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Regulatory Helpdesk: January 1, 2018

3 Questions from our Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Check back weekly, the helpdesk rarely hears the same question twice.

Location of the To/From Address

Q: Can the name and address of the shipper and/or receiver be on top of packages of hazardous materials?
A: For 49 CFR only 1 address is needed and for air you would need both. Ocean doesn’t specifically mention addresses but we tend to include one since most carriers are going to ask for it. None of the regulations actually state where they MUST go. In some of our older trainings it was indicated that the addresses had to be near the name and number. I’ve tried to correct that.

  • For Air – Section – both addresses “located on the same surface of the package near the proper shipping name mark, if the package dimensions are adequate
  • 49 CFR – Only one address is required per 172.301(d)
  • IMDG – There are no set guidelines for including addresses in Section 5.

New Segregation of Lithium Batteries

Q: Do lithium batteries have to be segregated?
A: It depends on the mode of transport.

In 49 CFR and IMDG 38-16, there are no segregation requirements for batteries. There could be information on a batteries SDS that should be followed.

For Air, in the new 59th edition of IATA or as some call it the 2018 version, there is some new information.  Table 9.3.A and Section now tell you that lithium batteries have segregation requirements.

The table indicates that packages of batteries labeled with the Class 9 hazard label must be segregated from Class 1 Explosives (other than 1.4S), Class 2.1 Flammable solids, Class 3 Flammable liquids, Division 4.1 Flammable solids and Division 5.1 Oxidizers. However, only those batteries that meet Section 1A or Section 1B of Packing Instruction 965 for Lithium-ion and 968 for Lithium metal batteries are considered for segregation. Also, per the NOTE these segregation requirements do not become mandatory until 1/1/19 even though operators should take steps to start implementing them as soon as possible.

Those meeting the Section II criteria of packing instructions 965 and 968 are not subject to segregation which makes sense given they do not bear the Class 9 label.

Placarding from the US to Canada

Q: If a customer is shipping from the US to Canada to one location they can use the US placard, but if they send it from one location to another in Canada then it needs the international placard. Is this still correct?
A: from the US directly to 1 location in Canada for use at that 1 location – yes, the US placard is fine. If from US to 1 location in Canada and that Canadian location then ships it to somewhere else in Canada then the TDG placard has to be used.
Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.

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