The IATA Regulations define an overpack as an enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage. Dangerous goods packages contained in the overpack must be properly marked, labeled, and in proper condition as required by these Regulations.
So we get the concept of what an overpack is, but what happens when it comes to shipper’s declaration and marking/labeling.
One our clients recently ran into a situation involving overpacks. They prepared two pallets with 200 L size drums on it. There were three drums on one pallet and one single drum on one pallet. The drums were placed so that the marks/labels and the UN specification markings of each drum were facing out for inspection. Straps were used to secure the drums to the pallets. The straps were about 2 inches in width, so as far as the checklist sections on marks/labels on packages were concerned, it was all clearly visible. Well, guess what…it was rejected because the shipment wasn’t offered as an “overpack.”
I spoke to the airline representative on behalf of our client. His explanation was that anything coming on a pallet is called an overpack for this airline. He said it needs to be marked on the shipper’s declaration as an overpack. So then I asked what about marks and labels. Everything is visible on each drum, so how does that work? Where would the “overpack” markings go? I said we couldn’t put marks/labels on the straps. Even he was confused and agreed with me. He suggested adding a piece of paper to the pallet and adding the marks/label on the paper. I said then we might as well shrink wrap it and make it a proper overpack. However, as we were discussing, I said as per Section 184.108.40.206 it states “unless all the marks representative of all dangerous goods in the overpack are clearly visible, the overpack must be marked with….”. Technically, in this case, the pallets don’t need to be marked/labeled as an overpack but rather just stated on the declaration as an overpack. He agreed with me on that. But then something else struck me. It’s a multiple overpack situation with two pallets, so each overpack must show an identification mark per Section 220.127.116.11, so technically we still have to mark the overpacks. Back to square one for marks/labels. Frustrating!
I think the best solution for overpacks is to actually make it an overpack and cover it with shrink wrap or similar. It’s so much easier to just mark/label each overpack, and this way, it’s aligned with the shipper’s declaration too.
I gave our client this suggestion, and we agreed to disagree with the airline in this situation. But since this shipment has to go ASAP, they agreed to shrink wrap on top of the straps and mark/label and document as a multiple overpack shipment.
The Regulatory Experts at ICC Compliance Center are always here to help ICC customers with their shipments when these situations arise. Contact ICC at 1-888-977-4834 (Canada) or 1-888-442-9628 (U.S.), and ask for one of our Regulatory Experts.
We have all the products, services and training you need to ensure your staff is properly trained and informed.