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Shipping Under Requirements of International (modal) Regulations

Shipping Under Requirements of International (modal) Regulations. North American and International Shipments . North America. International. Relationship between International Regulations and DOT Regulations. UN OECD. US Gov’t. TDG (transport). GHS (workplace). OSHA (workplace).

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Shipping Under Requirements of International (modal) Regulations

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  1. Shipping Under Requirements of International (modal) Regulations

  2. North American and International Shipments North America International

  3. Relationship between International Regulations and DOT Regulations UN OECD US Gov’t TDG (transport) GHS (workplace) OSHA (workplace) DOT (transport) Int’l Stds Land mode IMO (water mode) National Regulation (land mode) ICAO (air mode) Haz Mat FRA Regs FMCSR Regs IMO (water mode) ICAO (air mode) GHS = purple book TDG = orange book UN & DOT Regulations

  4. Questions to be Answered Prior to Shipping Dangerous Goods • To ship any material from one point to another, three questions must be answered. • Does the material I am shipping meet the definition of a dangerous good ? • What mode of transportation will be used? • What carriers, forwarders or contractors will be used?

  5. A Shipping Process

  6. The Compliance Equation Compliance w/ International Regulations Compliance w/ DOT Haz Mat Regulations Total Compliance = +

  7. The Compliance Equation Compliance means: Compliance with International Regulations Compliance with DOT Haz Mat Regulations AND because: DOT Regulations and International Regulations are not identical.

  8. The Compliance Equation Compliance means: Compliance with AND Compliance with TDG Regulation IMDG Code ICAO Technical Instructions/ IATA DG Regulations IAEA Regulations Subpart C of Part 171 —Authorization and Requirements for the Use of International Transport Standards and Regulations

  9. The Compliance Equation Compliance means: Compliance with Compliance with AND §171.12, North American Shipments §171.22, Authorization to use ICAO, IMDG, TDG, IAEA §171.23, HM& Packaging Requirements §171.24, Use of ICAO §171.25, Use of IMDG §171.26, Use of IAEA TDG Regulation ICAO/IATA Regulations IMDG Code IAEA Regulations

  10. North American Shipments Canada USA Mexico

  11. North American Shipments • North American shipments means shipment to, from, or within the United States from Canada or Mexico • Imports from Canada and Mexico • Goods transiting the United States from one destination in Canada or Mexico to another (e.g., shipment from Montreal, Quebec to Sarnia, Ontario or Ciudad Juarez to Tijuana, Mexico) traveling via the US Interstate Highway system) • Export shipments from the USA to Canada or Mexico

  12. Authorization to Use Canada TDG Regulations (§171.12) • A hazardous material transported from Canada may be offered or transported under Transport Canada TDG Regulations provided the requirements in §171.22 and §171.23, as applicable, and §171.12 are met • A cargo tank motor vehicle, portable tank or rail tank car authorized by the Transport Canada TDG Regulations may be used provided it conforms to the applicable requirements of §171.12 • The requirements in parts 172, 173, and 178 of this subchapter do not apply for a material transported iaw Transport Canada TDG Regulations if all other requirements of this subpart and the TDG Regulations are met, unless specifically provided in subpart A to Part 171

  13. Use of Cylinders (Canada ) (§171.12) • Cylinders • When a DOT or UN cylinder must be used, cylinders authorized in accordance with (“iaw)” the TDG may only be used if it corresponds with a: • DOT specification • Transport Canada specification cylinder • CTC a specification manufactured, originally marked and approved in accordance with the CTC regulations & conforming to TDG Regulations • UN Standard • Marked with “CAN” as country of manufacture or approval • Manufactured, inspected and tested “iaw” DOT Specification or UN STD per Part 178 • Cylinders not conforming to these requirements must meet the requirements in §171.23.

  14. Use of Cargo tanks, Portable Tanks, Rail Cars (Canada ) (§171.12) • The use of Cargo tanks, portable tanks or rail tank cars are authorized by the TDG subject to limitations • Cargo tanks, portable tanks or rail tank cars are authorized by the TDG • Packaging is equivalent to one authorized for HM according to the HMT in 172.101 • Conforms to: • applicable section(s) of part 173, Bulk packaging for the HM • assigned bulk packaging special provisions (B codes, and T and TP codes) • qualified for continued service in accordance with Part 180 or the TDG • periodic retests and inspections required by 49 CFR 173.31, 173.32 and 173.33

  15. International Shipments

  16. Authorization & Use of International Standards and Regulations (Subpart C of Part 171 ) • Dangerous Goods offered or transported in accordance with international standards and regulations must be in conformance with the applicable international standard or regulation; and • Must conform to all applicable requirements of 171.22 • Must conform to all applicable requirements of §171.23, §171.24, §171.25, and §171.26

  17. Applicability of DOT HMR to International Shipments §171.22 • Materials excepted from regulation • material designated as Haz Mat under 49 CFR, but excepted from or not subject to the international transport standards and regulations must be transported in accordance with 49 CFR (e.g., ¶ 1.16 of the TDG Regulations excepts from regulation quantities of DG less than or equal to 500 kg gross transported by rail). • Forbidden materials. • a forbidden material or package as designated in 49 CFR must be transported in accordance with 49 CFR

  18. General Requirements International (import) Shipments (§171.22) • Shipments entering the USA are subject to the following requirements: • Shipper registration (with DOT) under Part 107 (as applicable) • Foreign domiciled shipper exception [See 107.606(a)(7)] • Incident Reporting requirements under §171.15 & §171.16 (incidents occurring in USA) • Emergency Response Information required by §172.600 • Driver & HM Employee Training Requirements – §172.700 • Security Plan Requirements for carriers – §172.800 • For Export Shipments, packaging requirements in Subpart A of Part 173 (Packaging & Package requirements)

  19. General Haz Mat Requirements International Regulations (§171.22) • Hazardous Materials are always regulated by DOT regulations – even international shipments !!! • HMR authorize regulations of Dangerous Goods under international regulations • Haz Mat meeting the definition of Haz Mat under DOT but not regulated under International Regulations is regulated under DOT • Forbidden materials or DOT packages must be transported in accordance with 49 CFR • Shipping papers requirements • Conformance with Int’l and/or DOT regulations • Include Shipper certification (as applicable) • Package marking • Conformance with Int’l and/or DOT regulations

  20. Packaging Requirements for International Shipments §171.22 • Bulk packaging must conform to 49 CFR with the exception of UN Portable Tanks and IBCs [§171.25(c)] • Export packaging must meet basic 49 CFR packaging requirements • Cylinders must meet conditions in §171.23(a) • Cargo transport units that contain marine pollutants should display the marine pollutant mark even if the packages are not required to display the mark • PIH (TIH) materials must be • Packaged in accordance with 49 CFR • Marked, labeled, and placarded as “inhalation hazard”NOTE: IMDG labels may be used if packages are in closed transport unit

  21. Bulk containers & IBCs

  22. Shipping Paper Requirements §171.22 • Prepare shipping paper information in accordance with subpart B of Part 172 • in English, or • a language other than English, in order to dually comply with 49 CFR and the regulations of a foreign country • Retain a copy of the shipping paper or an electronic image for the time period specified in §172.201(e) • Provide shipper’s certification to initial US Carrier as shipper or through the forwarding agent at the place of entry • For hazardous substances, show the “RQ” descriptor on shipping papers • Identify marine pollutants on shipping papers [§171.23(b)(7)] • Identify “toxic-inhalation hazard” (TIH) materials [§171.23(b)(10)]

  23. Required Information Shipping Papers • Number and kind of packages • Indication of quantity of dangerous goods • Minimum flashpoint (IMDG) • Subsidiary hazards • Appropriate descriptors for certain dangerous goods • Marine pollutant descriptor • Waste designator • Elevated temperature descriptor - “HOT” • Control/Emergency Temperature ( • Inhalation hazard descriptor - PIH [§171.23(b)(10)] • RQ descriptor for hazardous substances [§171.23(b)(7)]

  24. Additional Requirements • Cargo transport units that contain marine pollutants should display the marine pollutant mark even if the packages are not required to display the mark. OBSOLETE

  25. Package Marking Requirements § 171.22 • Each person who provides for transportation or receives for transportation a dangerous good must: • Prepare package markings in accordance with subpart C of Part 172 in English, or • Prepare package markings in both English and a language other than English, in order to dually comply with 49 CFR and the regulations of a foreign country

  26. Additional Requirements for International Shipments §171.22 • Emergency response information must be provided for shipments as required by Subpart G/§172.600 • Haz Mat Training requirements must be must • ICAO/IATA Training – 2 year recurrent training • IMDG Training – 3 year recurrent training • Security plans and training

  27. Emergency Response Requirements

  28. DOT Requirements Differing from ICAO, IMDG Code, TDG and IAEA (§ 171.23) • Shipments offered for transportation or transported under the ICAO, IMDG, TDG and IAEA regulations, must conform to the requirements of 171.23, as applicable for: Cylinders Aerosols Chemical Oxygen Generators Explosives (Approval/marking) Hazardous Substances (SP/Marking) Hazardous Wastes (Manifest/Retention) Marine Pollutants Organic peroxides Toxic Inhalation Materials (TIH) Radioactive Materials Self Reactive Materials

  29. TIH Labelling Requirements Under § 171.23 • A package transported in accordance with the TDG in a closed transport vehicle or freight container, may be have affixed to the package a label or placard conforming to the TDG for a “Class 2.3” or “Class 6.1” in lieu of the POISON GAS or POISON INHALATION HAZARD label or placard, as appropriate • No reciprocity between TDG Regulations & DOT’s HMR for Division 2.3 and Division 6.1 materials or In lieu of or

  30. TIH Placarding Requirements (§ 171.23) • A package transported in accordance with the TDG in a closed transport vehicle or freight container, • may have affixed a label or placard conforming to the TDG for a “Class 2.3” or “Class 6.1” in lieu of the POISON GAS or POISON INHALATION HAZARD label or placard, as appropriate • may also be placarded in accordance with the appropriate TDG Regulations in addition to being placarded with the POISON GAS or POISON INHALATION HAZARD placards • The transport vehicle or freight container must be marked with the ID # for the DG, regardless of the total quantity contained in the transport vehicle or freight container or In lieu of or

  31. Hazardous SubstancesGeneral Requirements § 171.23 • Proper shipping name of a hazardous substance must • identify the hazardous substance by name, or • name of the substance must be entered in parentheses in association with the basic description • Shipping papers & package markings must identify the proper shipping name of the hazardous substance • Shipping papers & package markings must identify at least 2 hazardous substances with lowest RQ’s when the material contains 2 or more hazardous substances • A material meeting the definition of a hazardous substance must indicate the letters “RQ” on the shipping paper either before or after the basic description [see §172.203(c)] • Package markings must show the letters “RQ” on the package in association with the proper shipping name or the identification number displayed [see §172.324]

  32. Hazardous Substances/Hazardous Wastes§ 171.23 • The general requirements for hazardous substances must be met (refer to previous) • In addition to the general requirements: • Shipping papers and packages must include the word “Waste” immediately preceding the proper shipping name, AND • The shipping paper must be retained by the shipper & each carrier for three years after the date the material is offered for transportation • A Hazardous Waste Manifest must be completed in accordance with §172.205

  33. Hazardous Substances /Hazardous Wastes§ 171.23 (cont’d) If the hazardous substance meets the definition for a hazardous waste, the waste code (e.g., D001), may be used to identify the hazardous substance The shipping paper and the package markings must identify at least two hazardous substances with the lowest RQs when the material contains two or more hazardous substances; and The letters “RQ” must be entered on the shipping paper either before or after the basic description, and marked on the package in association with the proper shipping name for each hazardous substance listed.

  34. Hazardous Substances Shipping Papers (Sample document)

  35. Hazardous Substances Package Marking (RQ) 172.324 (b)

  36. Radioactive Shipments (§ 171.23) • Highway Route Controlled Quantities (HRCQ) must be shipped in accordance with §172.203 • (d)(4) The category of label applied to each package in the shipment must be noted on the shipping paper. For example: "RADIOACTIVE WHITE-I." • (d)(10) The words "Highway route controlled quantity" or "HRCQ" must be entered in association with the basic description • Each motor vehicle used to transport a package of HRCQ must have the required RADIOACTIVE warning placard placed on a square background as described in §172.527.

  37. Radioactive Shipments - § 171.23 (cont’d) • HRCQ quantities must be shipped in accordance with:173.22(c): • Prior to each shipment the shipper shall notify the consignee of the dates of shipment and expected arrival. • Notify each consignee of any special loading/unloading instructions prior to first shipment. • For any shipment of irradiated reactor fuel, the shipper shall provide physical protection in compliance with a plan established under: • Requirements prescribed by the U.S. NRC, or • Equivalent requirements approved by the AA.

  38. Shipments Using ICAO Technical Instructions 49 CFR § 171.24 • Shipments MUST BE shipped all or partly by aircraft • Haz Mat shipped in accordance with ICAO Technical Instructions (or IATA DGR) • Conform to requirements of §171.22 • Conform to applicable requirements • Parts 171 and 175 of the HMR • Quantity limits in ICAO Technical Instructions • Meet specific (additional) requirements if the HM package is • Batteries • Nonspillable, wet • Primary Lithium batteries and cells • Prototype lithium batteries • Oxygen, compressed or one of the oxidizing gases listed below • CO2 and oxygen mixtures • Oxidizing gases, n.o.s. • Nitrogen trifluoride (NF3) • Nitrous oxide (N2O) • TIH materials – see also §171.23

  39. Shipments Using IMDG Code49 CFR § 171.25 • Shipments MUST BE shipped all or partly by or vessel • Haz Mat shipped in accordance with IMDG Code • Conform to requirements of §171.22 • Conform to applicable requirements • Parts 171 and 176 of the HMR • Stowage & segregation requirements of IMDG or the HMR • Marking requirements for lithium batteries • Meet specific (additional) requirements if the HM package is • UN portable tank • TIH Material (see also §171.23) • Portable tank on transport vehicle while connected to motive power • Classed, labeled, marked, placarded iaw IMDG Code

  40. Contact Information • Joe Evans • Joseph.Evans@dot.gov • Tel. 443-865-9929 • Peter Kramer • Pete.Kramer@dot.gov • Tel. 405 954-4583 • Dave Sonnemann • Dave_sonnemann@praxair.com • Tel. 203-827-2294

  41. Any Questions?

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