Upcoming Dangerous Goods Training Classes - 2011
(All Feature Lithium Batteries)
- Dangerous Goods by Air - Recurrent Training: August 16
- Dangerous Goods by Air - Initial Training: August 23-24-25
- Domestic Cosmetics and Perfume Shippers On-Line Program available 24/7 (Features Special Permit 9275)
- In-House Training subject to schedule availability.
- * The Dangerous Goods by Air programs will feature the 2011 IATA Regulations.
- ** The Dangerous Goods by Ocean programs will feature the new Amendment 35
- Check our website for the 2011 Schedule which is now available.
We have been frustrated thousands of times over the last 35+ years trying to get good Material Safety Data sheets from shippers.
A considerable number of manufacturers, their distributors, and their clients still used MSDSs dated 10 or 20 years ago. The format
as well as critical information has changed over the years which prompts us to point out the following information.
From MSDS On Line: Do Your MSDSs Measure Up to Global Regulatory Requirements?
During OSHA’s recent Web chat on its Semiannual Regulatory Agenda, the Agency announced that the Hazard Communication Standard
(HCS) would be set to align with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) this September.
For chemical manufacturers, this means you may need to re-author your MSDSs and labels to conform to the prescribed GHS format requirements once GHS is adopted.
Manufacturers and shippers can get more information at:
Lithium Batteries – another accident?
Just as we were ready to send off this newsletter to Tom, our webmaster, we received a number of e-mails concerning another aircraft accident.
The Asiana Airlines cargo plane crashed off the southern coast of South Korea on Thursday, July 28, after reporting a fire in its cargo compartments.
The Boeing 747-400F took off from the Incheon airport west of Seoul at 3:05 a.m. on Thursday, bound for Pudong, China.
It was carrying 58 tons of electronic and machine parts, including lithium batteries.
There is no definitive cause of the fire at this time but we noticed how quickly those having professional interests in airline safety were quick to sense that
there might be a relationship between a cargo compartment fire and the presence of lithium batteries. Yes, we also thought the same thing…..
Our Soap Box
We rant and rave and preach about safety in transportation most of the time.
Washington – we have a problem!
UN numbers 0323, 0366, 0441, 0445, 0455, 0456, 0460, and 0500
If you ship fire extinguisher actuating charges (UN 0323, Cartridges, Power Device, 1.4S) used on all commercial
aircraft you may be shipping them in violation of ICAO, IATA, and U.S.D.O.T.
UN 0323 cartridges are also used as door actuating release devices – used to release the aircraft emergency exit doors
if passengers must evacuate the aircraft in an emergency. If you are shipping or transporting these cartridges to, from or
through the U.S. you are not likely to be in compliance either.
The 2010 ICAO & IATA Regulations issued a new Special Provision for the above UN numbers.
In 2011 IATA Special Provision A165 changed slightly –
USG-05 requires all explosives other than small arms ammunition to have a U.S. Approval prior to shipping.
On October 21, 2009, DOT/PHMSA Issued HM-215K proposing adoption of UN Test Series 6(d) for certain explosives previously
classified as 1.4S. This proposed rule was intended to maintain harmonization with the United Nations and ICAO.
On January 19, 2011, DOT/PHMSA issued an 83 page final rule under HM-215K, which included an almost hidden requirement for the
6(d) test to be mandatory effective July 1, 2011 for shipment by air and January 1, 2012 for shipments by ocean. The rule is effective
January 1, 2014 for U.S. Domestic Highway and Rail.
Without the testing the cartridges would have to be reassigned, probably to 1.4C or 1.3C, and a new Competent Authority Approval
would be necessary in order to ship replacement cartridges on a passenger-carrying aircraft.
We are mostly concerned with UN 0323 - Cartridges, Power Device, 1.4S – used primarily by the aircraft manufacturers and airlines for
initiating fire extinguishers in the aircraft. The fire extinguishers are mounted in the aircraft baggage compartments and engine nacelles
and other critical parts of all aircraft. At the slightest indication of smoke or fire the extinguishers are activated by the flight crew.
The discharge is accomplished by a small actuating explosive cartridge. If a fire occurs it is critical for the aircraft to land Within 15 minutes.
Sometimes the alarm is false. Never-the-less the flight crew will activate the system. “Better safe than sorry” is thankfully the correct procedure.
Ultimately the fire bottles will have to be recharged with a new extinguishing agent and a replacement actuating cartridge must be installed.
The fire extinguishing systems are a “no go” item, meaning the aircraft is not permitted to depart on a flight if the system is inactive. .
The problem? The manufacturers have not completed the new test procedures and new U.S. Approvals have not been issued. Since the old approvals
are no longer valid the cartridges cannot be shipped by air.
If an aircraft on ground (AOG) situation exists the carrier cannot transport the cartridges to wherever the aircraft is located and
the a/c must remain out of service due to no fire extinguishing system.
If the carrier cannot legally transport the replacements how does the carrier get that aircraft flying again?
U.S.D.O.T./PHMSA estimates approximately six weeks to arrange and complete the tests. No tests – no approvals. Our business is
safety and we have no quarrel with the need for the tests. We do think that PHMSA should have worked out some procedure to allow the cartridges to be transported by air.
The manufacturers are dragging their tails to accomplish the costly tests based upon the PHMSA’s mandatory compliance date for shipments
by domestic highway and rail (2014). Meanwhile they are selling the product to airlines and forwarding the old approvals which are no longer valid for shipment by air.
It appears that almost everyone has closed their eyes to the problem.
Since the “old” approvals had no expiration date how would the average airline acceptance agent know that the approval was no longer valid?
To our knowledge there have been no incidents or accidents caused by these cartridges. A simple temporary fix could be to take
all of the old 1.4S approvals and reissue them as 1.4C or 1.3C explosives so that the cartridges can at least be shipped on an all cargo type aircraft.
In 2010 those cartridges that were classified as 1.4S without the 6(d) test were allowed to be shipped as cargo aircraft only.
While PHMSA appears to be unaware of the problem, why is no one at PHMSA wondering how these explosive charges are managing to get to
their destinations around the world?
U.S. made aircraft and U.S. jobs are at stake. Let’s solve the problem instead of hiding from the reality that it does exist.