Regulatory Helpdesk: October 29

By November 9, 2018 April 19th, 2021 Uncategorized, Regulatory Helpdesk, 49 CFR

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.


Q. We have a customer that is asking why the VOC content is “N/Av” on their SDS. It is required under OSHA or WHMIS?
A. According to US federal OSHA Hazcom 2012, and Canadian WHMIS 2015 rules, VOC information is not actually a mandatory item to appear in any section of a 16 Section SDS. It is commonly requested as a sub-item in Section 9, which is why ICC automatically includes the subheading. ICC does not calculate VOC levels, so the data would have to be provided by you. VOC information is common info to have for coatings, and has become important for coatings manufacturers due to Environmental regulations.

Lithium Battery Mark

Q. Customer called and asked if they ship UN3480 lithium batteries ground within the US, can they use the lithium battery mark instead of the class 9 lithium battery label, or do both have to be on the package. He also wanted to know what packing group lithium battery packaging had to be?
A. When shipping ground within the US, you are required to use a lithium battery mark OR a Class 9 lithium battery label. So just the lithium battery mark is fine in this case, as opposed to IATA where Section 1B Intermediate batteries require both. Per 173.185(b)(3)(ii) at least a packing group 2 (Y) rating is required for lithium battery packaging.


Q. Overpacks – IATA. If we place the hazard class label on top of the overpack, is this allowed? Would we still have to mark the word “overpack” on the outside?
A. The hazard class labels can be placed on the top of the overpack, as long as it remains visible and nothing obstructs the view of the labels. states that unless all marks representative of all dangerous goods in the overpack are clearly visible, the overpack must be marked with the word “overpack”. So in your case, because the marks on the overpack are clearly visible, this would not be a requirement.

Stacking Skids

Q.My carrier in the US says that we cannot double stack hazmat in the truck when we ship to the US. I have UN3077 and the product is in 25 kg UN specification bags. They are all put on a skid. I have 22 skids on the floor and the last 2 skids are stacked on top of the others.
A. Verified in the 49 CFR, with all of the regulatory team and nobody found anything in regards to this rule. We did find the double stack rule, but only seems to be applicable to IBCs and suggest that you contact the carrier for additional clarification.
Karrie Ishmael, CDGP

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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