Regulatory Updates, January 2014
Keeping current with your training certification is only part of your responsibilities as a Hazmat/ DG shipper. Staying abreast of any relative changes which might affect your business is equally as important.
Imagine you received your initial shipping DGs by air compliance training and the following year, the regulations have a new mandatory requirement that previously didn’t exist and wasn’t covered in your initial training. The air regulations (ICAO) states recurrent training must be provided with 24 months. Typically most shipper’s find out the hard way if their consignment is non-compliant by having their shipment refused and are left in a quandary as to why
For domestic transportation only, checking with the latest version of the domestic regulations (CFR49) is relatively easy. Simply go on line to the Gov’t Printing Office (GPO) website and checking the electronic version. Here’s the link http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&tpl=/ecfrbrowse/Title49/49tab_02.tpl or go to the DOT’s Pipeline and Hazardous Materials Safety Administrations (PHMSA) website and click on the regulation hyperlink. I would strongly suggest cutting & pasting this to your browser`s favorites.
Shipping by air is a little more complicated, as ICAO and IATA don’t have electronic versions. They do publish them and are available, you just need to know where to look.
Concerning the International Civil Aviation Organization you need to know their regulations are found in the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air.This publication, commonly called “ICAO’s Technical Instructions” is produced biennially and is now in it’s second year (2013/2014). These regulations are the basic legal requirements for shipping dangerous goods, internationally, by air. There have been 3 addendums and 3 corrigendums since it first published in January 2013. All 6 changes can be found here http://www.icao.int/safety/DangerousGoods/Pages/default.aspx
As most airlines (operators) are members of the International Air Transport Association (IATA), their regulations for carrying dangerous goods, called the DGR, incorporates the ICAO TI as it’s basis. So there is nothing in the DGR that is less restrictive than the Technical Instructions. If you have been trained using the IATA DGR you’ll know that the pointing finger in the margins means that particular part of the regulation is in addition to the ICAO TI regulations. IATA publishes it’s DGR annually and even though their regulations aren’t used as a legal reference the fact remains it’s tricky to work in the industry without having them as a reference. These days air transport is a fragile business with operators and their businesses changing frequently. Interlining would be a major headache without this common reference.
As I spoke about in my last newsletter, the current price for the DGR ($275.00) is now getting critical and I see as a major non-compliance issue with shipper’s cutting budgets. There is little change from the ICAO regulations as of last month other than what is mentioned above, however there are still changes that you need to verify and see if they affect your operation. IATA DGR 55th Edition addendum 1
For transportation by vessel The IMDG Code has a unique sequence for compliance. The current edition, even though it’s called the 2012 Edition incorporating amendment 12-36, actually became mandatory this year (2014). It was introduced last year where shippers could voluntary comply. So there is a one year overlap from the previous edition. The IMO had one change last month December, 2013 IMDG Code Errata & Corrigenda Amendment 12-36
Regulatory compliance is not just about training it also requires shippers staying vigilant on the regulatory changes that might affect them as well. If this is something you feel is too cumbersome for your particular business feel free to contact me and discuss how we can assist.