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Upcoming Dangerous Goods Training Classes - 2012

(All Feature Lithium Batteries)
  • October 16, 2012 (Tuesday) – Warehouse Employees
  • November 13-14-15, 2012 (Tuesday-Wednesday-Thursday) – Ocean Initial
  • November 27, 2012 (Tuesday) – Air Recurrent
  • December 4-5-6, 2012 (Tuesday-Wednesday-Thursday) – Air Initial
  • Domestic Cosmetics and Perfume Shippers On-Line Program available 24/7 (Features Special Permit 9275)**

In-House Training subject to schedule availability.

Our 2013 schedule will be posted on this website in early December.

Check our website for the 2012 Schedule which is now available.

** This program has been updated to reflect changes in DOT Special Permit 9275 that went into effect on 1 September 2012. If your training certificate has expired or is nearing expiration and you use the permit you should take the course over once again.


Domestic U.S. D.O.T. Special Permits

We are repeating the changes that went into effect on September 1st 2012 and January 1st 2013. They will affect domestic shippers of cosmetics, flavorings, pharmaceuticals, and research laboratory chemicals in particular.

There are over 300 companies and individuals that are parties to the SP-9275 in particular. Most are major corporations but there are also a considerable number of small businesses that also utilize the special permit. A significant number of the products covered by the SP also qualify as consumer commodity, ORM-D.

Two very significant changes will affect these products.

  1. Effective 1 September 2012, shipments that qualify under Special Permit 9275 will require new markings on the outer packages. The packages must be marked DOT SP-9275, the name of the permit holder (you company name for example) and the description “contains ethyl alcohol”.
  2. Example:
    DOT SP-9275
  3. CONSUMER COMMODITY, ORM-D-AIR will cease to exist as a domestic PSN and Classification after 31 December, 2012. For Highway and rail shipments ORM-D will be phased out effective 1 January 2014.
  4. On 1 January 2014, products that would have previously been shipped as ORM-D should qualify as Limited Quantity and would require the new LTD QTY markings on the package that went into effect on 1-1-2012.
  5. PHMSA has indicated they are considering extending the effective date for highway and rail until January 1, 2015. Check future newsletters for more information.
  6. The Marking requirements:
    • LTD QTY by highway & rail: (effective 1-1-2014)
    • For limited quantities in classes/divisions 3, 4.1 (PG II & III), 5.1 (PG II & III), 5.2 (Types B-C-D-E-F that do not require temperature controls), 6.1 (PG II & III), 8 (PG II & III), and class 9 (PG II & III) by highway and rail there are no longer any shipping paper requirements unless the material meets the definition of a hazardous substance, hazardous waste, marine pollutant or is being shipped by vessel or air.
    • CAUTION: Very strict quantity limitations exist and combination packagings are always required so make sure you consult CFR 49, §173.150 through §173.156 before shipping those classes or divisions as limited quantities.
    • For shipments that qualify for air freight: (effective 1-1-12)
    • Air freight shipments will require the above “y” mark plus the hazard label(s). Check your IATA Regulations for more details.

Warehouse Training

We have added a warehouse employee training class for October 16. Six or more employees in the same class are eligible for a discount, We are in the process of notifying clients that we have had on our waiting list at this time. This will be the last program for the year so check your training records or your compliance standards. If the employee handles hazardous materials USDOT requires training. Contact our office now since we have only a limited number of openings for this class.

Reverse Logistics

Ever wonder about those hazardous materials that you returned to a retail store because it did not work right or was the wrong color or wrong size? Or playing the role of a good citizen, you returned used dangerous goods such as auto batteries, lithium and other types of batteries for recycling? Are those items segregated as required for safe storage at the retail outlet and are they packaged correctly for transportation back to the manufacturer?

U.S. DOT/PHMSA is considering adding a new section in 49CFR dealing with reverse logistics.

The Dangerous Goods Advisory Council has alerted us to the following issues that PHMSA is looking at in order to determine if regulations covering reverse logistics are in the public interest.

  1. What are the types of hazardous materials and quantities that are frequently returned?
  2. What is the volume of returns? Is there a ‘‘rule-of-thumb’’ metric—e.g., 10% of retail sales are returned?
    • What is the current volume returned by private citizens?
    • What is the current volume returned by other businesses?
    • What are the most widely-used methods of return (U.S. Mail, Walk-ins, Commercial Carriers, etc.)?
  3. Are returns directed to a disposal facility of the original manufacturer?
  4. Should returns be the responsibility of the manufacturer?
  5. To what extent should retail employees who package hazardous materials for shipments back to the distribution centers be subject to the training requirements in 49 CFR part 172, subpart H? Are retail employees currently being trained for the shipment of hazardous materials under 49 CFR part 172, subpart H?
  6. Are hazardous materials being properly segregated as required by § 177.843 of the HMR when being shipped from retail outlets to their distribution centers? How are they being segregated?
  7. Should certain hazard classes/divisions be excluded when considering regulations for ‘‘reverse logistics?’’ If so, why?
  8. Should PHMSA define specification packages for materials shipped under ‘‘reverse logistics’’? If so, why?
  9. Are shipping and distribution companies assuring the safety of their employees and the public when allowing drop-box hazardous material returns? If so, how?
  10. What precautions, if any, are these companies taking to avoid the mixing of hazardous materials and contamination of other packages that might contain hazardous materials and/or nonhazardous materials?
  11. What role(s) do 3rd party logistics providers play in the reverse logistics process, if any?

Lithium Batteries –

There are a few significant changes in IATA’s 2013 Dangerous Goods Reulations, particularly concerning lithium batteries. Our recurrent traing class on November 27 is filling up. This class as well as our initial training class in December will feature the 2013 Edition of the IATA Regulations.

DGAC – Dangerous Advisory Council

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