|February 2007 Newsletter
Upcoming Dangerous Goods Training Dates at JFK and on the web
All of the above live training classes will feature the new 2007 editions of the regulations.
U.S. and International Transportation Laws require that any employee who prepares hazardous materials for transportation or transports hazardous materials (dangerous goods) must be trained.
Yes, we will continue to provide the above services to our regular clients only.
In our December 2006 Newsletter we noted that Lithium Batteries continue to cause concern within the regulatory bodies, particularly the U.S. DOT/FAA. Of particular concern is the shipment of non-chargeable lithium batteries known as primary lithium batteries. There have been a number of incidents involving these batteries and despite industry efforts the issue continues to baffle some shippers and quite a few air carrier and forwarder personnel. Lithium batteries are by far the cause of most of our phone call and fax inquiries on a daily basis.
Shippers who are distributors. as opposed to manufacturers, and forwarders are almost always looking for those magic words: "not restricted" or "not regulated."
In the air regulations Special Provision A-45 is technically-oriented for the shipper so that he or she can determine whether the shipment is regulated or not. It deals with lithium or lithium ion content in (a) an individual cell, and (b) a lithium battery. A-45 further requires in (c) "that each cell or battery must be able to meet the requirements of the "UN Manual of Tests and Criteria" and in (d) there is a requirement to separate and pack the cells and batteries to prevent short circuits, and (e), provide additional requirements for marking; special procedures for damaged packages; be capable of withstanding a 1.2 metre drop test; and a gross weight limitation of 30 kgs.
The shipper or forwarder then must note on the air waybill that the shipment consists of "Lithium Batteries, Not Restricted per Special Provision A-45."
If the shipper does not have the correct technical information or a current and reliable MSDS the risk of shipping undeclared dangerous goods becomes a reality. For example, it is important to know positively whether the batteries are non-chargeable or re-chargeable. As a result of a number of incidents the non-chargeable batteries, also known as Primary Lithium Batteries, have been banned on passenger-carrying aircraft by the U.S. D.O.T.'s Pipeline and Hazardous Materials Safety Administration (PHMSA). Even if the batteries are not intended to be shipped by air, the boxes must be marked "PRIMARY LITHIUM BATTERIES - FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT." This requirement covers the situation where subsequent dealers/shippers will not accidentally ship the primary batteries on a passenger aircraft.
If you don’t think lithium batteries are dangerous, stop and consider all of the batteries that have been recalled by the manufacturers because of fires and explosions.
We get quite a few requests via our website and although we try to be as helpful as we can quite often the recipient gets his information and we never hear from him again. Not so with the following e-mail:
The above author was not your typical shipper, carrier or forwarder but a passenger wanting to do the right thing. He tried navigating government and carrier websites and was frustrated no end (you should have seen his other e-mails detailing his attempts to be a good citizen). Kevin patiently answered one e-mail after another in an effort to give guidance to the passenger. Oh, yes, it took time to be helpful.
As in any business, time is money. The above case was an amateur and safety was the primary consideration so we provided a free service to a person thousands of miles away.
Transportation Security Administration
The requirement for Security Threat Assessments for employees of aircraft operators, foreign air carriers, and indirect air carriers has been extended to March 15, 2007.
The requirement for Security Threat Assessments for agents of aircraft operators, foreign air carriers, and indirect air carriers has been extended to June 15, 2007.
The requirement for Security Threat Assessments for indirect air carrier proprietors, general partners, officers, directors, and certain owners has been extended to March 15, 2007.
Security Training for indirect air carrier employees who have unescorted access to cargo must have had the training completed by November 22, 2006 (no change in compliance date).
Security Training for indirect air carrier agents, contractors and subcontractors who have unescorted access to cargo has been extended to January 22, 2007.
If you are not current with the requirements go to http://www.tsa.gov/research/index.shtm. The "search" button is in the upper right corner. Type in "2004-19515" and the Docket should pop up. Click on "Reverse Order
Updating our August 2000 Newsletter regarding flammable liquids....
Misconception #1: the most frequent reply to the question "what is the meaning of flash point" is that it is the temperature at which a liquid will ignite or explode. WRONG!
FLASH POINT is the minimum temperature at which a liquid gives off ignitable vapors within a test vessel. The test vessel is either an open or a closed cup tester where the temperature of the liquid is strictly controlled. A device at the top of the cup sets off periodic sparks as the temperature of the liquid is increased. When the spark causes a "FLASH" you note the temperature of the liquid and you now have the "flash point", which should be in degrees Celsius. A closed cup test is the type of test required by the United Nations Orange Book and most regulatory agencies and is considered more reliable than an open cup test.
At least three, maybe more, bits of information about the properties of flammable liquids must be determined. BOILING POINT is vitally important. COMPATIBILITY with the primary receptacle containing the liquid, and the SPECIFIC GRAVITY of the liquid are also extremely important properties to be evaluated.
As the liquid boils it reacts similar to water boiling at 100°C. (212 °F) - it turns to steam.
For those of you who physically handle dangerous goods, when the drum of a flammable liquid is bulging on the top and the bottom you may have a very dangerous situation unfolding. Don't ignore it!
Think about the last time you needed gasoline for your lawnmower. If you ever put the gasoline in a plastic milk bottle you have experienced compatibility in packaging. Does the liquid "attack" the container or the gasket in the closure? Does the container start to soften or weaken and ultimately leak? Incompatibility leads to container failure and accidental release of the dangerous goods. In transportation that could lead to a catastrophe.
PACKING GROUP NUMBERS:
For Flammable Liquids, Class 3, the packing groups are based upon flash point and boiling point.