|December 2006 Newsletter
Upcoming Dangerous Goods Training Dates at JFK and the web
All of the above training classes will feature the new 2007 editions of the regulations.
U.S. and International Transportation Laws require that any employee who prepares hazardous materials for transportation or transports hazardous materials (dangerous goods) must be trained.
Our complete 2007 training schedule has been posted on the website.
Perfumes, colognes and cosmetics.
We have developed a low-cost on line training program exclusively for the cosmetics industry. It addresses such issues as materials of trade (sales reps carrying product in their automobiles); consumer commodity, ORM-D by highway; storage, handling and safety for sales representatives operating out of a home office and distribution personnel; and DOT-SP-9275 which requires that hazmat employees utilizing the special permit (formerly called an exemption) must be trained. We even cover D.O.T. HAZMAT security awareness - a scaled down version for the cosmetics industry. It is also a good primer for U.S. exporters of cosmetics. The advantages -
Transportation Security Administration
On October 25, 2006 TSA amended the compliance dates for TSA-2004-19515 - the Air Cargo Security Requirements that were originally published on May 26, 2006.
If you are a little confused by all of the requirements, it would be wise to review the meaning of some of the terms used in the rule.
TSA-2004-19515 requires a security threat assessment and training programs be completed for employees and agents (subcontractors) who have unescorted access to cargo.
It covers the following employees -
The requirement for Security Threat Assessments for employees of aircraft operators, foreign air carriers, and indirect air carriers has been extended to March 15, 2007.
The requirement for Security Threat Assessments for agents of aircraft operators, foreign air carriers, and indirect air carriers has been extended to June 15, 2007.
The requirement for Security Threat Assessments for indirect air carrier proprietors, general partners, officers, directors, and certain owners has been extended to March 15, 2007.
Security Training for indirect air carrier employees who have unescorted access to cargo must have had the training completed by November 22, 2006 (no change in compliance date).
Security Training for indirect air carrier agents, contractors and subcontractors who have unescorted access to cargo has been extended to January 22, 2007.
If you are not current with the requirements go to http://www.tsa.gov/research/index.shtm. The "search" button is in the upper right corner. Type in "2004-19515" and the Docket should pop up. Click on "Reverse Order
Air Shipments - Lithium Batteries:
Lithium batteries continue to be a major concern in aviation. At the DGAC Annual Conference in Washington last month the FAA gave a presentation that was very educational. We will add some new information about lithium and lithium ion batteries in our next newsletter. Also, check back soon - we will try to put the FAA presentation on our website. Meanwhile, if you ship lithium batteries you might want to take the time to do a search of this website. We have provided extensive information about the batteries in earlier newsletters.
Reminder - primary lithium batteries (non-rechargeable batteries) being shipped under special provision A-45 as "not restricted" are forbidden to be loaded on passenger aircraft into, out of, or through the United States. Refer to USG-02 in the ICAO, IATA, and Labelmaster's A.I.R. Regulations.
Importers of lithium batteries should notify their overseas shippers about that restriction.
Ocean Shipments & Documentation
Reminder: Amendment 33-06 is effective as of 1 January 2007 on a voluntary basis and is mandatory on 1 January 2008.
We continue to get phone calls, faxes, and e-mails raising questions about a so-called IMDG requirement to indicate the quantities of inner packagings one the IMDG dangerous goods declaration or dock receipt or bill of lading. NVOs in particular continue to make this a requirement when no such requirement exists in the Code. When we have discussed the requirement with NVO personnel they are unable to cite a rule dictating that this information is required. Indeed, in most cases, the NVO doesn't even have a copy of the IMDG Code in order to calmly discuss the regulations.
The problem really becomes a major issue when the NVO dictates where he or she wants the information on the paperwork - usually disrupting the required sequence of UN Number, Proper Shipping Name, Class and Packing Group Number. In effect, if you followed their requirements you are violating domestic and international regulations.
A few weeks ago, during an ocean hazmat training class that we conducted, we opened up a "can of worms" when we covered the documentation requirements. The biggest complaint that we heard from shippers and ocean forwarders was that there is no one at the ocean carrier that they can contact via phone to verify the requirements. Limited Quantities clearly generated the most interest..
FYI: Limited quantities do not require a hazard label but they do require a special marking (the UN Number inside of a diamond-shaped outline ... except for personal care or household use items, which do not require that special marking. If only Ltd. Qty. are loaded into a container a Limited Quantity mark is required on all four sides of the container in a fashion similar to the placarding requirements.
Ltd. Qty. packages are limited to a gross mass of 30 kgs.
Segregation rules apply to different hazard classes loaded within the packages but do not apply to different packages (of different classes) or to packages of Ltd. Qty. and packages of other dangerous goods (meaning non-limited quantity packages).
The documentation provides the carriers and emergency personnel with information necessary to help those personnel perform their jobs efficiently. Safe loading and stowage aboard the vessel as well as proper weight and balance is vitally important. Don't cause confusion by adding unnecessary and confusing information. Just provide the basic information and everyone will be grateful.
Our colleagues at Maersk Lines did a great job of explaining documentation requirements on their website at
Maersk has done a commendable job to educate the shipper, broker, forwarder, and NVO on the documentation requirements. Please cut & paste this link. Pass it on to those who think they know the rules but really do not. Perhaps it will save you hours of futile discussion.
IATA changes in 2007
IATA's website has posted a heads up on the changes that will go into effect on January 1, 2007.Click here.
One of the more significant changes deals with a new PSN and UN Number:
There have been a number of revisions to the Special Provisions as well as some new ones that are very important.
If you ship aerosols there are new specifications dealing with plastic aerosol packagings as well as new information in the packing instructions.
Labelmaster (www.labelmaster.com) has also come out with their 2nd edition of A.I.R. SHIPPER for 2007.
Stay safe through this holiday season and throughout the New Year.
Merry Christmas/Happy Kwanza/Happy Hanukkah!