2015 International & Domestic Regulatory Changes

Report
2015 International &
Domestic Changes
1
 Changes for 2015
♦ Classifications
♦ Dangerous Goods Table
♦ Marking & Labeling
♦ Packing Instructions
♦ Special Provisions
Significant Changes for 2015
 Air Bag Modules
 Class 9 Label
 Environmentally Hazardous Materials
 First Aid Kits
 Consumer Products with Ethyl Alcohol
 Overpack & CAO Restrictions
 Paint & Paint Related Materials
 Removal of Packing Group for Articles
 Lithium Batteries
Index
 Air Bag Modules
The current proper shipping names for
UN3268 are changing from Air Bag Module, Air
Bag Inflator or Seat-belt Pretensioner to
Safety Devices, electronically initiated.
Reference: ALL Modes - Dangerous Goods
Table*
* Currently a proposed rule domestically.
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 Class 9 Miscellaneous
Dangerous Goods
“Old” Hazard Class 9 label: This is what a pre-7/20/2011 label looked like
(other than size). It has the horizontal line in the middle. Can be used for
DOMESTIC SHIPPING ONLY
Reference:172.446(c) & Letter of Interpretation Ref# 14-0165
Current Hazard Class 9 label: Under the new International standards, this is
how the appearance of the label is shown (other than size). It is shown
without the horizontal line in the 49 CFR.
Reference: Air - 7.3.18 Ocean - 5.2.2.2
Best practice would be to use the label without the line.
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 Environmentally Hazardous Materials
UN3077 & UN3082
Can ship as “not restricted” provided:
The net quantity of the inner packaging or single
packaging does not exceed 5L/5kg
References:
Air-SP197/Domestic–Proposed-171.4/Ocean– 2.10.2.7
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 First Aid Kits
 Packaging
Must meet PG II Performance
Standards
 Documentation
The PG assigned to the first aid kit as
a whole must be the most stringent PG
assigned to an individual substance
uless the kit contains only hazardous
materials, where no PG is assigned.
References:
Air – SPA144/Domestic_Proposed173.161/Ocean SP251
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 Exceptions for Consumer Products
Containing Ethyl Alcohol
 Alcoholic Beverages
- Not subject
to the regulations IF:
Contains less than 24% or less alcohol
Contained in inner packaging of 5L or less;
or
PG III alcoholic beverage contained in
packaging of 250L or less- (Domestic/Ocean)
References:
Air- A9/Domestic -173.150(1) & (2)/Ocean –
SP144 & 145
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 Exceptions for Consumer Products
Containing Ethyl Alcohol
 Perfumes - Not subject to the
regulations IF:
Glass inners
o Less than 8 oz capacity (liquids)/ ½
lbs (solids); or
o More than 8oz but less than
16oz(liquids)/more than ½ lbs but less
than 1lbs – package must have the
company name and “Contains Ethyl
Alcohol” marked on the package
Reference:
Domestic – 173.150(g)
Note: there are more exceptions, these are just a few
common ones.
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 Paint and Paint Related Materials
Paint
Proper Shipping name can be either
Paint Related
Materials
Or
Paint
Paint Related
This also applies to all
the different Paint, Paint
related materials and
Printing Ink PSN’s.
References:
Air – SP192/Domestic_Proposed –
SP347/Ocean – SP367
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 Overpacks & CAO Restrictions
The restrictions for overpacks
containing packages showing the
Cargo Aircraft Only label has been
deleted.
Reference:
Air – 5.0.1.5 has been deleted.
CAO OVERPACK
RESTRICTIONS
REMOVED
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 Removal of Packing Groups from
Articles
 The following dangerous good articles will have the
PG removed for consistency with other dangerous
goods articles
♦ UN3090 Lithium metal batteries
♦ UN3091 Lithium metal batteries contained in/packed with
♦ UN3480 Lithium ion batteries
♦ UN3481 Lithium ion batteries contained in/packed with
♦ UN3506 Mercury contained in manufactured articles
♦ UN3356 Oxygen generator, chemical
♦ UN3268 Safety devices, electrically initiated
♦ UN1700 Tear gas candles
References:
Air – 3.0.3.3/Domestic_Proposed – 172.101(f)/Ocean –
2.0.1.3
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 IMDG Dangerous Goods Table
 Stowage and Segregation
♦ Column 16 has been made into
two columns
 16a – Stowage & handling
 16b – Segregation
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 49 CFR Revised Regulations for
Shipping Lithium Batteries
 The 49 CFR regulations for lithium batteries are now
mirroring the International Regulations
 There are now revisions to both Domestic Ground
and Domestic Air as Special Provisions 188 and 189 no
longer exist
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 Small Lithium Battery Criteria
 Small battery exemptions – lithium metal
♦ 1g of lithium content for cells
♦ 2g of lithium content for batteries
 Small battery exemptions – lithium Ion
♦ 20Wh for cells
♦ 100Wh for batteries
Reference: 173.185(a)
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 Lithium Metal & Lithium Ion Batteries Packed with
 Domestic Ground
♦ All packages containing batteries packed with equipment must show the
battery handling label
♦ All packages containing batteries packed with equipment must include a
battery handling document
References: 173.185(c)(3)
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Lithium Metal Stand Alone Batteries
Domestic Ground
Less than 5kgs
weight
Yes
Needs label “LITHIUM METAL
BATTERIES-FORBIDDEN FOR
TRANSPORT ABOARD
PASSENGER AIRCRAFT” and the
battery handling label and document.
net
No
Must ship Fully Regulated
 You can use the exception for medium size batteries with a lithium content of 5g for cells
and 25g batteries provided the package is marked “LITHIUM BATTERIES FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL”
Reference: 173.185(c)(1)
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 Lithium Ion Stand Alone Batteries
Domestic Ground
Watt hours less than 20Wh
for cell or 100Wh for battery
No
Yes
Battery handling label with accompanying
battery handling document
Must ship Fully Regulated
 You can use the exception for medium size batteries with 60Wh
for a lithium ion cell and up to 300Wh for a lithium ion battery
provided the package is marked “LITHIUM BATTERIES FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND
VESSEL” along with the battery handling label.
Reference: 173.185(c)(1)
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 Lithium Metal Stand Alone
Batteries Domestic Air
Contents
Max number of
cells/batteries
per package
Max net
quantity (mass)
per package
Lithium metal cells and/or
batteries with a lithium
content not more than 0.3g
Lithium metal cells
with a lithium content
more than 0.3g but not
more than 1g
Lithium metal batteries
with a lithium content
more than 0.3g but not
more than 2g
No Limit
8 cells
2 batteries
2.5 kg
N/A
N/A
Reference: 173.185(c)(4)
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Lithium Ion Stand Alone Batteries
Domestic Air
Contents
Lithium ion cells and/or
batteries with a Watt-hour
rating not more than 2.7Wh
Lithium ion cells with
a Watt-hour rating
more than 2.7Wh but
not more than 20Wh
Max number of
cells/batteries
per package
No Limit
8 cells
2 batteries
2.5kg
N/A
N/A
Max net
quantity (mass)
per package
Lithium Ion batteries
with a Watt-hour
rating more than
2.7Wh but not more
than 100Wh
Reference: 173.185(c)(4)
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 Lithium Ion/Metal Contained in/
Packed with - Domestic Air


Limited to the number of batteries/cells needed to power the equipment,
plus 2 spares
Total net quantity of the lithium cells or batteries in the completed package
must not exceed 5kg
Reference: 173.185(c)(4)
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Lithium Ion & Metal Stand Alone
Batteries Domestic Air
 Any package that exceeds the number or net quantity
limit in the tables shown on the previous slides does not
have to use UN packaging, if they meet the weight
restrictions.
 The following is still required:
♦ Shipping paper
♦ Class 9 label
♦ Battery handling label
Reference: 173.185(c)(4)(v)
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Lithium Metal Stand Alone
Batteries International Air
 Per PI968 – Lithium metal batteries
cannot ship via passenger aircraft
domestically or internationally.
 All packages shipping under PI968
Section II must bear the CAO label in
addition to the battery handling label.
Reference: PI 968
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A look ahead
 Ocean - The lettering of the "SALVAGE"
marking shall be at least 12 mm high. This shall
apply as from 1 January 2016.
Reference: 5.2.1.3
 Air – A new provision mandating the lettering
on the marking “Overpack” be 12 mm high. This
shall apply as of 1 January 2016.
Reference: 7.1.7
And last but certainly not least……
 Domestic – The ORM-D marking will be no
longer be allowed after December 31, 2019.
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How Can DGM Help?
Container Stripping and Stuffing
Fulfilment Services
• Intermodal freight containers
• Outsourced pick and pack operations
• Road trailers
• Inventory control, reporting and security
Blocking and Bracing
• Intermodal freight containers
• DG and non-DG
Crating
• Export
• Build/tear down services
• Onsite crating
• ASTM compliance
Pre-transport Inspections
Compliance
+
Efficiency
• Following Checklists and
procedures of Carriers
Warehousing
• Storage
• Pick and Pack
Dry Ice Delivery and Re-icing
• Pharmaceutical and agricultural
• Envirotainer inspection and battery
change
Contact Information
• Sam Krouse, Executive Sales Consultant,
[email protected], 773-279-2380
• Tracie Cady, General Manager,
[email protected], 773-279-2237
• General Inquires [email protected]
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