RAS Article

Happy New Year !!!

At least the world did not end on December 21st...

As we put this newsletter to bed, Congress did less than half the job on the U.S. Financial Crisis and we still have to worry about lithium batteries. So, what else is new?

Lithium Batteries

On December 23rd IATA issued a 17 page addendum to the 54th Edition of the IATA DGR which is effective 1 January 2013. You can download a copy from our website by clicking HERE.

Our Soap Box: Lithium Batteries

We rant and rave and preach about safety in transportation most of the time – this time it’s the economy, stupid (congress)

Wow! Talk about confusion over lithium batteries…

Bob Richard of Labelmaster has pointed out a few dumb moves by DOT/PHMSA regarding lithium batteries. (“Dumb” is your editor’s choice of words, not Bob’s).

Number one is that PHMSA is seeking comments on the 2013-2014 ICAO Technical Instructions that just went into effect. The Technical Instructions are automatically incorporated into the U.S. 49CFR and indeed, Congress has mandated that PHMSA and the FAA are forbidden to inaugurate any new initiatives that are stricter than the ICAO T/I. By “seeking comments” it opens the door for safety-conscious members of the public and corporations to comment on the impact of the T/I on safety and/or the cost of doing business among other possibilities. What happens if pilots and other safety minded citizens suggest stricter rules, particularly the NTSB recommendation for improving fire detection systems and fire-proof unit load devices on all cargo type aircraft? Nothing. Remember, congress forbids the FAA and PHMSA from enacting any stronger regulations than those that exist under the ICAO T/I. So, seeking comments is a waste of time and money.

Number two, PHMSA is considering the long-term impacts of permitting shippers and carriers to choose between compliance with the existing HMR, or compliance with the ICAO Technical Instructions 2013-2014 edition, when transporting batteries domestically by air. While we have been critical of the ICAO rules they certainly are better than the air regulations in 49CFR. By permitting shippers and carriers to choose which set of regulations they wish to use the result will surely be more confusion for transportation personnel and will compromise safety because of the many “loop holes” in 49CFR.

Number three, PHMSA is seeking supplemental comments to the January 11, 2010, Notice of Proposed Rulemaking (NPRM) and the April 11, 2012 notice that PHMSA is asking whether they should continue to allow domestic air exceptions for lithium batteries. Speaking of “loop holes”…..wow!

We should save money and confusion by firing the lawyers at PHMSA and replacing them with real experienced transportation people.

Another gripe:
Back in December 2011 we noted there were 261millionaires in the last Congress, out of a total of 535 members. The median wealth of a House member in 2009 stood at $765,010, while the median wealth for a senator in 2009 was nearly $2.38 million. No wonder we were facing the “fiscal cliff” with one of the main issues being higher taxes on wealthy Americans. And your congressional representatives are supposed to be looking after your interests?

About RAS

We provide corrective packaging for dangerous goods shipments at New York Area Airports and hazmat training courses either in house or on location.

Get in Touch

Our Address

  • R-A Specialists
    224 Buffalo Avenue
    Suite #1, Freeport, NY 11520
  • Map