Neil McCulloch, Senior Manager, International Product Development, Labelmaster
Businesses need and want predictability, particularly when it comes to government regulations. So the fact that the International Civil Aviation Organization (ICAO) updates its Technical Instructions for the Safe Transport of Dangerous Goods every two years is both a blessing and a curse. A blessing because industry knows the changes that are coming and a curse because there are changes coming.
However, these are important safety requirements covering everything that’s transported by air from cargo in the hold of the airplane to the cell phones carried by passengers. With the recent concerns over certain types of phones and tablets, the 2017 update to the regulations has a direct impact on almost every business everywhere.
No one is more focused on airplane safety than the airlines themselves and their record on that score is amazing with millions of people flying daily in complete confidence. Through their global trade association IATA, the airlines develop their own procedures based on government regulations to ensure that aircraft are as safe as possible. So it’s not surprising that 2017 will see the 58th edition the IATA Dangerous Goods Regulations (DGR) published.
Based on the 2017 ICAO Technical Instructions, the IATA DGR manual gives detailed instructions on how airlines, passengers and cargo shippers should comply with the national and international regulations on dangerous goods in air transport. These are far more common than people think.
Every day about $18.6 billion worth of goods are transported by air. We take our laptop computers, cell phones, hair spray and even our duty free liquor for granted. But each of those has significant hazards if mishandled, poorly manufactured or simply in the wrong place at the wrong time. Consequently, ICAO, the airlines and the government have identified them as “dangerous goods” and places a number of restrictions on their carriage by air.
So, what has changed for 2017? And how will it affect your business?
Well, if you ship any kind of lithium battery powered device, these changes will affect you and your shipping operations. If you conduct any kind of dangerous goods training, ICAO is giving advance warning of changes to how training will be evaluated in the future and you would be advised to study these changes. If you ship aerosols, the so-called packing instructions for these have been changed. If you ship any type of machinery, the way these are described on the shipping papers is changed. And many other changes will affect such products as stabilized materials and even uranium hexafluoride.
In short, the 58th edition of the IATA DGR manual is a comprehensive update on the regulatory requirements for the carriage of many substances and articles and should be considered required reading by anyone responsible for transport compliance in your organization.
Here are some highlights of major changes:
- Specific airline requirements – users of both FedEx and UPS services should note these companies have extensively revised their airline “variations” and check with their service representative for full details of any changes, particularly with respect to lithium battery powered products. These are major changes and should not be underestimated.
- A new lithium battery handling label (more properly called a mark) has been adopted by all modes of transport to facilitate multi-modal operations. Designed for multi-language, multi-modal use, the label contains no wording.
- A new lithium battery hazard label has been adopted. Again a multi-modal initiate designed to make the transport chain more efficient, this label clearly identifies the miscellaneous hazard of lithium batteries by adding a pictogram to the existing class 9 label. It’s probably worth reiterating at this point that class 9 dangerous goods should and indeed must be considered just as hazardous as any other class, it’s simply that their hazards don’t fall neatly into the hazards 1 – 8, such is the case with lithium batteries.
- An interim change to the regulations prohibited lithium batteries from being carried as cargo on passenger aircraft. This is now fully reflected in all sections of the regulations. Some airlines even have further restrictions and have amended their “operator variations.” While the DGR contains the latest list of these variations, they can change at any time. Shippers are well advised to contact their airline for any addition requirements which might have been imposed.
- The DGR requirement for the shipping paper, known as the Shippers Declaration of Dangerous Goods or “DGD,” must be signed and the title and place of signing included with that signature. The requirement for Title and Place has been deleted.
- Some new special provision numbers must now be shown on the DGD indicating to the airline that the shipper is aware of these and that those provisions have been correctly applied.
- The classification for UF6 has changed, reflecting the toxic nature of that substance.
Note, a number of these provisions are grand-fathered, meaning that that the prior requirements are still permissible.
Year after year, no transport mode sees more Dangerous Goods regulatory changes than air transport. That’s why it’s essential to have a complete grasp of each year’s changes as soon as possible.
Neil McCulloch is senior manager, International Product Development for Labelmaster, which provides dangerous goods and product regulatory support to customers worldwide. He has vast experience and knowledge of hazardous materials regulations through his extensive network of dangerous goods professionals. McCulloch may be reached via email at nmcculloch@labelmaster.com. More information on shipping DG compliantly is available at www.labelmaster.com or by calling 800.621.5808.
