[NHCOLL-L:4576] More dangerous goods updates

Wed Oct 28 10:32:15 EDT 2009

Hi all

It has just come to my attention that DOT has amended their 49 CFR 173.4 regulations in two major ways that have implications for our shipping policies:

1.	They have added section 173.4b "De Minimus Exceptions" (latest e-CFR attached) which now excludes very small quantities of hazardous materials (in our case under 1ml of ethanol) from the regulations.  The implications of this are that if you can keep tissues, for instance, to under 1ml of fluid (and under 100ml total per package) then there are no dangerous goods requirements for the package.  This has limited application but is something to keep in mind.
2.	They have amended 173.4 to now follow IATA labeling criteria (latest e-CFR attached).  You are now required to use the red hatched label (as per IATA) for DOT (domestic) packages in place of the "This package conforms to 49 CFR 173.4".  However, it appears as if USPS has yet to adopt these changes (may just be that they are yet to update their Publication 52).  I have emailed my contacts at USPS for clarification and will let you know as soon as I hear.  Until then, we should continue to use "This package conforms to 49 CFR 173.4".  However, if you are sending packages domestically using FedEx or UPS then you are required to use the new labeling protocols.

As an aside, I recently received confirmation from my IATA contacts that we have been successful in our bid to have verbiage inserted into the IATA dangerous good manual (Section 2.7) exempting specimen packages from the regulations if packed according to 2.7.  The exact verbiage is yet to be drafted but will be along the lines of:

"Axxx                Museum specimens, such as specimens of mammals, birds, amphibians and reptiles, fishes, insects and other invertebrates containing small quantities of UN 1170, UN 1987 or UN 1219 are not subject to these Instructions provided the following packing and marking requirements are met: 

Specimens are:

1.       Wrapped in paper towel and/or cheesecloth moistened with alcohol or an alcohol solution and then placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30 mL; or

2.       Placed in vials or other rigid containers with no more than 30 mL of alcohol or an alcohol solution;

a)      The prepared specimens are then placed in a plastic bag that is then heat-sealed;

b)      The bagged specimens are then placed inside another plastic bag with absorbent material then heat sealed;

c)      The finished bag is then placed in a strong outer packaging with suitable cushioning material;

d)      The completed package is marked "scientific research specimens, not restricted special provision Axxx applies".

The words "not restricted" and the special provision Axxx must be provided on the air waybill when an air waybill is issued.

This will only come into effect in January 2011 but will ensure that, together with the DOT and USPS letters of interpretation that we have already received (attached), all packages, whether domestic or international, will no longer fall into the category of dangerous goods.  It will also allow 30ml of free liquid per RIGID internal package (insects and other fragile specimens can be sent in free liquid) and will also allow 95% ethanol (again, up to 30ml free liquid per RIGID internal package).  

This has far reaching implications - no training necessary (you can self train to pack), previously inaccessible countries will now be accessible, international mailing by USPS to select countries (based on the USPS International Mailing Manual), no labeling requirements, 30ml of free liquid per internal package, 95% ethanol acceptable etc.  It is my hope that this will ease the burden on the small to medium sized museums as well as the larger institutions both within the US and internationally (as most countries follow IATA with some exceptions).  This has been a long and arduous process of negotiation, started with our Dangerous Goods roundtable held in Oklahoma, but the light at the end of the tunnel is now blazing!!!

Any questions please let me know.

Andy

   A  :             A  :             A  :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<(((_°>
   V                V                V
Andy Bentley
Ichthyology Collection Manager/Specify Usability Lead
University of Kansas
Natural History Museum & Biodiversity Research Center
Dyche Hall
1345 Jayhawk Boulevard
Lawrence, KS, 66045-7561
USA

Tel: (785) 864-3863
Fax: (785) 864-5335
Email: ABentley at ku.edu       

   A  :             A  :             A  :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<(((_°>
   V                V                V 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20091028/7768546c/attachment.html 
-------------- next part --------------
A non-text attachment was scrubbed...
Name: DOT 173 4.pdf
Type: application/octet-stream
Size: 93160 bytes
Desc: DOT 173 4.pdf
Url : http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20091028/7768546c/attachment.obj 
-------------- next part --------------
A non-text attachment was scrubbed...
Name: DOT 173.4b.pdf
Type: application/octet-stream
Size: 78655 bytes
Desc: DOT 173.4b.pdf
Url : http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20091028/7768546c/attachment-0001.obj 
-------------- next part --------------
A non-text attachment was scrubbed...
Name: DOT letter of interpretation - Dec 22 2008.pdf
Type: application/octet-stream
Size: 37104 bytes
Desc: DOT letter of interpretation - Dec 22 2008.pdf
Url : http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20091028/7768546c/attachment-0002.obj 
-------------- next part --------------
A non-text attachment was scrubbed...
Name: USPS letter of interpretation.pdf
Type: application/octet-stream
Size: 93084 bytes
Desc: USPS letter of interpretation.pdf
Url : http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20091028/7768546c/attachment-0003.obj 