|March 2007 Newsletter
Yes, we will continue to provide the above services to our regular clients only. We also provide instructions on reading a MSDS in our training programs.
We do not collect cookies so we have no idea who visits our website or what information they may collect. We do, however, collect information on what articles in our newsletters attract the most attention via website searches. Next to inquiries about training, the subject of lithium batteries generates the most searches. This information pretty much mirrors the telephone and fax and e-mail inquiries that we mentioned in last month's newsletter.
From time to time we climb up on our soapbox to do a little preaching. Since lithium batteries are a potential risk of fire or explosion, perhaps the time has come when the regulatory agencies should seriously consider eliminating the Special Provision A-45 for air and Special Provision 188 for ocean. We hear so much about "risk assessment" for security purposes, maybe we should apply that same logic to lithium batteries and simply do away with any prospects of confusion and non-compliance whether it be by misinterpretation or intent.
Did you know that your ordinary dry alkaline batteries used to power you flashlight or radio are forbidden in transportation unless the batteries are protected against short circuits and damage?
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).
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Security Training for indirect air carrier agents, contractors and subcontractors who have unescorted access to cargo has been extended to June 15, 2007. This is a corrected date. We indicated January 22, 2007 in error in our February Newsletter.
If you are not current with the requirements go to http://dms.dot.gov/search/searchResultsSimple.cfm
Type 19515 and the Docket should pop up. Click on "Reverse Order to see the latest comments and the interim final rule.
Special note to truckers and warehouse subcontractors for the forwarding industry - this affects your company and employees and your ability to perform work for the forwarders.
U.N. Specifications Packages
Are your packages capable of surviving the Performance-Oriented Packaging tests required by the U.S. D.O.T. and the United Nations? During a recent evening, an airline
We pointed out that under 49CFR 173.3 (a) that U.N. Specification Packaging Test reports must be made available to an authorized employee of the initial carrier and the Department (of Transportation).
IATA Rule 126.96.36.199.5 has a similar requirement. The IMDG Code covers the requirement in 188.8.131.52.8.
She asked the shipper - he couldn't provide the documents - shipment refused!
Shippers or their packers should maintain copies of the tests so that they can provide them immediately to the carrier or an enforcement officer.
Toxic Substances 6.1 (Liquids & Solids)
Effective January 1, 2007, the oral LD-50 upper limit for both liquids and solids is now the same: ≤300 mg/kg.
If you ship "borderline" toxic solids, note that the oral LD-50 value increased from 200 mg. to 300 mg. That may now make some of your products fall into Division 6.1, PG III
If you ship toxic liquids that have an LD-50 above 300 mg/kg your product is no longer regulated unless it also meets the definition of another hazard class.
Hope to see you at the DGAC's 7th International Dangerous Goods Conference 6-7 March 2007 in Prague, Czech Republic.
Happy St. Patrick's Day to all of our Irish colleagues - see you at the NYC Parade on March 17. I'll be marching with the Power Memorial Academy Alumni Association and enjoying a great post parade party!