Aircraft Pilot Notification
Last month's newsletter reminded air carriers that the dangerous goods/hazardous materials pilot notification form must now include a 24 hour emergency phone contact for any dangerous goods loaded on board the aircraft. We would remind shippers and carriers that international access and area codes should be included with the phone number. U.S. "800" numbers can not be dialed from points outside of North America.
Shippers are also reminded that the 24 hour emergency number must be manned 24/7 by someone familiar with the chemical and capable of providing immediate assistance in the event of an in-flight incident. Answering services and answering machines do not comply with that requirement.Contrary to popular belief, shippers can not use Chemtrec or similar organizations' phone numbers unless they are bonafide members or clients of those organizations.
Air Carriers must maintain a copy of the pilot notification at their principal place of business or at the airport of departure for at least 90 days.
If the airport of departure is not the carrier's "principal place of business" (home base) the carrier must keep a copy of the pilot notification readily accessible until the flight arrives at the destination airport.
Hazardous Materials/Dangerous Goods Training
Check your training records now! We added two HAZMAT training classes for air shippers, forwarders and air carriers in April because our May and June classes were nearing capacity.
Upcoming Training Dates
- April 11-12-13, 2005 - Initial Air Transportation
- May 24, 2005 - Recurrent Air Transportation
- June 1, 2005 - Recurrent Ocean Transportation
- June 7-8-9, 2005 - Initial Air Transportation
Lithium Batteries reminder -
Excepted primary lithium battery shipments to and within the U.S. must be marked:
‘‘Primary Lithium batteries-Forbidden for transport aboard passenger aircraft’’
This regulation applies even if the shipment is not expected to move via air.
Passengers' Cigarette Lighters and Matches - reminder
On April 14, 2005, U.S. TSA will start enforcing a new security initiative banning all types of cigarette lighters carried by passengers on all flights operating under U.S. jurisdiction. TSA originally stated that these items could be packed in checked luggage. However, it should be pointed out that the U.S. FAA bans matches and cigarette lighters from checked luggage as a safety issue and has had that rule in effect for many years.
TSA also bans the sale of lighters in secure areas of airports (points beyond the screening areas).
Interesting note - There are some indications that some carriers are considering allowing silverware including knives to be used by passengers.
U.S. Department of Homeland Security -
On April 7, 2005 the DHS announced that it would recommend continuation of the placard system on railcars for alerting first responders about the presence of hazardous materials in tank cars and box cars.
U.S. Truckers -
Effective May 31, 2005 drivers who currently hold Hazmat Endorsements on their commercial driver's license and wish to renew or transfer the HME, must undergo a fingerprint-based background check. As drivers licenses come up for renewal they will have to be finger- printed and we would suggest that they should file for renewal as soon as they get the notice. Delays on renewals are expected.
My Soapbox -
http://hazmat.dot.gov/enforce/penalty/pen03.pdf - the link to DOT/PHMSA's
penalty actions for 2003.
We think it's interesting how many shippers of explosives and butane lighters were fined for failure to comply with the regulations. In most cases the shippers failed to comply with training and testing requirements for their employees.
In calendar year 2004 there were 6,462 incidents involving Flammable & Combustible Liquids, causing 51 injuries and 8 deaths and $33,963,422 in property damage. We submit that this is only the tip of the iceberg - we are reasonably sure that a vast number of smaller incidents go unreported. Those numbers reflect only U.S.A. statistics.
IATA Corrections -
IATA has issued a second addendum (Addendum II) and it is quite lengthy. You can download it at the following link: http://www.iata.org
At the top of the opening page click on "What We Do" and then on the left click on "Dangerous Goods."
When the DG Page comes up, scroll down the right hand side to "Downloads" and click on "More."
The Addenda II pops up on the next page.
If you missed Addendum I you can download it on the same page.
We tried giving you a direct link but it just doesn't work right. If you can follow the above directions, "Your a better man than I, Gunga Din!"
ICAO Corrections -
If you ship or carry Infectious Substances and Diagnostic Specimens by air the following addendum went into effect on 18 March 2005:
| INTERNATIONAL CIVIL AVIATION ORGANIZATION
TECHNICAL INSTRUCTIONS FOR THE SAFE TRANSPORT
OF DANGEROUS GOODS BY AIR
The attached pages should be added to the 2005-2006 Edition of the
Technical Instructions (Doc 9284).
- 1 - ADDENDUM
TECHNICAL INSTRUCTIONS FOR THE SAFE TRANSPORT
OF DANGEROUS GOODS BY AIR
In Part 2, Chapter 6, amend paragraph 18.104.22.168 to read:
22.214.171.124 Cultures are the result of a process by which pathogens are intentionally propagated. This
definition does not include human or animal patient specimens as defined in 126.96.36.199.
In Part 2, Chapter 6, add the following new paragraph 188.8.131.52 and renumber subsequent paragraph: 184.108.40.206 Patient specimens are human or animal materials, collected directly from humans or animals, including, but not limited to, excreta, secreta, blood and its components, tissue and tissue fluid swabs, and body parts being transported for purposes such as research, diagnosis, investigational activities, and disease treatment and prevention.
In Part 2, Chapter 6, paragraph 220.127.116.11, add “UN 3291”.
In Part 2, Chapter 6, amend paragraph 18.104.22.168.1 to read:
22.214.171.124.1 Category A: An infectious substance which is transported in a form that, when exposure to it occurs, is capable of causing permanent disability, life-threatening or fatal disease in otherwise healthy humans or animals. Indicative examples of substances that meet these criteria are given in Table 2-10.
In Part 2, Chapter 6, amend paragraph 126.96.36.199.2 and corresponding Note to read:
188.8.131.52.2 Category B: An infectious substance which does not meet the criteria for inclusion in
Infectious substances in Category B must be assigned to UN 3373.
Note.— The proper shipping name of UN 3373 is Diagnostic specimens or Clinical specimens or Biological substances, Category B. From 1 January 2007, the use of the shipping names Diagnostic specimens and Clinical specimens will no longer be permitted.
In Part 2, Chapter 6, amend paragraph 184.108.40.206 to read:
220.127.116.11 Dried blood spots, collected by applying a drop of blood onto absorbent material, or faecal occult blood screening tests and blood or blood components that have been collected for the purposes of transfusion or for the preparation of blood products to be used for transfusion or transplantation and any tissues or organs intended for use in transplantation are not subject to these Instructions.
In Part 2, Chapter 6, amend paragraph 18.104.22.168 to read:
22.214.171.124 Medical or clinical wastes containing Category A infectious substances must be assigned to UN 2814 or UN 2900 as appropriate. Medical or clinical wastes containing infectious substances in Category B must be assigned to UN 3291.
In Part 2, Chapter 6, Table 2-10, under UN 2814 delete “Hantaviruses causing hantavirus pulmonary syndrome” and insert “Hantavirus causing haemorrhagic fever with renal syndrome”.
In Part 2, Chapter 6, Table 2-10, under UN 2814 add “(cultures only)” after “Rabies virus”.
ADDENDUM - 2 -
In Part 2, Chapter 6, Table 2-10, under UN 2814 amend the first entry of “Rickettsia rickettsii (cultures only)” to read “Rickettsia prowazekii (cultures only)”.
In Part 2, Chapter 6, Table 2-10, under UN 2814 add “(cultures only)” after “Rift Valley fever virus”.
In Part 2, Chapter 6, Table 2-10, under UN 2814 add “(cultures only)” after “Venezuelan equine encephalitis virus”.
In Part 2, Chapter 6, Table 2-10, under UN 2900 delete “African horse sickness virus”.
In Part 2, Chapter 6, Table 2-10, under UN 2900 “Avian paramyxovirus Type 1 –” insert “Velogenic” before “Newcastle disease virus”.
In Part 2, Chapter 6, Table 2-10, under UN 2900 delete “Bluetongue virus”.
In Part 2, Chapter 6, Table 2-10, under UN 2900 add “(cultures only)” at the end of all entries.
In Part 3, Table 3-1, page 3-2-30, insert the following entry:
Biological substance, Category B, UN 3373, “6.2” in column 3, “None” in column 5, “See 650” in column 9 and “See 650” in column 11.
In Part 3, Table 3-1, page 3-2-57, “Clinical specimens”, delete “A141” in column 7.
In Part 3, Table 3-1, page 3-2-70, “Diagnostic specimens”, delete “A141” in column 7.
In Part 3, Chapter 3, Table 3-2, page 3-3-10, delete the entry for “A141”.
In Part 4, Chapter 8, page 4-8-23 amend, Packing Instruction 650, paragraph 4) as follows:
… 650 PACKING INSTRUCTION 650
This packing instruction applies to UN 3373.
4) For transport, the mark illustrated below must be displayed on the external surface of the outer packaging on a background of a contrasting colour and must be clearly visible and legible. The mark must be in the form of a square set at an angle of 45/ (diamond-shaped) with each side having a length of at least 50 mm, the width of the line must be at least 2 mm, and the letters and numbers must be at least 6 mm high. The proper shipping name “Diagnostic specimen” or ,“Clinical specimen" or “Biological substance, Category B” in letters at least 6 mm high must be marked on the outer package adjacent to the diamond-shaped mark.