|November 2010 Newsletter
Note Changes - Upcoming Dangerous Goods Training Classes - 2010 (All Feature Lithium Batteries)
In-House Training subject to schedule availability.
The Ocean Training dates have been changed based upon the availability of the new regulations.
Check our website for the 2011 Schedule which will be posted soon.
24 Hour Emergency Phone Contact
Effective 1 October 2010 U.S. D.O.T./PHMSA required that shippers must identify the person or organization providing the 24 hour emergency phone contact and the contract number if an outside agency such as Chemtrec or Chemtel or Infotrac is being used as the emergency number.
While most domestic U.S. shippers consistently use a “800” telephone number, if the shipment is to be exported that 800 number can’t be dialed from overseas. Therefore, for exports, shipper must show the international access codes, i.e., country code, city or area code, and the local exchange telephone number. Some countries and carriers require the “+” sign before the country code – we suggest using the + sign before the country code in all cases since the “+” sign indicates that the caller should be using his or her own code to dial an international call.
There is another issue related to this emergency phone contact – the shipper must provide the emergency responder with current information for the dangerous goods. There may be potential problems in this area if the shipper does not provide the emergency responder with a current MSDS.
Other hot issues are U.S. Hazmat Registration and Hazmat Security Awareness.
We are still waiting for the other shoe to drop as far as U.S. proposed changes are concerned. Stay tuned. The White House Office of Management and Budget (OMB) is still reviewing the proposed regulation. OMB can accept the rule, reject the rule, or send it back to DOT/PHMSA for additional work or changes.
Keep checking our website for the updates. This will have an effect on both imports and expports.
Our soap box:
We rant and rave and preach about safety in transportation most of the time.
Last month we invited our website visitors to submit their gripes or rants.
The first one that we received dealt with USG Variation 04 in the ICAO/IATA regulations, particularly, where do you place the letters RQ on the air dangerous goods declaration? Various DG employees at carriers operating in the U.S.A. have rejected shipments based upon the individual employee’s personal interpretation of USG-04 (b) 3.
We went to our local FAA for some guidance. This does make sense.
(b) 3 stipulates the letters RQ (Reportable Quantity) identifier should be placed before the UN or ID Number or after the Packing Group number (if a packing group number applies to that particular proper shipping name). The actual wording in (b) 3 is “the letters “RQ” shall be entered on the Shipper’s Declaration either before or after the basic description and in association with the proper shipping name required to be marked on the package.”
Examples: RQ UN 2809, Mercury, 8, III …or… UN 2809, Mercury, 8, III RQ
The rant was not based upon the compliance issues but where various airline employees differed with the shipper based upon the airline employee’s personal preference. In IATA’s column form DG Declaration it is suggested that the “RQ” should be placed immediately above the UN # because of space limitations in the column. The other option: under the PG number in the Packing Group Column.
Reminder - The basic description is: UN or ID Number, Proper Shipping Name (and technical information, when required), Hazard Class and Sub Risk(s) if applicable, and the Packing Group Number, if applicable.
The second gripe that we received really was pretty hot & frustrated so we will eliminate the preamble to the question. It came from a freight forwarder.
“DG Acceptance Checklists - does it really vary from airline to airlines? why? we had an issue last week with "liquid DGs". Continental Airlines rejected it because it specifies "Single Packaging is not allowed" (point 32 on their checklist). In checking with BA this is not specified on theirs. It makes no sense to me why two of the majors would differ. I have attached two both the BA and CO checklists.”
We do not share the forwarder’s gripe against the airline. All the forwarder needed to do to prevent the double or quadruple handling was to check the Operator Variations listed in IATA Section 2.9.4. CO-03 provides that “for liquid dangerous goods single packaging is not allowed.”
Of course, it would have been better if CO had listed that particular variation was listed in all of the packing instructions covering PG III liquids acceptable on passenger aircraft. Never-the-less, it is the shipper’s or forwarder’s responsibility to check to see if their choice of carriers has any variations that would affect their shipments.
Send your Soapbox rant to email@example.com.
We might have to edit them a little but we will remain true to your real frustrations.