|December 2010 Newsletter
Note Changes - Upcoming Dangerous Goods Training Classes - 2010 (All Feature Lithium Batteries)
In-House Training subject to schedule availability.
The Ocean Training dates have been changed based upon the availability of the new regulations.
Check our website for the 2011 Schedule which is now available.
24 Hour Emergency Phone Contact
Effective 1 October 2010 U.S. D.O.T./PHMSA required that shippers must identify the person or organization providing the 24 hour emergency phone contact and the contract number if an outside agency such as Chemtrec or Chemtel or Infotrac is being used as the emergency number.
While most domestic U.S. shippers consistently use a “800” telephone number, if the shipment is to be exported that 800 number can’t be dialed from overseas. Therefore, for exports, shipper must show the international access codes, i.e., country code, city or area code, and the local exchange telephone number. Some countries and carriers require the “+” sign before the country code – we suggest using the + sign before the country code in all cases since the “+” sign indicates that the caller should be using his or her own code to dial an international call.
There is another issue related to this emergency phone contact – the shipper must provide the emergency responder with current information for the dangerous goods. There may be potential problems in this area if the shipper does not provide the emergency responder with a current MSDS.
Other hot issues are U.S. Hazmat Registration and Hazmat Security Awareness.
Not Bill Maher’s new rules….
With 2011 just weeks away the 2011 IATA Regulations require extensive research and updating by shippers, especially the ones that utilize computer-generated dangerous goods declarations. New packing instruction numbers have replaced most of the P/I’s used in the 2010 Edition and earlier versions of the Regulations. A few sections have been changed or deleted. A new marking is required for Limited Quantities that will also affect ID 8000 Consumer Commodities.
A very important new Operator Variation by FedEx, FX-18, will require a self editing version of a computer-generated dangerous goods declaration as FedEx leads the way with Electronic Data Interchange (EDI) which is acceptable to ICAO/IATA and U.S. D.O.T.
The 2010 IMDG Code Amendment 35 is finally being distributed. We will be commenting on the more significant changes in coming issues. Amendment 34 (2008) may continue to be used until 31 December 2011 and Amendment 35 becomes mandatory on 1 January 2012.
Amendment 35 is authorized for voluntary compliance effective 1 January 2011. There are important changes in the Limited Quantity provisions including a new mark for LTD QTY and the deletion of the exceptions for personal care and household use packages. The new mark is also required on the ocean containers when only limited quantities are packed in the container.
Both sets of regulations are working towards a Global Harmonization System that is acceptable to all modes of transportation on a world-wide basis.
Lithium Batteries -- we’re still waiting, and waiting, and waiting….
We are still waiting for the U.S. proposed changes. Stay tuned. The White House Office of Management and Budget (OMB) is still reviewing the proposed regulation. OMB can accept the rule, reject the rule, or send it back to DOT/PHMSA for additional work or changes.
Keep checking our website for the updates. This will have an effect on both imports and expports.
Our soap box:
We rant and rave and preach about safety in transportation most of the time.
Two months we invited our website visitors to submit their gripes or rants.
One of our airline cargo agent readers complained about the failure of lithium battery shippers to update their training programs to reflect the changes over the past three years. She pointed out the requirement in each of the six packing instructions that states “Any person preparing or offering cells or batteries for transport must receive adequate instruction on these requirements commensurate with their responsibilities.”
We certainly do agree with her timely complaint. From conversations that we have had with FAA Security Agents, they too have placed significant additional attention on shipments of lithium batteries and related training requirements.
Interestingly, as November was coming to a close we were asked by a freight forwarder to give an opinion on a lithium metal battery shipment by ocean. The MSDS was dated 16 December 2003 – a two page document that did not address transportation regulations. The issue was the IMDG Code Special Provision 957 which allows batteries manufactured before 1 January 2003 that have not been tested to U.N. Standards could continue to be shipped until 31 December 2013. The shipper’s argument was that since the design and chemistry of the batteries has not changed the manufacture date was immaterial and he could ship the batteries as “not regulated” based upon the MSDS that was dated in 2003. We pointed out that the date of manufacture was indeed important and that the manufacturer should test his batteries if they were manufactured after 1 January 2003. We also suggested that the manufacturer should update the MSDS to the current ISO standards for Material Safety Data Sheets. We also suggested that he contact DOT/PHMSA’s hot line for guidance.
The shipper pulled the shipment and gave it to another forwarder who did not raise any questions about the batteries.
Send your Soapbox Rant to firstname.lastname@example.org.
We might have to edit them a little but we will remain true to your real frustrations.
Visit our website often in order to check on the U.S. D.O.T. changes regarding lithium batteries.