In the October 29th edition of the Federal Register, the United States Department of Labor’s (USDOL) Occupational Safety & Health Administration (OSHA) issued a notice announcing that a public meeting will be held in Washington, DC on November 12th from 1 PM to 4 PM Eastern Time (EST) addressing the planned agenda and issues to be discussed as well as any proposed response to such issues by the United States at the United Nations Globally Harmonized System for the Classification and Labeling of Hazardous Chemicals (i.e., GHS) meeting to be held in December in Geneva, Switzerland.
As the rules around shipping lithium batteries continue to evolve in our industry, so must the training we provide the employees who ship these Dangerous Goods. On August 6, PHMSA published the HM-224F Transport of Lithium Batteries Final Rule. More than five years in the making, this rule contains a number of significant changes to how lithium batteries must be shipped, including:
- Changes to exceptions for domestic road transport, particularly the exception for packages with no more than 12 batteries/24 cells
- Adopting the international shipping descriptions and Watt-hour (Wh) ratings
- A new section for lithium batteries/cells being shipped for disposal or recycling
- Aligning the carry-on and checked baggage exceptions for passengers and crew members with the ICAO TI
Voluntary compliance is already in effect, and mandatory compliance begins February 6, 2015. You can read more about HM-224F on our blog here.
These new changes will have an impact on the training required for everyone who ships lithium batteries across all modes of transportation. That means it’s time to take an in-depth look at your current training programs and practices to determine how they’ll need to evolve to meet the mandatory compliance deadline. A good place to begin:
- Thoroughly reviewing HM-224F (and keeping an eye on proposal HM-215M—more on that can be found here)
- Reviewing what specific lithium battery products will need to be shipped and how they will be shipped
- Determining which aspects of the rule need to be applied
- Reviewing who is responsible for the different aspects of the shipping process
Most important—don’t wait until the last minute. Keeping your training programs in compliance with changing rules takes time and effort, and making sure your shipping employees are up to date on the latest regulations today means fewer frustrated shipments in the future.
If you have any questions, Labelmaster is ready to help with training support, consulting and the broadest range of products, services and software to address every aspect of shipping lithium batteries.
In the October 22nd edition of the Federal Register, the United States Department of Labor’s (USDOL) Occupational Safety & Health Administration (OSHA) issued a notice announcing that a webinar will be held on November 10th from 4 PM to 5:30 PM Eastern Standard Time (EST) addressing implementation issues surrounding Executive Order 13650. This order was issued by President Obama on August 1st, 2013 and was intended to help improve the safety and security of the nation’s chemical facilities in light of ongoing potential threats to such installations. The new webinar will present a progress report on the response to the order. The webinar will accommodate up to 250 participants. Interested parties may wish to review the webinar’s schedule and agenda at the link below:
For those interested, here is a link to OSHA’s web page detailing the original Executive Order which the webinar is in reference to:
Labelmaster is a full service provider of goods and services for the Hazardous Materials and Dangerous Goods professional, shippers, transport operators, and EH&S providers. See our full line of solutions at http://www.labelmaster.com.
Maintaining compliance with Dangerous Goods regulations doesn’t stop with packaging and labeling. Shippers need to be aware of placarding requirements before putting their shipments into commerce. This infographic provides a brief overview of the regulations governing the use of placards on trucks and trains.
Contact Labelmaster today to learn more about these and other important DG topics.
Posted in Infographics
Tagged Dangerous Goods, freight containers, hazard class, hazard classes, hazmat shipping, labeling dangerous goods, Labelmaster, Packaging, placarding, regulatory experts, shipping regulations, Spacemaster, Spacemaster flip placard system, square-on-point placards, transport vehicles, UN identification numbers
As part of its ongoing effort to harmonize Hazardous Materials Regulations; 49 CFR Parts 171–180 (HMR) with international standards, PHMSA published the HM-215M Notice of Proposed Rulemaking (NPRM) on August 25, 2014. The comment period for these proposed changes lasts until October 24, 2014, and you can read our expanded coverage of the NPRM announcement here.
PHMSA publishes these proposed changes every two years to help US companies remain competitive in the international Dangerous Goods (DG) shipping business. The goal is to simplify compliance across international borders and multiple modes of transportation while maintaining public safety. The proposed amendments will help align the HMR with the latest editions of:
- The United Nations Model Regulations on the Transport of Dangerous Goods (18th revised edition)
- The International Maritime Dangerous Goods Code (IMDG) Amendments 37–14
- The International Civil Aviation Organization Technical Instructions on the Safe Transport of Dangerous Goods (ICAO TI) 2015–2016 edition
These proposed changes con potentially affect any company shipping DG, both in the US and internationally, which is why it’s important to review the NPRM and provide feedback. Some of the more significant proposals in HM-215M include:
- Multiple amendments to the §172.101 Hazardous Materials Table (HMT) to update proper shipping names, hazard classes, packaging groups, bulk packaging requirements, passenger and cargo aircraft maximum quantity limits and new special provisions
- A proposal to revise and add vessel stowage codes to standardize segregation requirements
- An exception for environmentally hazardous substances, including marine pollutants, in quantities not exceeding 5 liters or 5 kilograms from the HMR in §171.4
- New definitions in section 171.8 including “bundle of cylinders,” “large salvage packaging,” “neutron radiation detector,” “non-bulk packaging” and a direction to §173.115 for the definition of “absorbed gas”
- Changes for markings, labels and placard specifications for OVERPACK and SALVAGE
- Additional harmonization of lithium battery requirements beyond the HM-224F final rule: The proposal would harmonize with the latest version of ICAO TI by requiring a “CARGO AIRCRAFT ONLY” label on packages containing small lithium metal batteries not packed in or with equipment
Keeping up with the ever-changing world of DG shipping regulations isn’t easy, but it’s a responsibility we all share to ensure every DG shipment arrives safely and without complications. And Labelmaster is here to help you stay on top of the latest developments.