2014 IATA Updates

By:  Arthur Mahoney, M.S., CHMM

January 2, 2014

IATA Dangerous Goods Updates in 2014

2014 has brought about some important changes to the IATA Dangerous Goods regulations (DGR) which may impact how you ship dangerous goods* by air.  I have summarized some of the changes below. Consult the 55th edition of the DGR for actual regulations.
DGR Changes in 2014:

 
Here are some changes in the 2014 DGR that may impact you.

 

Applicability

  • 1.4-Operator Responsibilities. A recommended practice for how operators should provide information to the pilot-in-command for certain items of dangerous goods permitted in passenger and crew baggage has been inserted in 1.4.2.
  • 1.5-Training Requirements.  Table 1.5.A and 1.5.B has been modified to clarify "category" of staff, rather than "key". Category 10 has also been modified to include flight operations officers/flight dispatchers who require specific information in accordance with 9.5.1.1.1 as of 1 January 2014 and therefore require dangerous goods training.

Limitations

  • 2.3-Dangerous Goods Carried by Passengers or Crew.  A clarification from ICAO on portable electronic devices, including medical devices containing lithium batteries has been made. Medical devices using the higher limits are not permitted in checked-baggage. 

Classification

  • 3.3.3.1-Clarification on the requirements that apply for viscous flammable liquids that are assigned to Packing Group III in accordance with the provisions of 3.3.3.1.

Identification

  • 4.2-List of Dangerous Goods.  New entries have been added to the list of dangerous goods which are currently assigned UN numbers, but had not previously appeared in the air transport Regulations for completeness. In the absence of provisions for transport by air, these "new" entries are all forbidden for transport by air.
  • 4.4-Special Provisions.  Special provisions A4 and A5 have been modified to mandate their inclusion on the Shipper's Declaration when items are transported in accordance with those provisions. 
  • A806-applicable to Batteries, nickel metal hydride has been added to clarify that the UN Number UN3496 is only applicable for sea transport. This UN number has been added to the list of dangerous goods for completeness as indicated above.

Packing Instructions

  • The packing instructions for lithium batteries 965-970, have been revised to remove duplicate content to clarify the applicable provisions.
  • PI 965 and PI968-The documentation provisions for lithium ion and lithium metal batteries in Section IB of PI 965 and PI 968 have been revised to mandate the use of a Shipper's Declaration. To assist shippers there is a three-month transition period until 31 March 2014, during which time the information required may still be provided on an air waybill.

Marking and Labeling

  • 7.1.5.5- Clarification that packages prepared in accordance with the limited quantity provisions in surface transport and bearing the surface limited quantity mark, are acceptable for air transport provided that the packages are in full compliance with the marking and labelling requirements for air transport.
  • 7.2.4.7.1- Clarification on the dimensions applicable to the lithium battery handling label, including the dimensions of the reduced size lithium battery handling label.
  • 7.1.7-The provisions for overpack markings have been moved to follow the more logical package marking workflow.

Documentation

  • The documentation requirements have been modified to reflect the new requirement for Section IB lithium batteries to use a Shipper's Declaration for Dangerous Goods.
  • 8.1.6.9.2- Clarification that alternative spelling is acceptable for other than proper shipping names has been added.
  • 8.1.P- A new example of a completed Shipper's Declaration for lithium ion batteries shipped in compliance with Section IB of Packing Instruction 965.  


 

 
Training Reminder and Services

Training Requirements
 
Who Must be Trained: Have you asked yourself this question? Very often, companies will only train and certify Shipping and Receiving personnel and forget about other employees who have a role in their company's dangerous goods shipping process. 

 

A common situation that puts companies out of compliance and at risk occurs when employees (e.g., lab personnel) without the proper training and certification package or even partially package a dangerous good.  The DOT has made it clear that employees who even "partially" assemble a dangerous goods package must be properly trained and certified.  This means that even employees who place sealed primary containers (e.g., a bottle of a regulated dangerous good) in an outer shipping box, which they provide to Shipping and Receiving personnel to inspect, close, and mark and label, are themselves required to be trained and certified.  

 

As a reminder, per 49 CFR and HM-223**, all employees who affect hazardous materials/dangerous goods* transportation safety must be properly trained and certified.  This includes employees who:

  • Determine a material's hazard class(es);
  • Select the packaging;
  • Fill and close a packaging;
  • Mark and label a package;
  • Prepare or review shipping papers and emergency response information;
  • As an importer of hazardous materials/dangerous goods*, provide the shipper with shipping requirements that will apply to the transportation of the material within the United States;
  • Certify that a hazardous material/dangerous good* is in proper condition for transportation;
  • Load, block, and brace a hazardous material/dangerous good* package in a freight container or transport vehicle;
  • Segregate a hazardous materials package in a freight container or transport vehicle from incompatible cargo.
  • Select, provide, or affix placards for a freight container or transport vehicle to indicate that it contains a hazardous material/dangerous good*.
How Often is Training Required:
Initial training is required within 90 days of the job function.  Retraining is required with 24 months (air) and 36 months (highway) of initial training.  Additionally, employees must be retrained when there are changes in the regulations which impact them.
 
What is the Required Content of the Training:
 
  • General familiarization training
  • Function-specific training
  • Safety training
  • Security awareness training
 
Testing and Certification:
Employees must be tested and certified.  But the testing can (and should) be customized to the functions of the employee.  It has been my experience that the most effective training includes the actual packaging materials, shipping software, etc that your employees use. 
 

Our Training Solution
 
Focused on What You Ship:
Save money and time and improve compliance by making the training applicable to your employees.  Employees do not need to attend a 2 or 3 day offsite training course which may spend much of the time on irrelevant topics and completely miss the ones that your employees really need to know well.  The program I offer can often be completed in a single 1-day session (or several 3-4 hour sessions) at your facility.  In addition, the testing and certification can also be customized to the specific job functions and even include applicable practical exercises using the actual packaging, software, etc that your employees use.     

 

Added Value: Find and Fix Problems

Ultimately companies should be focused on compliance.  And a valuable outcome of onsite training is discovering and fixing problems in shipping programs during the training.  

 

Added Value: Your Very Own Shipping Guidelines:
Included in the training can be shipping guidelines/checklists customized to the types of materials you commonly ship.  These can also include procedures and forms for carriers that you use (e.g., FedEx, World Courier, UPS, DHL).  

 
More Added Value: Packaging Solution Consultation:
Working with a number of packaging vendors over the years, I can assist your organization in developing customized packaging solutions.

 
An Easy Way to Comply
 
Contact me and I would be happy to provide you a quotation for dangerous goods/hazardous materials training program.
 
What makes my program especially valuable is that it is specific to the dangerous goods/hazardous materials that you ship and it is presented by me, an expert in the field.

 Other commonly requested services include:
  • Onsite EHS support and services on an as-needed basis
  • Regulatory compliance
  • Chemical safety audits
  • Safety training, both in person and hosted web-based
  • Onsite and special project support
  • HMBP and chemical inventory services (including uploads to CERS)
  • Hazardous waste auditing, minimization and reporting
  • Bloodborne Pathogens (annual requirement)
  • Hazard Communication 
  • Chemical Hygiene Plan 
  • Laser Safety
  • Biological Safety 
  • Radiation Safety
  • Shop Safety
  • Many others, please contact me
 
artServed by an Expert  Arthur Mahoney, Principal Consultant
MS, CHMM

 
For 20 years, he has been assisting public and private companies to comply with safety, hazardous material management, transportation and safety concerns. He also provides chemical inventory database services.
 
Feel free to contact us at 650-347-0417 or by email
 
 
Sincerely,
 

Arthur Mahoney
Hazard Solutions LLC
 
*Dangerous goods includes articles or substances which may be hazardous (in air transport).  The definition of dangerous goods is found in the Dangerous Goods Regulations, published by the International Air Transport Association (IATA) .  Dangerous goods are synonymous to hazardous materials, which is the term used to describe hazardous substances in 49 CFR. 
 
**HM-223 clarifies the many pre-transportation functions which necessitate training.
 
Disclaimer:  The information presented above should not be construed in any way as legal advice or an interpretation of regulations.  It is meant to provide basic information about topics that may affect clients and colleagues.
 

 

 
 
 
 
 

 

 
Home | Training | Services | Onsite EHS Services | Chemical Storage & Risk Management Assistance
Database Solutions | Resources | About | Contact