DGM Network

Since 1987 taking the danger out of dangerous goods

Every January a new edition of the IATA Dangerous Goods Regulations arrives. As usual, we will take a look at the most relevant changes and additions made to the basic regulation for the transportation of dangerous goods by air, which come into effect on January 1st, 2017.

IATA 58th

 

 

Classification

A procedure has been added for the classification of substances which, while listed by name in the Dangerous Good List, also present a subsidiary hazard that is not identified in the List. In that case, the substance may be shipped under the most appropriate generic entry reflecting all hazards, or under the same UN number and name (including the necessary information in the documentation and labelling to communicate the existence of the additional risk), with the approval of the appropriate national authority.

Division 4.1 has been expanded to also include polymerizing substances (substances which, without stabilization, are liable to undergo a strongly exothermic reaction, resulting in the formation of larger molecules or polymers). The provisions have been amended with new definitions and requisites.

New paragraphs have been added to specify certain substances that may experiment a dangerous decomposition or polymerization (from classes 2, 3, 6 and 8) are forbidden for transport.

The criteria to assign flammable liquids (class 3) to packing group III have been updated to take into account their kinematic viscosity (Table 3.3.B).

 

List of Dangerous Goods

There are nine new UN numbers in the List of Dangerous Goods, one new explosive (UN 0510) and eight entries from UN 3527 to UN 3534. UN 0510 is applied to rocket motors in Division 1.4. UN 3527 comprises polyester resin kits with a solid material from Division 4.1 as their base component. UN 3528 to UN 3530 cover different kinds of engines which were previously assigned to UN 3166 (which is now only used for vehicles). Finally, UN 3531 to UN 3534 have been added as n.o.s. entries for polymerizing substances, the new addition to Division 4.1.

A number of entries have revised. For example, UN 3507 (uranium hexafluoride, radioactive material, excepted package) is now classified with a primary hazard of toxicity (Division 6.1).

Analogously to the rest of the changes in the List of Dangerous Goods, a number of special provisions have been added, modified or deleted. Most notably, special provision A104, which allowed packages containing methanol not to bear the label corresponding to its toxic subsidiary hazard, has been deleted. Another change has been done to special provision A112, which states which dangerous goods may be shipped as ID 8000 (consumer commodities): UN 3334 and UN 3335 have been added to the list.

 

Packing

Several packing instructions have been revised. All the changes to packing instructions for lithium batteries that came into effect in April 2016 have been incorporated to the new edition, and some of the transitionary measures have been deleted, since they are not needed anymore.

There are also a few new packing instructions, such as PI 220 and 378 (for internal combustion engines powered by flammable gas and flammable liquids, respectively), PI 450 and Y450 (for polyester resin kits) or PI 603 (for uranium hexafluoride in a excepted package).

A new paragraph has been added regarding packagings made of wood materials. In order to prevent the introduction of plagues and organisms harmful to plants, those must be in accordance with the International Standards for Phytosanitary Measures No 15 (ISPM15) and EU Commission Directive 2003/102/EC, whenever applicable.

 

Marking and Labelling

A distinction has been made to clearly differentiate between marking (the act of applying all the required marks to the external surface of a packaging) and mark (the physical object). On previous editions, the two terms were not used indistinguishably, leading to possible misunderstandings.

There is now a specific class 9 hazard label for lithium batteries (Figure 7.3.X). It must be used instead of the regular miscellaneous dangerous goods label when it is stated on Column D of the Dangerous Goods List.

Lithium batteries hazard label

Also, the lithium batteries handling label has been replaced by a new lithium batteries mark (Figure 7.1.C), which must be borne in packages containing lithium batteries or cells prepared under Section II of packing instructions 965 to 970, or under Section IB of packing instructions 965 and 968.

Lithium batteries mark

However, as a transitional measure, the traditional lithium batteries handling label and the class 9 generic label may still be used instead of the new mark and label until December 31st, 2018.

 

Documentation

The title of the signatory and the place of signature in the Shipper’s Declaration for Dangerous Goods are no longer mandatory. This information is now optional and the place for it is still present in the sample forms, but it may be left blank.

The additional document that had to accompany consignments prepared Section IB of PI 965 and PI 968 and Section II of all of the lithium battery packing instructions is no longer required.

 

Applicability

Following the trend from other regulations, the DGR clearly differentiates between mandatory provisions (noted by the words “shall” and “must”) and recommendations or preferred requirements (designated by “should” or “may”).

It is now clearly stated that consignments dangerous goods accepted for air transport which meet the requirements of the most current edition of the DGR at the time of acceptance by the initial operator may continue the same journey, including transfers, even if during the time it takes to reach its destination a new addendum or full edition of the Regulations comes into effect. A reoccurring example of this would be consignments accepted during the last days of December which arrive to its destination in January, when a new version of the DGR has become valid.

Training and instruction

New instructions are given for the approval of dangerous goods training programmes by the appropriate national authorities.

Also, the new edition indicates the minimum content that an employer should consider for an adequate instruction for the employees who prepare cells or batteries prepared under section II of packing instructions PI 965 to 970 (which are not subjected to the regular training provisions).

 

Handling

Regarding acceptance, the DGR clearly states that operator must be able to identify the person who performed the acceptance check. This obligation includes that the acceptance checklist retained on file must contain the identification of said person.

The 58th edition also includes a new recommendation for operators engaged in commercial air transport operations to implement a safety risk assessment process, complying with ICAO’s regulations.

 

Competency-Based Training

Although the competency-based approach to training has not made it yet to the Regulations, some of the expected provisions are detailed in a new Appendix H. Changes are expected in training programmes and curricula, and the current 17 training categories will be replaced with six competency functions. ICAO (International Civil Aviation Organization) will be collecting feedback about these proposed provisions until March 31st, 2017.

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