[Editor’s Note: Lion Technology Inc. instructor Roseanne Bottone is blogging from the Dangerous Goods Advisory Council (DGAC) Conference & Hazardous Materials Transportation Exposition. Daily, she will provide her observations and insights from the conference in order to keep our members up–to–date with the latest regulatory news.]
Coming Soon from the International Civil Aviation Organization (ICAO)
The second day of the DGAC conference was jam–packed with so much great information that today’s blog is a continuation of what was learned in Tuesday’s program regarding developments with the International Civil Aviation Organization (ICAO).
Ross McLachlan from the United Kingdom’s Civil Aviation Authority reviewed changes to the upcoming 2013–2014 edition of the ICAO Technical Instructions (TI). He first discussed a small change to the training standard that may allow a little more flexibility in scheduling your upcoming 2–year training class. The TI now allow an employee’s training certification to be valid until the end of the month of his/her training anniversary date. This is going to be a change to the 2013–2014 technical instructions. However, hazmat training in the U.S. is regulated by the DOT rules at 49 CFR 172, Subpart H. The DOT rules will still require the hazmat employee to be trained every three years by the anniversary date.
Ross McLachlan also mentioned five things about lithium batteries and air shipments under the ICAO TI:
- Lithium batteries must be manufactured under a quality management program;
- Special Provision A21 will be changed to include only vehicles powered by lithium battery (by removing reference to equipment containing lithium batteries);
- They will add a new special provision, A185, to address the requirements of shipping equipment containing lithium batteries;
- Overpacks containing lithium batteries will require the lithium battery marking; and
- The lithium battery airway bill will require special wording indicating the lithium battery is in compliance with all applicable regulations.
ICAO has done a lot more work with special provisions (SP). Look for changes that address solids that convert to flammable, toxic, or corrosive liquids; a reformatting and clarification addressing engines and vehicles; medical waste containing Class A infectious substances; chemicals under pressure; and a new SP A186 for UN3499 capacitors. Of particular interest are two yet un–numbered special provisions:
- Formaldehyde solutions at 10%–25% shall be assigned to UN 3334 Aviation regulated liquid. If it contains less than 10% formaldehyde, it won’t be subject to the regulations.
- Manufactured articles containing mercury will be Class 8 corrosives and also require a 6 toxic hazard label. If there are less than 5 kg of mercury in the package, the toxic label will not be required.
Packaging and Hazard Communication
The 2013–2014 edition of the ICAO TI will also contain some changes to packing requirements. There will be a liberalization of requirements for excepted quantity materials with E1, E2, E4, and E5 codes (that’s right–not for E3); Packing Instructions 370 and Y370 will see an increase in quantities allowed for polyester resin kits; and Y373 for Mercaptan liquid, flammable will require absorbent material for glass inners as well as intermediate packaging.
Even marking requirements have a new rule for the minimum size of the UN identification number as follows:
- 12 mm for > 30 L/30 kg
- 6 mm for ≤ 30 L/30 kg
This will be mandatory starting January 1, 2014.
As far as labeling goes, the orientation arrows label will not be required on
Here’s a big one that can affect your palletized/overpacked materials: Dangerous goods and non–dangerous goods will have to be offered separately to the operator. As you may already know, the operator has to use an acceptance checklist in order to receive your dangerous goods. ICAO will now require them to keep that paperwork for 3 months.
There’s one more piece of good news that may be coming down the pike for anyone shipping under an exemption. Right now, you have to get approval from the operator and states of origin, transit, and destination. ICAO is working on removing the requirement for approval from any “over–flight” transit state.
In Friday’s post, I will bring the last installment, covering the final day’s presentations.