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September 2009 Newsletter

Have you checked your training records lately?
Upcoming Dangerous Goods Training Dates at JFK and on the web (All Feature Lithium Batteries)

  • Warehouse Employees & Truckers September 15
  • Dangerous Goods by Ocean – Recurrent September 22
  • Importers & Brokers October 13
  • Dangerous Goods by Air – Recurrent November 24
  • Dangerous Goods by Air – Initial December 8-9-10
  • Dangerous Goods by Ocean – Initial November 17-18-19
  • Domestic Cosmetics Shippers On-Line Program available 24/7
  • In-House Training subject to schedule availability.

All of the above programs place emphasis on Lithium Battery Safety in transportation.

Our complete 2009 training schedule is posted on this website.

Click on TRAINING on our opening page in order to reserve your place now. Remember, if you ship, handle, or transport dangerous goods, U.S. Transportation Law as well as International Laws you must receive initial training and then recurrent training every two or three years thereafter, depending on the mode of transportation.


Lithium Batteries

Again? Yes.

What we see……

Confusion, frustration and non-compliance still exists in all modes of transportation.

Although the U.S. has not yet fully adopted the United Nations system of identifying Lithium Batteries, on August 25th DOT’s Pipeline and Hazardous Materials Safety Administration issued a notice of approval that it will authorize use of the UN identification numbers and Proper Shipping Names presently used by all modes of transportation world-wide:

  • UN 3480, LITHIUM ION BATTERIES
  • UN 3481 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT
  • UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT
  • UN 3090 LITHIUM METAL BATTERIES
  • UN3091 LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT
  • UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT

Because the U.S. was slow to adopt the new identifications it has caused confusion and frustration since January 2009. Additional rulemaking is expected from PHMSA before the end of the year and that should bring domestic U.S. shipments into total harmonization with the international standards.

On August 20, 2009, the U.S. Air Line Pilots Association (ALPA) sent a letter to the Pipeline and Hazardous Materials Safety Administration requesting that all lithium battery shipments should be completely regulated and all relaxation of regulations should be terminated. The most recent incidents cited by ALPA include –

Lithium Batteries (continued)

ALPA noted similarities to a February 2006 accident in Philadelphia, Pennsylvania on a DC-8 aircraft and the National Transportation Safety Board recommended that all lithium batteries should be fully regulated. ALPA also noted that there have been 26 incidents reported by the FAA since the above noted accident.

In May of this year the NTSB and D.O.T. were questioned at length about lithium batteries during a congressional hearing on the Reauthorization Bill for PHMSA. NTSB emphasized its position concerning totally regulated batteries.

On December 17, 2007 NTSB recommended elimination of regulatory exemptions for lithium batteries. The 2009 Editions of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air and the IATA Dangerous Goods Regulations issued new regulations that attempted to satisfy everyone’s concerns but they both continued to allow for some relaxations for the lithium batteries. They emphasized that persons that prepare or transport lithium batteries must be thoroughly instructed in their assigned duties. While the airlines have pretty much complied with that rule many shippers and forwarders and contract warehouse operators apparently have not done so. And that is a prime problem.

Since we train hazmat employees we see the confusion that is prevalent for both shippers and transportation personnel. People get lost in the maze of regulations and have difficulty in determining when the batteries are regulated and when they are not (in their minds). At the slightest hint at the possibility that the batteries may be “non-regulated” they instinctively choose “non-regulation” and feel that the batteries must be harmless so no special packaging, marking, labeling or documentation are necessary. That perception is not accurate, and extremely unsafe.

With that frame of mind being so prominent it is only a matter of time before another incident occurs.

Prior to January 2009, the air regulations had a Special Provision outlining when lithium batteries could be shipped as “not restricted”. That provision was eliminated when the 2009 air regulations went into effect. But an overwhelming number of shipping and transporting personnel have not been brought up to date.

We have preached about lithium batteries in 27 newsletters since 2001. Yes, we think ALPA is correct in wanting to do away with all relaxations concerning lithium batteries. All lithium batteries should be fully regulated! But...


Our soap box:

Airlines should do away with all dangerous goods fees. That would go a long way towards eliminating that almost passionate desire to declare lithium batteries as “not regulated”….and other dangerous goods too.

Check this link…. http://www.dgac.org/conferences/index.shtml

 


DGAC
Dangerous Goods Advisory Council

For over thirty years the DGAC has been a leader in promoting safety in transportation. The council has been an advocate for the chemical industry and transporters of dangerous goods/hazardous materials. Your company should seriously consider becoming a member of this outstanding organization.

Mark your calendar:
31st Annual Conference & Hazardous Materials Transportation Exposition
November 18-20, 2009,
Grand Hyatt San Antonio,
600 East Market Street,
San Antonio, TX 78205

Check out DGAC’s website for details – www.dgac.org

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