FedEx DROPS “V-PACK” REQUIREMENT

By October 26, 2018 September 12th, 2019 IATA and ICAO, Regulation Updates, Regulations

IATA DGR 2019 and FX-02

IATA SIGNIFICANT CHANGES

In keeping with the standard practice of alerting users to modifications in the new edition of the Dangerous Goods Regulations (DGR) for air transport, the list of Significant Changes and Amendments to the 60th Edition (2019) were released several months ago, and are incorporated into the recently published copies of the DGR.

An overview of these changes was the subject of blogs issued by ICC on August 28th and September 26th of this year.

Typically changes in the State and Operator Variations, in s. 2.8, are not outlined in specific detail in the Significant Changes document, but are referenced as a general reminder. This contrasts with amendments issued between publications which illustrate the actual details of changes.

Which leads us to FX-02…

FX-02 DROPS “V” RATED PACKAGING

A rather significant operator variation in s. 2.8.4 of the IATA DGR was the common application of FX-02 (f) to liquids in specified classes. This limitation, which existed as FX-17 prior to the 57th Ed., required shippers to use the heavy duty UN-standard “V-Pack” (“variation” commonly noted by UN code 4GV) package even though it wasn’t mandated by the Packing Instruction (PI) or other provisions of the DGR.

The limitation was invoked when FedEx customers were choosing to ship under the “International Economy” or “International Freight Economy” designations. Not only was it required in place of PI-required UN standardized packaging, but the V-rated package was also invoked for limited quantity (“Y”) PI that normally did not require UN standardized packaging.

The provision applied to liquids that belong to primary Class 3, 4.2, 5.1, 5.2 or 8.

There are approximately 129 PI that invoke FX-02, up to a third of which would probably have applied paragraph (f).

As you may have deduced at this point, the IATA DGR 60th Ed., effective January 1, 2019 no longer contains paragraph (f) in FX-02, nor is there a re-numbered equivalent section in the FedEx Variation section.

Similarly, FX-02(a) which (except for UN1230), required “V” rated packaging for international transport of PG I or II primary or subsidiary Class 6.1, has been edited. The 2019 version requires UN specification PG I level packaging under this limitation. So the packaging options for shippers will be increased starting January 1, 2019.

Clifton J. Brown

Clifton J. Brown

Clifton Brown has over 35 years of practical experience in the Canadian chemical and manufacturing industries. He has worked in research, quality, environment, health and safety in a range of industries including explosives, pesticides, manufacturing/contract packaging, pharmaceuticals, and specialty chemicals. This experience has provided a basis for dealing with a variety of regulatory approaches that have been useful in implementing and evaluating/auditing compliance. This experience has also been useful in effectively helping others to understand and apply the regulations in a North American context. Clifton represents ICC on the RDC regulatory and safe operations committees, participates in Transport Canada consultations and attends WSPS, CSSE and related activities.

One Comment