IATA Publishes Addendum III to the 2013 DGR

As is almost always the case, IATA has published an addendum for the summer.  You may view it here.

The 2011 Penalty Actions Report

DOT issues an annual report concerning enforcement of the Federal Hazardous Materials Transportation law.  The 2011 report was just released.  It makes for interesting reading!

View the report here.

Lithium Ion Batteries to Be Banned from Passenger Air?

It appears that ICAO is thinking about banning ion batteries shipped as cargo via passenger air.  There's no doubt the recent Boeing 787 problems have elevated the topic.  If ICAO bans them, it will be interesting to see how quickly IATA will react.  Also, the reaction of DOT will be interesting as well.

Click here for the story:

http://www.usatoday.com/story/travel/flights/2013/02/13/icao-lithium-batteries/1917259/

Training Requirements - Whose Actually?

One thing that shippers are always concerned about are the training requirements found in the various regulations.  Typically, if the auditor calls, one of the first items on the agenda will be compliance with the training requirements.

The training requirements of DOT occupy Subpart H of Part 172 of the Hazardous Materials Regulations.  The requirements are straightforward.  Testing is required.  Recurrent training is required.  Training records must be kept.  Certain training components are required.

A shipper using the DOT regulations for a highway shipment rarely has questions as to the training requirements.

But what are the training requirements if you ship using the alternative regulations, such as the IMDG Code, or the ICAO Technical Instructions? (typically through the IATA Dangerous Goods Regulations).

It is true that ICAO/IATA and the IMDG documents have training chapters or subsections.  These requirements are based on the UN Model Regulations.  But experienced shippers know that there are subtle differences between the DOT requirements and those of the UN.

For example, DOT states that a hazmat employee may perform functions prior to the completion of training provided they are supervised by someone who has been trained.  But the employee must receive the training within 90 days after employment or a change in job function.

The “90 day window” does not exist in the international regulations.

This biggest difference seems to be in recurrent training.  DOT requires training once every 3 years, and the international rules state every 24 months.

Clearly this is a controversial discrepancy.

Who is right?

Whether you agree with the logic or not, the answer lies in Subpart C of Part 171 of the DOT regulations.  This subpart, known as “Authorization and Requirements for the use of International Transport Standards and Regulations” addresses training issues.  Specifically, section §171.22(g)(2) states that if using an international standard, the shipper is subject to the training requirements in subpart H of part 172 of this subchapter, including function-specific training in the use of the international transport standards and regulations.

Whether one agrees with this or not, simply put, the only training requirements that can be enforced in the US are the DOT requirements, which include the 3 year recurrent training requirement.

The shipper of course can stay on a 2 year recurrent training schedule which is more conservative than 3 years, but it appears that all that can be enforced are the DOT requirements for training.

HM-215L - Changes to DOT Regulations

Every two years, PHMSA publishes a final rule in the "215" docket series.  In this case it's HM-215L.  As a training organization we have to stress that it's important to focus on the various dates associated with this type of docket.

In this case:

Voluntary compliance is authorized as of January 1, 2013
Delayed compliance is authorized until January 1, 2014

Our experience in training is that these dates can confuse a shipper, so caution is urged.  It does create a more complicated scheme for 2013.

This is a big document, stretching for 114 pages.  For a copy, click here.

HM-215K Final Rule Extends Transition Period for ORM-D Materials Transported by Highway

The ORM-D issue continues to generate much interest.  Our experience as a training organization is that most US shippers do NOT ship consumer commodities by air under the DOT regulations.  But by highway, it's another story entirely.

On Monday, January 7, 2013, the transition period for shipments traveling under ORM-D designation was extended until December 31, 2020.

Other issues are discussed in this final rule as well.  Click here to view the Federal Register document.

IATA Publishes Addendum to 2013 DGR

This is interesting in that the addendum has been published before 1 January 2013!  Click here for the file.

IATA Lithium Battery Guidance

IATA has published another excellent guidance document which addresses the 2013 DGR changes.  To view the document, please click here.

FAA Battery Incidents Report

This document is fairly up to date and will certainly open your eyes as to the large number of incidents in air transportation involving lithium batteries.  Note how many of these take place in the passenger cabin or in checked baggage!

Access the document here.

FAA Allows Transition Period on Lithium Batteries

FAA announced today (12/21/2012) that a one month transition period will be allowed for use of the 2011-2012 ICAO Technical Instructions as they relate to lithium batteries.  This does not include "contained in" or "packed with" equipment.

For the IATA user, this means you may use the 2012 IATA DGR until the end of January 2013

Asiana B744 Cargo Fire

In 2011, an Asiana Airlines B744 freighter crashed off Jeju Island, near South Korea   It has long been speculated that a fire caused by lithium batteries may have been the cause of the crash.  The South Korean government has published an initial report, which you may read here

IATA Changes for 2013

IATA has published a summary of their changes for 2013

You may view it at:

http://www.haztraining.com/images/DGR54-Significant-Changes.pdf

As usual, this document reflects the continued development of the DGR.

See you in the classroom soon!

Environmentally Hazardous Substance?

The EHS concept is getting a lot of attention, particularly now in ICAO/IATA and the IMDG Code.

Trouble is, DOT has had a similar concept for quite some time now.

And as you can imagine, this can get very confusing.

Take a look at the attached document:

Welcome Back!

Welcome back to the Haztraining Blog!  

It's been a long time since we posted, as we shut down our training site for a while, and we apologize for this!


But we are back and here to stay!

Of course so much is happening in the dangerous goods world now, and many topics will be addressed very soon here.

We are inundated with questions about lithium batteries, environmentally hazardous substances, and many other issues.

And we intend to address them all very shortly!

Please visit our training site at:

www.haztraining.com

We look forward to working with you again!

The Dangerous Goods Training Blog

Welcome to the Dangerous Goods Training Blog. This blog will focus on regulatory and training issues concerning the transport of dangerous goods and hazardous materaisl by highway, ocean, and air. Our principal focus will be on the actual regulations themselves, from DOT, IATA/ICAO and the IMDG Code.

Posts will appear about once a week. Please check back soon. The transport of dangerous goods by any mode has never been more complicated!

Feel free to visit our dangerous goods training website:

www.haztraining.com