from here to there: topics in transportation Steven CharleS hunt President, ShipMate, Inc. Back and Forth—Harmonization? Iwas not properly classified for transportation. I was comply if they keep changing the rules?Additionally, although there is a one-year transitiontime-to-time)? At first glance, I became really annoyed.How does the government expect shippers and carriers torecently received a phone call from a client thathad been shipping aerosols by vessel for years. Theyclaimed that their shipment was stopped because it shocked. I rushed back to the office to open the heavy fi- phase for compliance with the new IMDG Code, Amdt. berboard containing the latest versions of the International 36-12, many steamship lines have already begun to imple- Maritime Dangerous Goods (IMDG) Code, Amendment 36- ment the new Code. No surprise there, because the two 12. I had received five sets of the shiny new Code shortly previous Amendments, Amdt 34-08 and Amdt. 35-10, before the December holidays, but like most people, I was became mandatory shortly after being published and a caught up in the rush and didn’t open them until the first transitional period was not offered. week back in the office in the New Year. However, upon closer inspection, I see that there is, in fact, a one year transition period with the new IMDG Surprise, Surprise! Code. Compliance with Amdt. 36-12 is voluntary as of I threw Volume 1 aside and tore into Volume 2, scanning Jan. 1, 2013 and does not become mandatory until Jan. 1, the Dangerous Goods List (DGL) for UN1950, AERO- 2014. Whew—a reprieve! SOLS. When I finally came upon the page in question (p. As it turns out, the latest amendment of the IMDG 98), I was shocked! There was only one entry in the DGL Code actually hides all of the “fine print” in the Special for UN1950, AEROSOLS. The hazard class listed was Provisions within Chapter 3.3 of Volume 2. Although the Class 2. It seems as though the steamship line that refused previous Amendment (35-10) also listed the same Special the shipment may have been correct! Provisions, most people didn’t really pay any attention The previous edition of the IMDG Code contained to the finer details. Every different type of aerosol had its more than 20 different entries for UN1950, including own entry in the table and the class/division and subsid- iterations for Divisions 2.1 (flammable) and 2.2 (non- iary risk were clearly laid out. flammable), subsidiary risks of 6.1 (toxic) and 8 (cor- It is more critical than ever that you now actually read rosive), and every possible combination thereof. Also and understand the minutia within these Special Provi- included in Amendment 35-10 were entries for UN1950, sions. If you rely only on the Dangerous Goods List for the WASTE AEROSOLS. description, as the carrier did in this case, you may be in Seeing the consolidated classification and single entry violation of the U.S. DOT’s Hazardous Materials Regula- only in the new IMDG Code caused me to reflect back on tions and those standards for any country that requires a brief period of time where, during one or two iterations compliance with the IMDG Code. of the Code, limited quantities of aerosols were classified For example, Special Provision 63 of the IMDG Code and described as AEROSOLS, 2, UN1950, LTD QTY. clearly states that: I distinctly remember that the lack of a division (Class 2 vs. 2.1 or 2.2) created quite a stir among shippers and The division of Class 2 and the subsidiary risks carriers. Eventually, everyone became used to it and then depend on the nature of the contents of the aerosol in the next amendment, the divisions were broken out dispenser. The following provisions shall apply: again. 1. Class 2.1 applies if the contents include 85% by mass or more flammable components and the chemi- Closer Inspection cal heat of combustion is 30 kJ/g or more; Now, I’m wondering if we really are moving toward 2. Class 2.2 applies if the contents contain 1% by harmonization between countries and modes of trans- mass or less flammable components and the heat of portation, or if the International Maritime Organization combustion is less than 20 kJ/g; is going off on a tangent (which they have done from 3. Otherwise the product shall be classified as tested 30 Spray February 2013
feb combined corrected
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