by ICC Compliance Center 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
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.
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:
On April 11, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice of proposed rulemaking (NPRM) in the US Federal Register relating to transportation of lithium batteries by air. PHMSA is considering harmonizing the current hazardous materials regulations (HMR) with the requirements that are found in the 2013-2014 ICAO Technical Instructions. PHMSA published an NPRM in January 2010 addressing harmonization to the 2011-2012 ICAO Technical Instructions, but a final rulemaking was not published in relation to that previous NPRM. The new NPRM will incorporate the additional or revised requirements found in the newer Technical Instructions, and will allow interested persons to supplement comments that were submitted previously. The lithium battery provisions recently adopted by ICAO will become effective for international air transport on January 1, 2013. Comments relating to this NPRM are due by May 11, 2012.
by ICC Compliance Center 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:
Short circuit, and
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.
by Emily Walter on December 16, 2009 at 10:41 am · in Emily's Blog
Since lithium battery shipping is a hot topic these days, I ask this question a lot in my training classes. More often than not, the answer is a resounding "no". That’s when I respond with "Are you sure?" Upon further discussion, many people realize that they do, in fact, ship lithium batteries.
So how could they not know? When I get a response of "no" to the question, I start asking more questions. Do you ever ship pieces of equipment or machinery that is powered by lithium batteries? Do you ever ship cell phones or laptop computers to other offices or field locations? After a little bit of thought, the realization often occurs… Hey, we DO ship lithium batteries!
Many shippers overlook these types of shipments when asked about shipping lithium batteries. They tend to think only of individual batteries or products that they ship, instead of equipment or tools of the trade. In order to avoid causing and accident or receiving costly fines, make sure you know what you are shipping before you ship it so that you can comply with the appropriate regulations.