the marine pollutant mark has changed (the fins on the fish are gone)
• several paragraph rewrites
• seven column 16 corrections

A copy of this errata and corrigenda can be downloaded from the IMO website at. Wishing everyone a happy and prosperous New Year.