The Need for Standardizing the Distribution of Emergency Response Information

Editorial by Russell Bowen

Andy Rooney, from the TV show of 60 Minutes, isn’t the only one with an opinion. Everyone has an opinion on something. Here are some opinions that I have concerning the life endangering topic of hazardous materials or dangerous goods information during a transportation incident or accident. Unless the entire emergency response community demands and receives the best that industry currently can provide, who wins? For all first responders to a transportation emergency scene involving an aircraft or a surface vehicle, one of the first considerations, in my opinion, should be: "Are there any hazardous materials on board and if so, where and how much?" While one of the primary objectives for first responders is to neutralize and contain a hazardous materials spill or incident, the safety and well-being of the responders and others involved in the incident must also be a priority. A way of notifying any emergency responder of critical hazmat information should be available immediately upon demand and automated. An automated Notification to the Pilot in Command (NOTOC) or “NOPIC or Pilot Notification Form (PNF)” or Truck Manifest that has emergency response information from two sources contained on it would certainly fill the bill here. Although there has been much talk and meetings on the subject, including a meeting in Washington D.C., by interested parties, little has been done to resolve the lack of timely, accurate and automated hazmat information to all emergency responders. The first source of information should be from the Emergency Response Guidebook (ERG) that was developed jointly by the US Department of Transportation, Transport Canada, and the Secretariat of Communications and Transportation of Mexico (SCT). The second source is the International Civil Aviation Organization (ICAO) Emergency Response Guidance for Aircraft Incidents involving dangerous goods (known as the ICAO Red Book). For the first responder, these sources of information are essential for not only addressing the incident but also conveying information about protective clothing, evacuation and first aid. Onboard the aircraft, the pilot and crew could be considered the first line of defense involving any type of emergency, including a hazardous material spill or incident, and they are in essence the first responders while the aircraft is in the air. Emergency procedures will differ onboard an aircraft in flight vs. procedures to follow while the aircraft is on the ground. Under the guidance of the International Civil Aviation Organization, the ICAO Red Book has been developed with the assistance of the Dangerous Goods Panel to provide guidance to countries and airlines for dealing with dangerous goods emergencies while the aircraft is in the air.  The crew is supplied information related to the inherent risk, risk to aircraft, risk to occupants, spill or leak procedures, firefighting procedures and additional considerations. On board a truck, the procedures for addressing emergency response are outlined on a Truck Manifest using the Emergency Response Guidebook (ERG), including inhalation hazards procedures and ERIP Name or Contract number if provided. The information made available to all should also include the name of the chemical, the UN identification number, class hazard, the degree of danger known as the UN Packing Group Number, quantity per package and a description of the package and where on the aircraft or truck the package is located.  This information should be immediately available from the airline involved to a first responders, free of charge, by using the world wide web. The entire NOTOC or Truck Manifest form should be made available to be immediately e-mailed to any MAPI-compliant e-mail address anywhere in the world within seconds (terminals, smart phones, airport towers, response vehicles, etc.).  While en-route to the scene of a hazmat incident, a first responder that has a smartphone should receive not only the NOTOC or Truck Manifest via e-mail , but also receive a summary in the front end of that e-mail of all of the dangerous goods onboard the aircraft or truck by position number, reflecting total quantity by class hazard, ERG Guide Numbers as well as emergency response telephone numbers of the emergency response information provider. These opinions are that of just one person. Should there be more consideration given to the topic? Unless the entire emergency response community demands and receives the best that industry can currently provide, who wins?

Technical Name Requirements on Shipping Papers

Introduction

The requirement to reflect a Technical Name on shipping papers and packages (in most cases) in addition to the proper shipping name is signified in several ways, based on regulatory publications for the transportation of hazardous materials and dangerous goods. 

These include (but are not limited to):

• Capital letter “G”
• Five-pointed star and/or asterisk
• Number 274

This requirement by the regulations comes from the need for more descriptive information, primarily to assist emergency responders in their efforts to provide quick and accurate response when called upon.

Technical names are to be sourced from scientific handbooks, texts or journals. Trade names (e.g. WD40, Ambesol, Clorox, etc.) provide little to no information for emergency responders as they, in most cases, do not reflect the actual chemical or hazardous constituents that must be identified in an emergency situation. Even when the chemical or hazardous constituents are printed somewhere on the package label, in most cases the package is engulfed in the emergency situation leaving responders with the inability to access that information.

Requirements

The regulatory requirement for reflecting technical names depends on which set of regulations that are being used and further delineated by either a Latin character, a symbol or a number.

• The capital letter G in 49 CFR is reflected in the Hazardous Materials Table, Column 1, is the rule which is found in 172.101(b)(4).
• The five pointed Star is found in the IATA DGR Alphabetical List of Dangerous Goods, which is defined in Appendix B, Symbols an abbreviations, B.2.1. The asterisk if found in the ICAO Technical Instructions, Chapter 1, 1.2.7.
• The number 274 is found in the IMDG Code, Volume 2, the Dangerous Goods List, Column 6 Special Provisions, and defined in Chapter 3.3, 3.3.1.

Considerations and Exceptions

There are times when a shipper can use a proper shipping name listed in the regulations as a technical name. Some transportation employees will incorrectly reject this as inappropriate and return the shipment to the shipper which costs time, revenue and customer good will.

For example, a shipper declares the following:

UN 1224, Ketones, liquid, n.o.s. (Acetone), 3

Sometimes, an operator or freight forwarder will reject the technical name of “Acetone” because it is listed as a proper shipping name (UN 1090tone, 3) in the regulations and refuse to validate the accuracy of the declaration or package markings.

What is not realized here is that the regulations themselves could be consider a scientific handbook, text or journal that reflect recognized chemical and biological names. There are even references in the regulations that give examples on how a proper shipping name is to be reflected as a technical name.

Using the IATA Dangerous Goods Regulations, let’s consider the following example:

A shipper takes some UN 1090, Acetone and mixes it with distilled water (non-dangerous goods). This combination of liquids is no longer pure UN 1090, Acetone, 3, II. The flash point has been diluted to 25°C and boiling point is 52.6°C, changing the Packing Group from II to III.

IATA DGR Subsection 4.1 describes the process for “Selecting Proper Shipping Name”. In 4.1.0.2, the regulations list four general types of proper shipping names a shipper may choose from:

• Single entries for well-defined substances,
• General entries for a well-defined group of substances or articles,
• Specific n.o.s. entries covering a group of substances or articles of a particular chemical technical nature, and
• General n.o.s. entries covering a group of substances or articles meeting the criteria of one or more classes or divisions

To properly select the right proper shipping name in this example, the shipper must now refer to IATA Subsection 4.1.3 – Mixtures and Solutions not Listed by Name. 

In Subsection 4.1.3.1 – Mixtures and Solutions, there are four exceptions to adding qualifying text “solution” or “mixture” to the proper shipping name. The third bulleted item reads:

“the hazard class or division, subsidiary risk(s), physical state (solid, liquid, gas), or packing group of the mixture or solution differs from that of the substance named in listed Subsection 4.2 – List of Dangerous Goods”

Subsection 4.1.3.1 – Mixtures and Solutions also reads the following:

“For a solution or mixture when the hazard class, the physical state or the packing group is changed in comparison with the listed substance, the appropriate n.o.s. proper shipping name must be assigned, followed by the technical name of the substance in parentheses”

Because mixing UN 1090, Acetone with distilled water changed the flash point and Packing Group from II to III, the shipper must follow these regulations accordingly. Acetone is a Class 3: Flammable liquid and in the Ketone chemical family. As a result, the shipper must declare this as:

UN 1224, Ketones, liquid, n.o.s. (Acetone), 3, III

Conclusion

Whether it’s the shipper, freight forwarder, ground handler or airline, trucking company or vessel operator, it all boils down to proper, in-depth training on the proper use and application of the regulations. When it’s your time to get training, exercise what is taught in any business school by understanding the Latin term of, “Caveat Emptor”, and exercise due diligence as to who is performing your dangerous goods training and how long have they been providing it. There are excellent DG training schools in the market place, just make sure you get one of them.

What is a Q-value? For dangerous goods air transport?

Introduction and Background
When a shipper packs two or more dangerous goods (or hazardous materials, hazmat) into one combination package for air transport, there are additional requirements over and above the general packing requirements and compatibility compliance within the ICAO/IATA regulations.

Shippers must also be aware of possible:

• Combustion and/or evolution of considerable heat,
• Evolution of flammable gases that asphyxiate or are toxic,
• Formation of corrosive substances, or
• Formation of unstable substances if the materials mix.

When a package contains dangerous goods of the same physical state (e.g. liquids, solids or gases), it is easy to calculate the maximum net quantity allowed in the package based on the regulations. You simply add the allowable quantity (based on their respective packing instructions) for each dangerous goods together.

This becomes difficult when your package contains dangerous goods of different physical states.

To address this issue, the ICAO Technical Instructions (TI) published a new requirement in 1985 for calculating the maximum quantity allowed for multiple dangerous goods contained in one outer packaging, regardless of the physical state. The IATA Dangerous Goods Regulations (DGR) quickly followed suit.

This new requirement was called the "Q-value". As outlined in IATA DGR 5.0.2.11(g), the Q-value is applied to packing such that, "the quantities of different dangerous goods contained in one outer packaging must be such that "Q" does not exceed the value of 1.0."

Applicability
The Q-value is calculated by using the formula of:

Where n₁, n₂, etc. are the net quantities per package of the different dangerous goods, and M₁, M₂, etc. are the maximum net quantities allowed per package for these different dangerous goods according to the List of Dangerous Goods in Section 4 of the IATA DGR.

The sum, Q, must be equal to or less than 1. The sum must be rounded up to the nearest tenth (or first decimal place). This formula is applicable whenever more than one dangerous goods is packed or contained within a combination package intended for air transport.

Example
A shipper is shipping the following dangerous goods contained in the same outer fiberboard box:

• 1.0 Liter of UN1114, Benzene, Class 3, PG II, using packing instruction 353
  (max. net quantity per package for 353 is 5 Liters)
• 2.0 kilograms of UN2803, Gallium, Class 8, PG III, using packing instruction 867
  (max. net quantity per package for 867 is 20 kilograms)

The Q-value for this package is calculated with the following equation:

This gives a Q-value of 0.3. Since the Q-value is equal to or less than 1, these dangerous goods quantities may be all packed into one 4G fiberboard box. If the Q-value exceeded 1, the quantities of dangerous goods would have to be reduced until the Q-value of 1 or lower is achieved.

Exclusions
The following dangerous goods are not considered in the calculation of the Q-value:

• UN1845, Dry ice,
• Those where Columns J or L in the IATA List of Dangerous Goods indicate "No Limit",
• Those with the same UN number, packing group and physical state (e.g. solid or liquid), provided they are the only dangerous goods in the package and the total net quantity does not exceed the maximum  net quantity shown in the List of Dangerous Goods, or
• Those where Columns J or L in the IATA List of Dangerous Goods indicate a gross weight per package.

Considerations
There are additional considerations to take into account when dealing with multiple dangerous goods being packed into one outer package.

These can include (but are not limited to):

• IATA DGR 8.1.6.9.2(f) for describing how these packages are declared on the shipper's declaration for dangerous goods:
• For one package, the phrase "All Packed in One (description of package type)" must immediately follow the relevent entries (e.g. "All Packed in One Fiberboard Box"), and
• For multiple packages, the phrase "All Packed in One (description of package type) x (number of packages)" must immediately follow the relevant entries (e.g. "All Packed in One Fiberboard Box x 3").
• The outer package must be allowed for all dangerous goods contained within it,
• The outer package must meet the specification performance tests for the most restrictive packing group of the a substance or article within the package,
• Must comply with inner packaging requirements, and
• When a package contains a dangerous goods with the letter "G" following the quantity shown in Columns J or L in the IATA List of Dangerous Goods, the gross weight of the completed package does not exceed the lowest applicable gross weight.

Other considerations (including Limited Quantities, special provisions, etc.) will be saved for a future discussion.

Regulatory Staff
Bureau of Dangerous Goods, Ltd.

IATA Dangerous Goods Regulations Significant Changes for the 53rd Edition (2012)

A preliminary list of significant changes being made to the 53rd edition of the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) has been published by IATA for the upcoming year.

Changes are being made to:

• 2.3 - Dangerous Goods Carried by Passengers or Crew
• 2.7 - Dangerous Goods in Limited Quantities
• 4.4 - Special Provisions
• 5 - Packing Instructions
• 7 - Marking and Labeling
• 9 - Handling
• Appendices D, E, F and H

You can read about these changes by clicking on the following link:
IATA DGR 53rd Edition Significant Changes

Common misapplication of the UN packing group number for IATA/ICAO dangerous goods shipments

As most of us have been taught by our dangerous goods instructor, the UN Packing Group Number (I, II or III) denotes the degree of danger for a particular dangerous goods. UN Packing Group I, II or III means respectively, high, medium or low danger.

Criteria for these groups have been developed for dangerous goods in Class 3, Class 4, Division 5.1, Division 6.1 and Class 8. Whenever a UN Packing Group Number is reflected in Column F of the Alphabetical List in the IATA Dangerous Goods Regulations (and Column 8 of the ICAO Technical Instructions), with a few exceptions, this number must then be reflected on the shipping document.

A frequent misapplication of this requirement happens when a shipper will notice a UN Packing Group Number reflected in the text of a Packing Instruction Number (PIN) that is not reflected in either Column F or Column 8.

For example, a Class 1 material, UN0456, Detonators, electric, is referenced to PIN 131 for either Passenger or Cargo Aircraft Only preparation in the Alphabetical List of Dangerous Goods and Column F is blank for the Packing Group (Column 8 in ICAO for the same Class 1 material is also blank). The reasoning for the blank packing group column is that Class 1 dangerous goods have not had packing group criteria developed yet by IATA and ICAO.

In the text of PIN 131, it states, "Unless otherwise provided for in these Regulations, packagings must meet Packing Group II requirements". In general, this statement refers to the degree of integrity that the packaging must have, not the degree of danger of the dangerous goods.

The UN Committee of Experts uses the letter of X, Y or Z to denote what UN Packing Group Numbers are authorized in a UN package.

• Using the letter X, means that the package is authorized to contain a Packing Group I, II or III material.
• Using the letter Y, means that the package is authorized to contain a Packing Group II or III material.
• Using the letter Z, means that the package is authorized to contain a Packing Group III material only.

In the case of PIN 131, the letter Y is to be reflected in the UN Specification Mark as a minimum. The letter X is also authorized because it is meant for Packing Group I and II materials.

Unfortunately, this misapplication isn't normally caught until after the shipment has been delivered to the airline, and has been inspected by the airline's dangerous goods specialist or technician utilizing a checklist. Upon detection of the error, the shipment has now automatically incurred a delay until corrected by the shipper. Upon inspection of the airline's dangerous goods file (kept by the airline for a period of 1-2 years depending on the country concerned) of dangerous goods shipments by a regulatory officer, the shipper may be asked additional questions regarding the shipment.

New FedEx Ground Hazardous Materials Shipping Requirements Begin August 1, 2011

Effective August 1, 2011, FedEx Ground will require all hazardous materials shipper papers to be completed and submitted electronically using one of the following methods:

• a FedEx® electronic shipping solution,
• a FedEx® recognized hazardous materials vendor software application,
• a FedEx® Compatible Solutions Program application, or
• a custom solution that has the ability to transmit hazmat shipping information electronically

Similar to IATA FX-18 for FedEx Express dangerous goods air shipments, this requirement is intended to reduce errors in data entry, provide accurate emergency response information and improve the overall safety of transporting hazardous materials.

This new requirement is only applicable for shippers using FedEx Ground for transporting hazmat shipments.

To learn more about each available solution listed above, please visit the following URL on the FedEx website:
http://www.fedex.com/us/hazardous-materials/current-requirements/index.html

Did you know...

The Bureau of Dangerous Goods, Ltd. is a FedEx recognized software vendor with its ShipHazmat web applications and CD software.

We have developed a specific web solution called ShipHazmat Ground to help shippers meet this new requirement. This easy-to-use solution will be available August 1, 2011 in conjunction with the FedEx Ground requirement.

Important Note: We are running a very special promotion for all users who sign up at www.ShipHazmatGround.com through December 31, 2011. Please visit any of our websites to learn more!

IATA Dangerous Goods Regulations - Addendum II to the 52nd Edition 2011 has been published

IATA Dangerous Goods Regulations
Addendum II - 52nd Edition (2011)

IATA recently published Addendum II to the Dangerous Goods Regulations on May 5, 2011.

Several changes and corrections have been made to the following sections:

• 2.8 State and Operator Variations
• 4.2 List of Dangerous Goods
• 5.4 Packing Instructions — Class 4 — Flammable Solids; Substances Liable to Spontaneous Combustion; Substances which, in Contact with Water, Emit Flammable Gases
• 10.0 Transport of Radioactive Material

To review the full addendum, please follow the link below:
http://www.bureaudg.com/downloads/IATAAddendum052011.pdf

Users of our ShipHazmat 2011 software can download updates pertaining to these changes at the following location:
http://www.bureaudg.com/support

ShipHazmat.NET will undergo server maintenance to update its regulatory engine with these changes later today at 4:00PM EST. Maintenance is expected to last approximately 10 minutes. Users will not be able to use or log into ShipHazmat during this time.

HR 658 Transporting Lithium Batteries in the United States

Lithium Batteries
Ever since January 11, 2010, when Hazardous Materials docket HM-224F was published concerning Lithium batteries, the entire global shipping and transportation industry was very concerned that the ability to send lithium batteries via air transport was going to be severely restricted in the United States.
In January 2010, the DOT proposed to remove exceptions for small lithium batteries (Section II of the Lithium Battery packing instruction numbers of the IATA/ICAO Regulations), effectively making them fully regulated Class 9 hazardous materials like their medium and large-sized counterparts.

Change of Direction
Approval today, April 5, 2011, by the U.S. House of Representatives of HR 658, the Federal Aviation Administration (FAA) Reauthorization and Reform Act, which includes a provision directing the U.S. Department of Transportation (DOT), to ensure that its regulations governing the air transport of lithium ion or lithium metal batteries and products that contain or are packed with these batteries are no more stringent than international requirements in place at any time. The one exception allowed is the continuance of the U.S. prohibition of air shipment of lithium metal cells and batteries on passenger aircraft.

The House approved HR 658 by a vote of 223-196 and will have to reconcile it with a Senate-passed bill that does not include any provisions pertaining to lithium batteries. The battery provision, offered by Transportation and Infrastructure Committee Chairman John Mica (R-FL), was approved by a bipartisan vote of 251-168.

Chairman Mica's harmonization amendment directs DOT to not issue or enforce any regulations regarding the air transportation of lithium metal cells or batteries, or lithium ion cells or batteries, or products that use them, that are more stringent than requirements pertaining to lithium batteries in the 2011-2012 Edition of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air or any future amendments to those instructions.
Although this Approval is not a Final Rule yet in the transportation regulations of the USA, it gives the transportation industry and shippers of Lithium Batteries the insight necessary for them to make business decisions on the future ability to transport lithium batteries by air in the United States.

HM-215K Harmonization of PHMSA Hazardous Materials Regulations with International Standards for Dangerous Goods

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is scheduled to publish docket HM-215K tomorrow regarding the harmonization of U.S. Hazardous Materials Regulations with the United Nations Recommendations, IMDG Code and ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air.

International standards will be adopted by the Hazardous Materials Regulations that include changes to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, air transport limited quantities and vessel stowage requirements.

Voluntary compliance begins on January 1, 2011.

Mandatory compliance with the amendmends adopted in HM-215K begins on January 1, 2012.

To read the full docket HM-215K regarding harmonization, please click on the link below:

Harmonization docket HM-215K

IATA Addendum to the 52nd Edition Dangerous Goods Regulations

IATA has recently published an addendum to the 52nd edition of the Dangerous Goods Regulations.

The amendments found within are effective January 1, 2011 and are highlighted in yellow.

To view the addendum, click on the link below:

IATA Dangerous Goods Regulations Addendum 52nd Edition