|August 2007 Newsletter
As we were about to have our Webmaster place our July Newsletter onto the website, DGAC alerted us that DOT/PHMSA published a proposed rule in the July 2nd Federal Register.
That and other business developments kept pushing the newsletter back further until we finally gave up and transformed it to an August Newsletter.
In HM-206F the Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing a significant change in how the 24-hour emergency phone contact will be identified on shipping papers (hazmat/dangerous goods documents).
PHMSA proposes to require the person who offers a hazardous material for transportation and who uses an emergency response service provider such as Chemtel, Chemtrec, Infotrac, or 3E Company, must be identified clearly by name or contract number on any subsequent shipping papers that use the service provider's emergency response number.
PHMSA also clarifies that when new documents are substituted or replace the original documents from the shipper, the original offeror (shipper) must be identified in relation to that emergency response number. If the shipper changes on subsequent documentation and provides its own phone number it must identify by name its own valid telephone number.
FOR FURTHER INFORMATION CONTACT: Joan McIntyre, Office of Hazardous
Next, we explained that nickel cadmium batteries, if packaged to prevent short circuits and damage, would be non-regulated (not restricted for you air shippers). See the entries for batteries in Appendix A of the IATA Dangerous Goods Regulations.
There are four advisories dealing with batteries. One in particular deals with inadequate or inaccurate MSDSs and is well worth a little of your time if you ship batteries, or, for that matter, any potential dangerous goods.
Which leads us to a lengthy quest for 3 decent MSDSs that we recently encountered...
Material Safety Data Sheets (MSDS)
A forwarder client recently sent us 3 MSDS, each one 2 pages, where the shipper failed to identify any of the ingredients and claimed that the chemicals were not hazardous.
No ingredients were indicated; no chemical properties were shown on the data sheets except for an "estimated" pH value; no flash points; the only instructions were to wear a face shield and rubber gloves.
The potential client/shipper wanted us to issue a letter to the carrier indicating that the three chemicals were not hazardous. After many e-mails back and forth with the shipper (it was like pulling teeth), this is the result . Still inadequate, yes. But at least the manufacture has started the learning process, we hope.
The deadline for Security Threat Assessment submissions for agents (sub-contractors) of indirect air carriers was July 15, 2007.
After the above date aircraft operators and indirect air carriers (air freight forwarders) may not allow unescorted access to air cargo for any individual unless the operator has submitted the information for that individual to TSA.
Every employee of R-A Specialists has successfully passed TSA's Security Threat Assessment and Training Program.
Dangerous Goods Advisory Council
November 14-16, 2007
Join DGAC this November in the beautiful city of Santa Fe, New Mexico for the 29th Annual Conference and Hazardous Materials Transportation Exposition.
Check the DGAC Website for additional information at www.dgac.org