| 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
(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:
(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:
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
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.