[NHCOLL-L:5109] IATA Dangerous Goods 52nd Edition - INCLUSION OF SPECIAL PROVISION A180

[Bentley, Andrew Charles]

Hi all

 

The long (and often painful) two and a half year odyssey of dangerous goods issues is finally coming to an end with the publication of the new edition of the IATA Dangerous Goods Manual (52nd Edition) recently.  This edition includes the A180 special provision that I worked on with IATA and DOT - see attached.  These regulations become effective January 1st 2011 and should not be used before then.  I will send a reminder towards the end of the year.

 

There are a number of positive benefits that this special provision affords us:

 

1.     No more training required.  You still need to know how to pack these packages (the irony being that packages still need to be packed as excepted quantity dangerous goods to qualify to be exempt!!) but you can self train to do this and do not need to pay for training.

2.     These shipments will now be exempt from dangerous goods status altogether which will allow us to ship these packages to and within more countries.

3.     Includes all natural history material (although certain types are listed in the first paragraph, the use of "such as" infers all types).

4.     This applies to ethanol, isopropyl and formalin (in concentration higher than 10%) - see extracted pages from dangerous goods table in attached.

5.     You are now allowed up to 30ml of free fluid in the internal bag and solid container (1 liter total per package).

 

Negatives (that I could not get them to budge on):

 

1.     Heat-sealing of bags is now a requirement (small inconvenience for the benefits).

2.     Still no carrying onto planes as carry-on or checked baggage.  There was no debate here given the complexities of TSA and Homeland security involvement.

 

However, the most important issue was whether FedEx, UPS and DHL would adopt this new special provision.  Without their support we would still not be able to ship using A180.  Again, I am grateful to my contacts at dangerous goods at all three carriers for their instant responses as below which indicate that they will all adopt this for shipments of specimens packaged in accordance with A180.

 

FedEx

 

"There is no Regulatory issue with FedEx that would delay a shipment.  We have communicated the upcoming changes in IATA with the field and are in the process of printing the 2011 guidance for FedEx Express personnel; however we will send additional communication concerning these shipments.  These shipments are not to be offered to any FedEx Office location for transit." -  Vivian Montgomery (Dangerous Goods Administration) - The last sentence refers to packages having to be collected and not offered to FedEx offices for shipping.

 

UPS

 

"We seem to have agreement regarding the air transportation of these items.  UPS accepts packages prepared in accordance with ICAO (IATA) requirements.  But one question has been raised regarding the allowance of this Special Provision by ADR for road movement.  I don't know if David Brennan knows if the acceptance by other modes was addressed, but we may want to get his opinion on this question.  This would be of concern for all carriers as harmony between the regulations for all modes is necessary for complete transportation cycles." - Brad Cook (Director, Dangerous Goods) - I will be working with IATA to ensure that all other forms of transport adopt A180 too.

 

DHL

 

"Effective January 1, 2011, provided the complete package is prepared in accordance with IATA/ICAO SP A180, DHL Express will accept these shipments worldwide without any restrictions or limitations.  Furthermore, customers are not required to be registered or approved to ship dangerous goods w/DHL Express.  Should you encounter any issues with DHL Express, please feel free to reach out to me directly or call our International Dangerous Goods Hotline at 1-866-817-3794." - Jerry Freeman (Manager, Dangerous Goods).

 

Along the way we have also resolved the FedEx dead animal policy that at one point made shipments of dead animal specimens unacceptable

 

Together with these IATA regulations, the letters of interpretation received from DOT and USPS for domestic transportation within the US and Canada (see attached) allow us to send such packages as non-dangerous goods domestically too.

 

I would like to thank all those at IATA, DOT, FedEx, UPS, USPS and DHL that have worked with me to make this a reality and hope that this assists those of us that regularly ship natural history specimens around the world.  As always I would welcome any feedback on problems or issues that folks encounter with any packages and will liaise with my contacts to try and resolve as many of these as possible.

 

Andy

 

    A  :             A  :             A  :
 }<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
    V                V                V
 Andy Bentley
 Ichthyology Collection Manager
 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 <mailto: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/20101201/e8a76fbf/attachment.html 
-------------- next part --------------
A non-text attachment was scrubbed...
Name: IATA Dangerous Goods 52nd Edition - SP A180.pdf
Type: application/octet-stream
Size: 252213 bytes
Desc: IATA Dangerous Goods 52nd Edition - SP A180.pdf
Url : http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20101201/e8a76fbf/attachment.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/20101201/e8a76fbf/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/20101201/e8a76fbf/attachment-0002.obj