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Every day, thousands of personal care and household products such as nail lacquers, certain medicines and aerosols or perfumes are shipped by air transport. However, do we bear in mind that they can be required to be declared as dangerous goods?

 

Consumer Commodities air transport

According to IATA DGR 55th Edition, Appendix A, a consumer commodity is defined as “a material which is packed and distributed in a form intended or suitable for retail sales for the purposes of personal care or household use (see special provision A112 for classes and divisions permitted under this definition)”.

To get a better insight about how to ship consumer commodities, read and learn from the following article -written by DGM New York- about how to meet compliance requirements in accordance with air transport regulations

The article provides the guidelines needed to prepare consumer  commodities shipments   to be in compliance with international air transport requirements such as:

  • Identification of consumer commodities
  • Their classification under ID 8000
  • Packaging requirements
  • Marking and labelling requirements
  • Information required to be provided in the Dangerous Goods Declaration (DGD)

For further details or assistance, please do not hesitate to contact us. DGM will ensure your shipments are fully compliant with regulations.

DGM has received a 20 year Strategic Partner award from the International Air Transport Association (IATA) for the period 1994-2014.

The Strategic Partnerships Program is a platform for aviation solution providers to build as well as strengthen relationships with key industry stakeholders. Through their participation in various IATA work groups, Strategic Partners gain a unique insight into airlines’ priorities and have the opportunity to be recognized for working together with IATA in serving the air transport industry.

Starting in 1990 with nine founding members, the Strategic Partnerships Program (SP) DGM Support Strategic Partner 20yearshas grown into a community of more than 350 partners worldwide, sharing ideas and supporting the initiatives and initiatives of IATA.

Through its contributions over the years, DGM has been recognised as an influential member in the cargo standards area of involvement,  participating in IATA’s Dangerous Goods Board and supplying a wide range of dangerous goods services and products such as: operations, consultancy or software.

Besides DGM being IATA Strategic Partner, DGM companies are IATA Accredited Training Schools or Accredited Training Centers. Furthermore, all DGM companies are IATA Sales Agents.

DGM is pleased to continue supporting the development, implementation and promotion of standards in the aviation industry.

 

Everyday thousands of overpacks containing dangerous goods are offered for all modes of transport. However, are they shipped in compliance with dangerous goods regulations?

This article intends to provide some helpful guidelines to ship overpacks containing dangerous goods in accordance with dangerous goods regulation requirements.

Overpack concept and definition

A common question asked by those involved in dangerous goods shipments is the following:  is an overpack a package? What are the main differences between them?

An overpack, as defined in the IATA Dangerous Goods Regulations is an enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage.

On the other hand, a package is defined as: the complete product of the packing operation consisting of the packaging and contents prepared for transport.

Marking and labelling requirements for overpacks

Overpacks shall be marked and labelled in accordance with dangerous goods regulations provisions. Generally, an overpack shall reproduce the markings and labels appearing on the package(s) inside the overpack, unless all markings and labels representative of all dangerous goods contained in the overpack are clearly visible.

If the dimensions of the overpack require it, labels and markings shall be reproduced in two opposing sides of the overpack.

Depending on the applicable transport regulation (such as: IMO-IMDG Code, ICAO- IATA-DGR ADR or 49-CFR), the required markings and labels can include UN number(s), Proper Shipping Name(s), Orientation Arrows, limited quantities marking, hazard labels (primary and subsidiary if they are required) for each dangerous goods package contained in the overpack and any additional handling information/markings appearing on the package (s).
overpack marking

In addition to the information mentioned above and an indication of compliance, an overpack shall be marked with the word “overpack” unless markings and labels representative of all dangerous goods contained in the overpack are visible.

 

Overpacks & Safety

Dangerous goods overpacked shall ensure safety requirements. The attached list shows some positive reasons to ship dangerous goods overpacked:

  • Facilitate identification of the dangerous goods overpacked
  • Protect the package from damage
  • Avoid any leakage from the package

However, it is important to ensure that safety practices are implemented with the aim to minimize potential risks and injuries such as:

  • Incompatibilities in the storage of dangerous goods  
  • Product damage related to handling operations (for instance: stabbing which can result from having the forks extended too far out from a load or from the practice of pushing a pallet using the forks )

Bear in mind that a safe warehouse environment and proper handling practices can be the key to success.

DGM can assist you in preparing your dangerous goods overpacks shipments in accordance with dangerous goods regulations requirements. For any question, please don’t hesitate to contact us.

 According to transport regulations, dangerous goods must be assigned to one of the Proper Shipping Names shown in Dangerous Goods List of the applicable transport regulations such as ADR, ICAO-IATA DGR, IMO-IMDG Code, RID or 49 CFR.  

Selecting the Proper Shipping Name (well known by the abbreviation PSN) is a key step to ensure that the dangerous goods offered for transport accurately represents its hazards. It is the preliminary step to determine labelling, marking and documentation requirements. In fact, the Proper Shipping Name is an essential element to identify the dangerous good (article, substance, mixture or even waste) on the outside of the package and on the Dangerous Goods Declaration.
proper-shipping-name-dgm-9

 

This article intends to provide  the guidelines to identify and select the Proper Shipping Name and guarantee that your shipment meets all dangerous goods regulations provisions.

 

 

 

 

  • Definition of Proper Shipping Name (PSN)

IATA DGR 55th Edition defines the Proper Shipping Name as “the name to be used to describe a particular article or substance in all shipping documents and notifications and,  where appropriate, on packagings”.

 On the other hand, the IMDG Code defines the Proper Shipping Name as “that portion of the entry most accurately describing the goods in the Dangerous Goods List which is shown in upper-case characters (plus any letters which form an integral part of the name).

  • General Criteria to select the Proper Shipping Names

Entries in the Dangerous Goods List are of the following four types, in the preferred order of use:

  1. Single entries for well-defined substances or articles. Example: UN 1090, ACETONE
  2. Generic entries for a well-defined group of substances or articles. Example: UN 1263, PAINT
  3. Specific “Not Otherwise Specified “n.o.s. entries covering a group of substances or articles of a particular chemical or technical nature, for example UN 1224, KETONES, LIQUID, N.O.S
  4. General n.o.s. entries covering a group of substances or articles meeting the criteria of one or more classes or divisions, for example UN 1992, FLAMMABLE LIQUID, TOXIC, N.O.S

In all cases the shipper shall classify the substance offered for transport by comparing its properties with the classification criteria of the hazard class. If the item has more than one hazard, the shipper must apply the prevalence of multiple hazards criteria to determine the primary hazard and assign the proper shipping name accordingly.

The selected Proper Shipping Name may be used in singular or plural as appropriate according to the Dangerous Goods List of the applicable transport regulation such as 49 CFR, ICAO-IATA, IMO-IMDG, ADR, RID.

The proper shipping name shall be included in the Dangerous Goods Transport Document. In some occasions, it is important to note that the dangerous goods description can be supplemented. Here below some examples to be considered when offering dangerous goods for sea transport:

  • Generic and "not otherwise specified" proper shipping names that are assigned to special provision 274 or 318 shall be supplemented with the technical name of the goods, for example: UN 1993, FLAMMABLE LIQUID, N.O.S (contains acetone and ethyl alcohol).
  • Wastes: the proper Shipping Name must be preceded by the word “WASTE”
  • Marine Pollutants: identified in the dangerous goods list with the P symbol. When shipping dangerous goods by sea transport, the proper shipping name may be supplemented with the recognized chemical name of the marine pollutant and the term “MARINE POLLUTANT” which may be supplemented with the term “ENVIRONMENTALLY HAZARDOUS”
  • Flashpoint: the minimum flash point shall be indicated if the dangerous gods to be transported have a flash point of 60o C (in closed-cup, c.c.) or below. Example: UN 1294, 3, II (7o C c.c.)
  • Mixtures or Solutions: if a mixture or solution is composed of a single predominant substance identified in the Dangerous Goods List and one or more substances not subject of the classification criteria, the mixture shall be assigned to the Proper Shipping Name of the predominant named in the Dangerous Goods List by adding the words “MIXTURE” or “SOLUTION” unless:
  • The mixture is identified in the Dangerous Goods List
  • The name identified applies only to the pure substance
  • The hazard class or division, subsidiary risk, packing group or physical state of the mixture or solution is different from that of the substance named.
  • The hazard characteristics and properties of the mixture require different emergency response measures.

A mixture or solution not identified in the Dangerous Goods List and that is composed by two or more dangerous goods shall be classified accordingly.

It is important to note that if a substance or mixture is intended to be offered for transport and is not included in the Dangerous Goods List, it does not mean that it does not meet the classification criteria to be considered as Dangerous Goods. In these cases, the consignor shall determine if the dangerous goods fall under any hazard class and check all relevant information to conclude it.  The Safety Data Sheet can be a helpful tool as described in our previous article.

 

DGM can ensure that your dangerous goods are classified and offered for transport meeting Dangerous Goods provisions in accordance with Dangerous Goods Transport Regulations. For any questions, please don’t hesitate to contact us.

 

 

 

 

Safety Data Sheets – SDSs – are an important and well-known element of hazard communication. Every day thousands of SDSs are asked for those agents involved in dangerous goods activities in order to check storage conditions, proper classification or personal protective equipment (PPE).blog 8

However, do we check lacking of information? How can we deal with the statement “data not available” in some sections? The purpose of this article is to provide general guidelines to ensure that all your dangerous goods requirements have been checked.

The Safety Data Sheet follows a 16 sections format which is internationally agreed:

  • Section 1: Identification of the substance/mixture and of the company/undertaking
  • Section 2:  Hazards identification
  • Section 3: Composition/information on ingredients
  • Section 4: First aid measures
  • Section5: Firefighting measures
  • Section 6: Accidental release measures
  • Section 7: Handling and storage
  • Section 8: Exposure controls/personal protection
  • Section 9: Physical and chemical properties
  • Section 10:  Stability and Reactivity
  • Section 11:  Toxicological information
  • Section 12: Ecological information
  • Section 13: Disposal considerations
  • Section 14: Transport Information
  • Section 15: Regulatory information
  • Section 16: Other information 

For dangerous goods transport purposes, the most relevant section is Section 14, Transport Information. This section shall provide basic classification information for transporting/ shipping substances or mixtures mentioned under section 1 by the different modes of transportation: air, road, sea, or rail. It shall provide the following information:

  • The UN number
  • Proper Shipping Name (PSN)
  • Hazard classes (primary and or subsidiary)/divisions assigned to the substance or mixtures
  • Packing Group assigned to the substance or mixture in accordance with their degree of hazard
  • Environmental hazards: it shall be indicated whether the substance or mixture is environmentally hazardous according to the criteria of Regulations. Example: marine pollutant under the IMDG Code.
  • Special precautions for users
  • Transport in bulk containers: only when applicable

However, additional information (e.g.: tunnel code according to ADR, segregation groups according to IMDG Code, Special Provisions or Packing Instructions) can be required to draft the Dangerous Goods Declaration and not provided in the Safety Data Sheet.

Regulations such as ADR, ICAO-IATA-DGR, RID, IMDG Code or 49-CFR shall be always checked. An SDS does not always contain updated information and all requirements needed by transport regulations.

  • Section 2: Hazards identification: This section describes the hazards of the substance or mixture and the appropriate warning information associated of those hazards such as label elements. This information shall support classification criteria specified in Section 14.
  • Section 3: Composition/information on ingredients: the information provided in this section can help in completing the N.O.S “not otherwise specified” entries by supplementing the Proper Shipping Name with the technical name or chemical group. Example: UN 1993, Flammable liquid, n.o.s (contains xylene and benzene), 3, II.
  • Section 9: Physical and chemical properties: information such as Boiling Point and Flash Point shall be provided in this section. Physical and chemical properties can be decisive to assign the packing group.
  • Section 11:  Toxicological information: the relevant toxicological properties of the hazardous substances or mixtures such as Lethal Dose LD50 or Lethal Concentration LC50 shall also be provided. Toxic parameters will help in the assignment of packing group of Class 6.1 substances and mixtures.
  • Section 16: Other information: this section shall incorporate other information that it is not included in sections 1 to 15, including information on revision of the Safety Data Sheet such as: full text of R phrases, the hazard statements, safety phrases and/or precautionary statement.

To sum up, the Section 14 of a Safety Data Sheet offers relevant information for the transport of dangerous goods and hazardous materials. However, it is recommended to check some information provided in other sections for the accuracy of the content. However, the Safety Data Sheet is just a hazard communication element that does not replace transport regulations.

DGM helps customers to ensure the safety of their shipments by checking all transport legal requirements.

 

 

From packing to storage through transport, dangerous goods activities are regulated by different laws all over the world such as:

  • ICAO Technical Instructions for air transport
  • IMO IMDG regulations for sea transport
  • Local or regional regulations (ADR or CFR 49)
    07 dangerous goods audits

Many companies establish procedures to guarantee that they are complying with all legal requirements in a continuous basis. A key element of these procedures is to carry out dangerous goods transport audits.

A dangerous goods audit is an independent, objective, and systematic assessment of how a company is managing its activities, responsibilities, and resources in order to determine the level of conformity with specific standards.

In general, there are two types of dangerous goods audits; Internal -performed by skilled employees of the organization- and external audits, carried out by independent professionals of the entity being audited

In both cases, a qualified auditor should follow these guidelines:

  • Establish the audit objective and the audit criteria. The audit criteria refers to how conditions should be. It can be specified in local laws, regulations, internal policies or standards.
  • Gather audit evidences. Audit evidence is any information collected by the auditor in order to determine whether the information being audited is stated in accordance with the established criteria. Examples of audit evidences are: photographs, records or confirmations.
  • Determine audit findings. Audits findings result from the compare audit evidences against the audit criteria.
  • Report positive and negative findings
  • Conclude against the established audit objective.

In order to guarantee independence and professionalism, outsourcing the audit process to external auditors is very a common practice.

 

The importance of considering this process in a serious way comes from the responsibilities and accountabilities assumed by shippers. Any mistake in the classification, identification, packing, labelling, marking or documentation of dangerous goods could be the cause of an incident or accident and/or a fine for shipper companies.

Fines and sanctions could reach quantities of millions of dollars and if a manager is not sure that the company is complying with regulations this is really not a nice feeling to have.

In summary, dangerous goods audits are a key element of a safety management culture and they have to be carried out by qualified, skilled and independent professionals with expertise in dangerous goods and audit technics.

DGM can perform dangerous goods audits in order ensure that all dangerous goods requirements are met by your organization. For further details please contact us.

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