The latest International Maritime Dangerous Goods (IMDG) Code, Volumes 1 & 2 April 2017 SPRAY 29 • Emergency response telephone number • Emergency response information • Training requirements • Security requirements • Reporting of incidents and accidents • Registration • and, for export, general packaging requirements, and the requirements for the reuse, reconditioning or remanufacture of packaging All shipments offered for transportation or transported in the U.S. under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations or the IAEA Regulations must conform to the requirements of 49 CFR 171.23, including conditions and requirements for: • Aerosols • Cylinders • Safety devices (e.g., air bag modules, seat-belt pre-tensioners, air bag inflators) • Chemical oxygen generators • Class 1 (explosive) materials • Hazardous substances • Hazardous wastes • Marine pollutants • Organic peroxides • Materials classified as Toxic-Inhalation Hazard • Class 7 (radioactive) materials • Self-reactive materials In addition, 49 CFR 171.24 outlines additional conditions and limitations on the transport of specific hazardous materials including: • Non-spillable wet electric storage batteries • Lithium metal cells and batteries; • Compressed oxygen; and • Other oxidizing substances For those companies that offer for transportation or transport aerosols in the U.S., it is important to note that 49 CFR §171.23(b)(1) states that: Except for a limited quantity of a compressed gas in a container of not more than 4 fluid ounces capacity meeting the requirements in §173.306(a)(1) of this subchapter, the proper shipping name “Aerosol,” UN1950, may be used only for a non-refillable receptacle containing a gas compressed, liquefied, or dissolved under pressure the sole purpose of which is to expel a nonpoisonous (other than Division 6.1, Packing Group III material) liquid, paste or powder and fitted with a self-closing release device. What this means is that substances such as refrigerant gases (e.g., R-134a2b) and dusters may not be classified as “aerosols” and assigned to UN1950 if the volumetric capacity exceeds 4 fluid ounces, unless they have a special permit to do so. This is significantly different than the IATA DGR and IMDG Code, which define “aerosols” as “non-refillable receptacles containing a gas compressed, liquefied or dissolved under pressure the sole purpose of which is to expel a nonpoisonous (other than Division 6.1, Packing Group III material) liquid, paste, powder or itself.” Similar conditions and limitations for the transport of dangerous goods by sea to, from or within the U.S., using the IMDG Code, are found in 49 CFR §171.25. IATA Dangerous Goods Regulations Although not formally recognized by DOT, the use of the IATA Dangerous Goods Regulations for the transport of dangerous goods by air would be consistent with the use of the ICAO technical instructions, provided the State (IATA DGR section 2.8.1) and Operator (IATA DGR section 2.8.2) variations are complied with, and the conditions and limitations for the use of the ICAO Technical Instructions found in 49 CFR §§171.22, 171.23 and 171.24 are also complied with. For shipments to, from or within the U.S., you must consult the applicable IATA DGR State Variations for the U.S. (USG) that includes restrictions and requirements for: • Compliance with 49 CFR subchapter C Hazardous Materials Regulations (USG-01) • Forbidden & restricted materials (USG-02/03) • Prototype lithium batteries & cells (USG-03) • Hazardous substances & hazardous wastes (USG-04) • Class 1 (explosive) materials (USG-05) • Aerosol cans & cylinders (USG-06) • Lighters (USG-07) • Class 7 (radioactive) materials (USG-10) • Non-spillable batteries (USG-11) • Emergency Response Telephone Number & Emergency Response Information (USG-12) • Compliance with 49 CFR Part 175 (USG-13) • Oxygen, compressed (including medical-use) (USG-15) • Safety devices (USG-16) • Security requirements (USG-17); and • Oxygen, certain oxidizing substances & chemical oxygen generators (USG-18) Most IATA member airlines and associate members require compliance with the IATA DGR as a matter of business Therefore, shippers are strongly encouraged to follow the IATA Dangerous Goods Regulations to ensure that the shipments will be carried by the airline, but are reminded to also consult the applicable state and operator variations, and to comply with the applicable terms and conditions for the use of the ICAO Technical Instructions within the U.S. whenever offering or transporting dangerous goods by air. Likewise, shipments prepared for ocean transport to or from the U.S. by vessel must conform to the IMDG Code as well as the terms and conditions for the use of the IMDG Code within the U.S. For shipments to or from Canada, there is a reciprocity agreement that will permit the use of Canada’s TDGR within the U.S., subject to the terms and conditions found in 49 CFR §171.23. For questions regarding the transport of dangerous goods using the international transport standards and regulations, contact the DOT PHMSA at +1 (800) 467-4922 or the author at steve@shipmate.com or +1 (310) 370-3600. SPRAY 1 49 United States Code §§ 5101–5127 2 Klyza, Christopher McGrory, Industry Hazards - Transporting Hazardous Materials International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air goods found Although gerous would provided DGR and 49 plicable restrictions Most and compliance DGR policy. strongly the Regulations shipments the to state and cable the Instructions whenever ing by conditions to use tions international PHMSA or 1 2
SprayApril 2017
To see the actual publication please follow the link above