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August 2007 Newsletter

U.S. D.O.T.
"Stop the presses!" as they used to scream when a newspaper had a hot story to print.

As we were about to have our Webmaster place our July Newsletter onto the website, DGAC alerted us that DOT/PHMSA published a proposed rule in the July 2nd Federal Register.

That and other business developments kept pushing the newsletter back further until we finally gave up and transformed it to an August Newsletter.

In HM-206F the Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing a significant change in how the 24-hour emergency phone contact will be identified on shipping papers (hazmat/dangerous goods documents).

PHMSA proposes to require the person who offers a hazardous material for transportation and who uses an emergency response service provider such as Chemtel, Chemtrec, Infotrac, or 3E Company, must be identified clearly by name or contract number on any subsequent shipping papers that use the service provider's emergency response number.

PHMSA also clarifies that when new documents are substituted or replace the original documents from the shipper, the original offeror (shipper) must be identified in relation to that emergency response number. If the shipper changes on subsequent documentation and provides its own phone number it must identify by name its own valid telephone number.

FOR FURTHER INFORMATION CONTACT: Joan McIntyre, Office of Hazardous
Materials Standards, telephone (202) 366-8553, Pipeline and Hazardous
Materials Safety Administration.

As July was drawing to a close and we were feeling very guilty about our failure to finish the July newsletter we received a call from one of our favorite freight forwarders requesting information about nickel cadmium batteries. These are the types of batteries that you might use in your flashlight or portable radio. We had explained that all batteries are forbidden in transportation unless they are packaged in such a way that they will not cause a short circuit or become damaged during transportation.

Next, we explained that nickel cadmium batteries, if packaged to prevent short circuits and damage, would be non-regulated (not restricted for you air shippers). See the entries for batteries in Appendix A of the IATA Dangerous Goods Regulations.
We then discussed the shipper's MSDS, which apparently left a lot to be desired.

At that precise time an FAA Inspector arrived on the scene as part of his routine visits to air freight forwarders and he joined the friendly conversation. A few days later, he sent us, and many, many others, an interesting link to FAA information about batteries and hoped that we would pass it on to as many shippers, carriers and forwarders as possible. Press here for the link!

There are four advisories dealing with batteries. One in particular deals with inadequate or inaccurate MSDSs and is well worth a little of your time if you ship batteries, or, for that matter, any potential dangerous goods.

Which leads us to a lengthy quest for 3 decent MSDSs that we recently encountered...

Check your training records!
Upcoming Dangerous Goods Training Dates at JFK and on the web

  • August 7, Dangerous Goods by Air - Recurrent Training
  • August 14-15-16, Dangerous Goods by Air - Initial Training
  • September 11, Hazmat Warehouse Training
  • September  18, Dangerous Goods by Ocean - Recurrent Training
  • Our new On Line Training Program for the Cosmetics Industry - available 24/7.

Our complete 2007 training schedule is posted on this website.

Check your current training records - if you are close to the expiration date make your reservations now for any of our classes throughout the year. We always remind attendees a few days prior to the class.

Material Safety Data Sheets (MSDS)
Nowadays, a single or two page MSDS just does not hack it. Time and again, though, that is all that is provided to us in the many faxes and e-mails that we receive daily.

A forwarder client recently sent us 3 MSDS, each one 2 pages, where the shipper failed to identify any of the ingredients and claimed that the chemicals were not hazardous.

No ingredients were indicated; no chemical properties were shown on the data sheets except for an "estimated" pH value; no flash points; the only instructions were to wear a face shield and rubber gloves.

The potential client/shipper wanted us to issue a letter to the carrier indicating that the three chemicals were not hazardous. After many e-mails back and forth with the shipper (it was like pulling teeth), this is the result . Still inadequate, yes. But at least the manufacture has started the learning process, we hope.

2 Drums:                       

Proper DOT. Shipping Name:  None
DOT Hazard Class  Mild Hazardous
U.N./N.A. Number  1778
Label Required  Corrosive
Hazard Class or division 8
Packing Group II

1 Drums:                       

Proper DOT. Shipping Name:  None
DOT Hazard Class  Mild Hazardous
U.N./N.A. Number  UN3415
Label Required  Poison
Hazard Class or division III
Packing Group 6.1


The deadline for Security Threat Assessment submissions for agents (sub-contractors) of indirect air carriers was July 15, 2007.

After the above date aircraft operators and indirect air carriers (air freight forwarders) may not allow unescorted access to air cargo for any individual unless the operator has submitted the information for that individual to TSA.

Every employee of R-A Specialists has successfully passed TSA's Security Threat Assessment and Training Program.

Dangerous Goods Advisory Council
29th Annual DGAC Conference and Hazardous Materials Transportation Exposition

November 14-16, 2007
La Fonda Hotel
Santa Fe, New Mexico

Join DGAC this November in the beautiful city of Santa Fe, New Mexico for the 29th Annual Conference and Hazardous Materials Transportation Exposition.

Check the DGAC Website for additional information at www.dgac.org


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