In the Hazardous Materials (Dangerous Goods) Regulations, the term “article” means machinery, apparatus, or other devices containing one or more dangerous goods (or residues) as an integral element, necessary for its functioning, that cannot be removed for the purposes of transport
The hazmat tables in 49 CFR, the IATA DGR
, and the IMDG Code
identify many articles: batteries, engines, fire-extinguishers, mercury thermometers, safety devices, capacitors, etc.
But what happens when you have an article that contains dangerous goods, but that article is not identified by name in the regulations
, like a fuel pump (pictured below) or a piece of lab equipment?
Traditionally you had one option: Classify it as “UN3363//DANGEROUS GOODS CONTAINED IN APPARATUS//9.” The thing is, articles shipped under this description could not contain more hazmat than was authorized as a limited quantity.
So, what happens when you have an article that contains dangerous goods inan amount that exceeds its limited quantity threshold?
There was nothing you could do; such articles were forbidden from transport without prior Approval.
Save when you order your copy of the 2019 IATA Dangerous Goods Regulations (60th Edition) or the 2018 IMDG Code before 10/15 at Lion.com! Save $10 and get free shipping anywhere in the US.
Starting on January 1, 2019, the IATA DGR
and IMDG Code
feature twelve new proper shipping names that shippers can use for air and vessel shipments.
The new UN numbers run from UN3537
, and each description begins with the words "ARTICLES CONTAINING." Following those two words is a description of the hazard class of the DG contained in the article.
For example, the new description for UN 3537 is "ARTICLES CONTAINING FLAMMABLE GAS, NOS 2.1"
What’s the Catch?
These twlelve new shipping descriptions may provide more flexibility for shippers, but there are still limitations that must be observed:
1. Articles containing any of the following hazards may only be transported with Approval from Competent Authorities: Division 2.3, 4.2, 4.3, 5.1, 5.2, and PG I materials in Division 6.1
2. Articles containing more than one of “gases”, “liquid desensitized explosives” and “self-reactive substances” are also prohibited
from transport without Approval.
You’ll see that these new provisions do not
apply to dangerous goods of Class 1 (explosives), Division 6.2 (infectious material), or Class 7 (radioactive). Articles containing those materials are already well regulated under existing provisions.
Can Articles Contain Lithium Batteries?
Articles shipped under these new provisions can
contain lithium batteries, provided that those lithium batteries are undamaged and meet applicable testing requirements.
What About Subsidiary Hazards?
Subsidiary hazards, or combinations of dangerous goods in the article, are not a problem; provided that you take steps to ensure only compatible materials are shipped together.
To wrap up, starting next year, you will have new options for shipping large articles containing dangerous goods. These new descriptions are not for articles containing a limited or excepted quantity of hazmat—for which shippers should still use UN 3363—they are only for large articles.
Likewise, if you're shipping an article that already appears on a list of dangerous goods (batteries, fire extinguishers, capacitors, etc.), you should continue to use the appropriate, existing description.
We've already seen these new rules in the IATA DGR
(3.12) and the IMDG Code
(220.127.116.11). Chances are that US DOT will add these new descriptions to 49 CFR in a future harmonization rulemaking.
We'll let you know if and when they do.
IATA DGR Dangerous Goods Air Shipper Training
Join us live in San Francisco, San Diego, Seattle, Kansas City, Detroit, and Cincinnati for expert-led multimodal hazmat shipper training in October 2018.
Lion instructors will be covering the new 2019 rules you must know to ship dangerous goods by ground, air, or vessel.
Can’t make it to the workshop? Expand on your 49 CFR knowledge from the comfort of your home or office! Join in on a live Lion webinar to learn the latest unique IATA or IMDG rules over the web. Interact with a live instructor and get answers to your questions during or after the sessions. Plus, get resources to help you simplify compliance and earn a full year of Lion Membership for complete regulatory support.