[NHCOLL-L:5110] RE: IATA Dangerous Goods 52nd Edition - INCLUSION OF SPECIAL PROVISION A180

Wed Dec 1 11:09:13 EST 2010

Dear Andy,

On behalf of members of SPNHC Council (and I am certain, of the entire SPNHC membership), I would like to congratulate you for this enormous accomplishment. No doubt, this was a long and painful process but the outcome will greatly benefit for years to come so many of us working in museums and universities in shipping fluid-preserved natural history collection specimens. 

I echo your thanks to IATA, DOT, FedEx, UPS, USPS and DHL for their important and essential contribution while acknowledging that you actually initiated this process and did much of the legwork to get these organizations to recognize our challenges as natural history collections professionals and to talk to each other and adopt the solution you are presenting today.  Bravo!

As you pointed out, these regulations become effective January 1st 2011 and should not be used before then.  I appreciate that you will be sending a reminder towards the end of the year. 

Also, your statement that we need "to know how to pack these packages" is particularly important if we do not want to comprise the work you accomplished in getting this exemption approved. Provision 180 clearly spells out how these specimens must be packaged and I suspect a "How To" guide will be published in the next SPNHC Newsletter.

Thanks again for all you've done on our behalf.

Sincerely,

Jean-Marc

Jean-Marc Gagnon, Ph.D.

President of the Society for the Preservation of Natural History Collections (www.spnhc.org <http://www.spnhc.org/> ) 

Lead Organizer of the 2010 SPNHC & CBA-ABC Joint Conference (www.spnhc-cba2010.org <http://www.spnhc-cba2010.org/> ) 

Chief Collection Manager / Gestionnaire en chef des collections

Invertebrate Collections / Collections des invertébrés

Canadian Museum of Nature / Musée canadien de la nature

P.O. Box 3443, Stn "D" / C.P. 3443, Succ. D

Ottawa, ON Canada K1P 6P4

T: 613-364-4066 / F: 613-364-4027

E/C: jmgagnon at mus-nature.ca <mailto:jmgagnon at mus-nature.ca> 

http://www.nature.ca <http://www.nature.ca/> 

P Thanks for thinking of the environment before printing! /

           Merci de penser à l'environnement avant d'imprimer! 

-----Original Message-----
From: owner-nhcoll-l at lists.yale.edu [mailto:owner-nhcoll-l at lists.yale.edu] On Behalf Of Bentley, Andrew Charles
Sent: 1 décembre 2010 09:50
To: NHCOLL-L at lists.yale.edu
Subject: [NHCOLL-L:5109] IATA Dangerous Goods 52nd Edition - INCLUSION OF SPECIAL PROVISION A180

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

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 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>         :
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