Search

New for 2019: How to Ship Hazmat in Articles

Posted on 10/8/2018 by James Griffin, CDGP

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.

Until now. 

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 to UN3548, 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 (2.0.6.6). 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

air-loading.jpgJoin 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.

Tags: dangerous, goods, hazardous, hazmat, IATA, IMDG, materials, new, rules, shipping

Find a Post

Compliance Archives

Lion - Quotes

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete.

Felicia Rutledge

Hazmat Shipping Professional

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well.

Marty Brownfield

Hazardous Waste Professional

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.

Brittany Holm

Lab Supervisor

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

Download Our Latest Whitepaper

The definitive 10-step guide for new hazardous materials shipping managers. Quickly reference the major considerations and details that impact hazmat shipping compliance.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.