Latest amendments for transporting dangerous goods

By John V Currie -- Logistics Management, 11/1/1998

Once again it's time to prepare for amendments to the modal regulations for the international transportation of dangerous goods. Effective Jan. 1, 1999, the regulations for ocean and air transportation will include amendments that affect shippers and carriers of dangerous goods. Here's a look at some of those changes.

For the first time ever, the Maritime Safety Committee (MSC) of the International Maritime Organization (IMO) recommended a six-month transition period for compliance with Amendment 29-98, from Jan. 1, 1999, to the amendment's effective date of July 1, 1999. The MSC recognized that some governments might opt to implement all or part of the new requirements during that transition period and recommends that IMO be so notified. To date, I am unaware of any governments that have declined to recognize the transition period, but shippers and carriers should monitor developments to ensure smooth international movement of dangerous goods.

Several new proper shipping names have been added to the General Index of the International Maritime Dangerous Goods (IMDG) Code, including some generic or "n.o.s." entries that require additional technical descriptions. Some materials that had been identified by a generic description now have their own proper shipping name and individual schedule. For example, new United Nations (U.N.) identification numbers and descriptions have been added for refrigerant gases, insecticide gases, nitroglycerin mixtures, mercaptans, xanthates, thiourea dioxide, and many pesticides in Class 6.1.

Class 6.2 requirements for certain biological products, diagnostic specimens, and clinical or medical wastes, and the requirements for their packagings when they contain refrigerants have been amended. Separate packaging tables for liquids and solids have replaced the packing tables in the introduction to each class.

This amendment also introduces a dangerous-goods form that is recommended for shipments involving multiple modes of transportation and which includes a container packing certification. Although this form is based upon the U.N. Layout Key for Trade Documents and it includes entry fields for air-transportation data, it remains to be seen if IATA will accept this document.

Speaking of IATA, the 40th Edition of the International Air Transport Association (IATA) Dangerous Goods Regulations also becomes effective Jan. 1, 1999. It includes many of the same changes found in the IMDG Code because both are based on the recommendations of the U.N. Committee of Experts. In addition to clarifying the compliance responsibilities of freight forwarders and cargo agents, the newest IATA regulations also amend classification criteria for certain explosives, pesticides, and biological products. New proper shipping names and U.N. numbers have been added to the "List of Dangerous Goods," and the "Special Provisions" have been amended to reflect changes in the U.N. recommendations.

"Aviation Regulated Solid or Liquid" has been added as a proper shipping name. "Vehicle (flammable gas powered)" and "Vehicle (flammable liquid powered)" now will be used to describe vehicle shipments and will use the same U.N. number assigned to "Engines, internal combustion." The descriptions for "Aerosols," as corrected in an errata to the 39th Edition, will revert to those listed in the 38th Edition but will no longer include the entry "n.o.s." following the proper shipping name.

IATA now will place additional responsibility on shippers to prevent damage to drums on some narrow-bodied aircraft, by requiring them to overpack or otherwise protect drums as a single packaging. Another new regulation says that a package with upward orientation arrows must be stowed and handled at all times in the upright position. U.S. domestic regulations also are currently being amended to reflect the latest regulatory harmonization.

John V. Currie's firm, Currie Associates Inc., provides hazardous-materials transportation safety and compliance audits, consulting services, customized training manuals, and public and in-house seminars. He may be contacted at 1118 Bay Road, Lake George, NY 12845. Phone: (518) 761-0668. Fax: (518) 792-7781. E-mail: currie@netheaven.com.