Regulatory Helpdesk: November 27, 2017

Top 4 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

Lithium Battery Special Provision

Q. Why is only a reference to Packing Instruction Section IB required on a lithium battery Shipper’s Declaration – what about shipments made under Section I or IA?

A. Sections I and IA refer to fully regulated shipments so it’s redundant to indicate an authorization unless there’s a special provision deviation involved.

Although Section II shipments don’t require a Shipper’s Declaration document, if an airwaybill is used a notation must be made indicating the Section II status like “Lithium ion batteries in compliance with Section II of PI— CAO”.

This is particularly true for UN3090 or UN3480 where the document is required to indicate the CAO status.

Shippers also need to verify any listed state or operator variations that may require information over that mandate by IATA DGR.

Determining the Size of the Package

Q. I have a customer who wants a “portable tank” of product instead of our usual smaller sized containers, can I oblige?

A:

• Characterize your product,
• read the container supplier’s specification,
• read the relevant regulation,
• read the cited container standard; review 1. & 2. in the context of 3. & 4; decide on any required modifications.

Shipping Soda

Q. A customer called and said he had someone on the phone whose son wants to ship a can of root beer to his brother who is studying abroad. The can would go by air. Is it hazardous or anything?

A.  Generally this would fall under the compressed gas rules of hazard class 2.2. However, the US ground regulations have an exemption in 173.307 for carbonated beverages and IATA has one as well in §3.2.2.4.2.

The Carrier is not Always Correct

Q. An airline referred a client who works for a counter-top company to call us because he wanted to ship a pump with this airline and the airline said it was dangerous goods.

A. Does the pump have any type of fuel/liquid that run through it or any type of pressure vessels attached to it or explosive gadget? “No,” said the customer. It’s just a regular pump with nothing in it. It is non-DG and he should inform the airline that there isn’t anything in the pump, even residue.