The DG Shipping Process – Part 5 – Other Requirements (Step 7 of 7)
By: Terry Poland, Principal Instructor and Consultant
Are you shipping dangerous goods for the first time? Or perhaps it has been a while, and you just need a quick review of the process. Where do you begin and what are the basic steps to follow? Airlines MUST use a checklist; however, shippers and others are not required to – especially for surface modes such as ocean and ground transport. So, what do we recommend? The answer is simple: a “process” that provides shippers with step-by-step guidance to assure all aspects of compliance are addressed in a logical order. While this process is not as detailed as the IATA Acceptance Checklist, generally it can be applied to all modes of transport – air, ocean, or ground (highway and rail).
- Identification – Proper Shipping Name (with technical name for N.O.S. entries) & UN/Identification Number.
- Classification – Hazard Class and/or Division (subsidiary hazards, if any) & Assignment to Packing Group (PG I, II or III, if applicable).
- Packaging – UN Specification, Limited Quantity (LTD QTY), Excepted Quantity (EQ) and/or other exceptions granted by special provisions or packing instructions.
- Marking – Proper Shipping Name, UN/Identification Number, From & To Addresses, Quantity (if applicable), other shipment-specific markings as required.
- Labeling – Primary & Subsidiary Hazard Labels & Handling Labels (Orientation Arrows, CAO, others as applicable).
- Documentation – Shipping Paper (Dangerous Goods Declaration, Transport Document, Air Waybill, Bill of Lading, etc.).
- Other Requirements – Placarding/Special Provisions/State Variations/Operator Variations/Carrier Matters.
In Part 1 of this series, we covered Steps 1 & 2: Identification & Classification of the material. In Part 2, we covered Step 3: Packaging, where the shipper determines the quantity and type of packaging for the material. In Part 3, we covered Steps 4 & 5: Marking & Labeling for dangerous goods packages. In Part 4, we covered Step 6: Documentation.
This brings us up to date with the current discussion in this article regarding Step 7: Other Requirements.
Step 7 – Other Requirements:
Other Requirements for processing dangerous goods shipments consist of the application of five possible identified final considerations depending upon shipment-specific details. These include:
- Placarding (similar to labels in color and pictographs, these are larger versions used on containers and truck loads of dangerous goods to identify their dangers to other road traffic);
- Special Provisions (additional requirements or exceptions that apply to certain materials based on the mode of transport, type of packaging among other factors);
- State Variations (additional restrictions placed on the transport of hazardous materials based on individual country restrictions);
- Operator Variations (found in IATA/ICAO regulations, these are airline policy requirements placed on the transport of certain dangerous goods);
- Carrier Matters (any restrictions or requirements placed on DG shipments by air, ocean, or ground such as transport schedules or individual carrier policies).
Placarding, for example, is generally not required for most shipments packed in non-bulk packaging (where each package has a rated capacity of not more than 450 L/119 gallons each). However, placarding is almost always required for materials identified as “high-consequence dangerous goods” as shown in placarding Table-1 in 49 CFR, Part 172.504. Once it is determined that placarding is required for a particular DG shipment, it is the shipper’s responsibility to offer placards to common carriers or to actually install the placards on all four sides of most containerized cargo. Placarding is almost always required on DG shipments prepared in bulk packaging (where each package has a rated capacity of more than 450 L/119 gallons each).
Special Provisions, on the other hand, consist of additional regulatory requirements applicable to certain materials and are noted in the SP column of the applicable dangerous goods list (air and ocean) or hazmat table (highway and rail). These may include available exceptions as well as any special packaging or identification/classification instructions. In many cases, this column is simply left blank indicating that none apply.
State Variations are detailed in the IATA (ICAO) air regulations in Section 2.8.1. These are filed by individual States (Countries) as per any additional restrictions on specific shipment types or other general DG requirements for shippers or operators (air carriers). When required, these apply to all shipments traveling to, from, through or within the filing country. Approximately 70 of the 200 qualifying nations have one or more State Variations. For example, the United States requires that a copy of the shipping paper (DG Declaration) be maintained by the shipper for no less than two years whereas IATA/ICAO only requires it to be saved for three months. Therefore, DG shippers in the US must adhere to the stricter two-year standard or be faced with potential civil penalties for non-compliance.
Operator Variations are detailed in the IATA (ICAO) air regulations in Section 2.8.3. These variations are filed by individual Operators (air carriers) as per any additional restrictions on specific shipment handling policies or other general DG requirements for shippers or operators (air carriers). For example, IATA requires that shippers provide a minimum of two copies of the Shipper’s Declaration with each shipment; however, FedEx (among others) requires that shippers provide three copies with each shipment. If a shipper refuses this policy, the operator has every right to simply reject their shipment. However, no civil liability is realized as non-compliance with Operator Variations are simple POLICY violations NOT regulatory violations.
In summary, just about every shipment is different based on the description of the material itself; the mode of transport, packaging type, and quantity and many other factors. Likewise, Step 7, Other Requirements will vary greatly for each shipment based on its unique details.
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