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April 2002 Newsletter

News Archive
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This should have been the March Newsletter but, unfortunately, we had so many interruptions we never did finish it on time so we ended up just skipping the month of March altogether. We are still sorting through the comments generated by our February Newsletter but it looks like American companies prefer the three-year rule concerning recurrent training. The cost of training surely is a factor. Individual airline employees who commented favored a one or two year recurrent training requirement for U.S. shippers.


What's New?

ICAO has adopted a new symbol for packaging dangerous goods that are transported by air.

The symbol will verify that the shipper prepared the packagings specifically for airfreight. We are confident that our readers understand that there are special requirements for shipments by air, specifically concerning changes in pressurization and temperature, positive methods of closure, quantity limitations for inner packagings in combination packagings, the use of absorbent and cushioning materials, movement within the outer packaging, and the effects of vibration. The new symbol becomes mandatory on 1 January 2004. Voluntary compliance is authorized on 1 January 2003. Be on the alert for IATA to make it mandatory on 1 January 2003.

It is still unclear if the mark can be placed on a package in the form of a sticker or label. Permanent markings printed by the packaging manufacturer could cause problems since the same outer package might be used for highway, rail, and ocean.
The symbol looks like this:


In view of the interest in special packaging and markings for airfreight shipments by ICAO and IATA, it might be wise to review U.S. Domestic Hazardous Materials Regulations relating to Consumer Commodities. There are some misconceptions that should be addressed.

Consumer Commodity, ORM-D, in 49CFR 171.8, is defined as a material that is packaged and distributed in a form intended or suitable for sale through retail sales agencies or instrumentalities for consumption by individuals for purposes of personal care or household use. This term also includes drugs and medicines.

In the Hazardous Materials Table (172.101) the entry for "Consumer Commodity" shows the letter "D" in column (1) - the letter "D" designates proper shipping names which are appropriate for describing materials for domestic transportation but may be inappropriate for international transportation under the provisions of international regulations (e.g., IMO, ICAO).

In the HM Table the hazard class indicates "ORM-D" - a classification that does not exist in IMO, ICAO (or IATA). No UN or ID number has been assigned for this domestic proper sipping name and hazard class and packing group numbers do not apply.

Column (6) of the Hazmat table also indicates that there is no hazard label requirement for this material and column 7 indicates that no special provisions apply.

Columns (8A) and (8B) show identical packaging instructions for packaging exceptions and non-bulk packaging, i.e., 173.156 and 173.306.

Column (9A) provides a quantity limitation for passenger aircraft and passenger rail transportation column (9B) provides that quantity limitation for cargo aircraft only. For consumer commodity that limitation in (9A) and (9B) is the same: 30 kg. Gross mass (weight).

49CFR Subpart C - Shipping Papers - provides the requirements concerning documentation. However, 172.200 dealing with applicability of the requirements specifically states in (b)(3) that this subpart does not apply to ORM-D, except when the material is offered or intended for shipment by air. Therefore, for domestic highway, rail, and water shipments there are no documentation requirements.

Subpart D - Marking -
172.316 covers the marking requirements for materials classed as ORM-D.
(a) provides for the ORM-D to be placed within a rectangle "immediately following or below the proper shipping name" - remember? The proper shipping name from the Table 172.101 is "Consumer Commodity".

(a) (1) provides for the correct marking for an ORM-D that has been packaged for air in accordance with 173.27: ORM-D-AIR (within the rectangle). Example:

CONSUMER COMMODITY

 

(a)(2) indicates that the marking ORM-D is required for packages of ORM-D materials
that are not prepared for shipment by air. Example:

CONSUMER COMMODITY

When ORM-D material is shipped by air a number of problems come to mind. Distributors and forwarders automatically assume that the domestic U.S. version of consumer commodity is the same as the ICAO/IATA version of a consumer commodity. It is not!

First of all, refer to 172.316 (a) (2). It states if the consumer commodity is not prepared for shipment by air the simple ORM-D mark should be applied. Yet time and again shippers take that cargo, slap on a class 9 label, and re-mark the packagings as "Consumer Commodity, ID 8000". The packaging itself did not change, which means it was not prepared for shipment by air. Otherwise it would have been marked ORM-D-AIR.

Next, U.S. Regulations allow consumer commodities to include limited quantities of cartridges, small arms (UN 0012, 1.4S); aerosols - flammable, non-flammable, corrosive and toxic; flammable liquids, PG I, II, III; flammable solids in PG II and III; oxidizers in PG II and III; organic peroxides that do not require temperature controls; toxic substances in PG III; and corrosives in PG II and III. Depending on the hazard class and the packing group, inner containers are limited to .5 L. to 5.0 L. for liquids and 1 kg. to 5 kg. for solids.

The only provisions are that the products must meet the definition of a consumer commodity and there must be a packaging exception listed for the product in column 8(a) of the Hazmat Table, 172.101.

We would point out that cigarette lighters, 2.1, UN 1057, are not aerosols and they do not have a packaging exception, and they are expressly forbidden to be shipped as a consumer commodity.

The ICAO/IATA version of a consumer commodity is more restrictive. It limits consumer commodities to flammable and non-flammable aerosols (825 ml or less); flammable liquids, PG II and III only (500 ml or less), toxic substances in PG III only (liquids - 500 ml or less/solids - 500 g or less) and UN 3175 (500 g or less), with no subsidiary risks permitted. The gross mass limitation is 25 kgs.

Your HAZMAT quiz for April , 2002:
Just roll your mouse over the for the answer!

Provide the hazard class or division number and the hazard class or division name appropriate to the following descriptions:

  1. True or False
    A material must meet the regulatory requirements of a limited quantity and must be packaged for retail sale in order to be reclassified as a consumer commodity, ORM-D.

  2. True or False
    A "Consumer Commodity ORM-D Air" marking may be used for surface shipments of consumer commodities.

  3. 3. What is the Identification Number associated with an air shipment of Consumer Commodity materials?

    a. ID 8001
    b. UN 8000
    c. UN 8001
    d. ID 8000


  4. 4. True or False
    A Class 9 label must be used on packages containing Consumer Commodity materials being transported via truck.

  5. 5. True or False
    An ORM-D Air label can be substituted for a Class 9 package being shipped under the Consumer Commodity ID 8000 designation.

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