[Nhcoll-l] New headache (solved)

[Dirk Neumann]

Hi all,

it might be worth to add a second bit of clarification:

IATA/ICAO A180 compliant packing says if non-infectious specimens, such 
as .... containing small quantities of UN1170 (ethanol, ethanol 
solution, ethyl alcohol or ethyl alcohol solution), UN1198 (formaldehyde 
solution, flammable), UN 1987 (alcohols, not otherwise specified) or 
UN1219 (isopropyl alcohol) *are not subject to these Regulations* 
providing the following packing and marking requirements are met ..."

The words are /not subject to these Regulations/ are decisive: despite 
their identification as UN-rated hazardous materials, they are not 
classified as such, i.e. they are not considered dangerous goods at all. 
This exemption stands and falls with the correct packing. ICAO/IATA is 
an international UN agreement, excepted in all countries (ICAO), and by 
all airlines (IATA).

If you are travelling and have such materials in your hand-carried or 
checked luggage, it is advisable to take copies of IATA/ICAO A180, and 
at least a copy of the limitations table (2.3A) from the IATA handbook 
with you. Respective sections in ICAO and IATA are interchangeable, the 
legally binding one is ICAO.

All the best
Dirk

Am 02.07.2018 um 15:00 schrieb Ellen Paul:
>
> One call to EPA help line is all it took. Well, that and knowing what 
> questions to ask.
>
> So actually you need a certification for ethanol (I will look up SDS 
> later to see if it is on the TSCA inventory). But there is an express 
> exemption for R&D.
>
> https://www.law.cornell.edu/cfr/text/40/720.36
>
> So you still need the certification:
>
> http://ftn.fedex.com/forms/TSCA_Certification.pdf
>
> But it is the "positive" certification. And they said for product 
> description, write, "R&D exemption."
>
> That easy.
>
> I would advise everyone to have this form with them for hand-carries 
> and in the FedEx pouch for shipping. It is one page, easy to complete, 
> and better to have it and not need it than need it and not have it.
>
> It is most likely going to keep coming up for anyone who has to have 
> an APHIS import permit and certificate of treatment, because ethanol 
> and SDS are probably the most commonly used of the approved treatment 
> methods. So the CBP agricultural specialist reads your certificate of 
> treatment and then sees that you have a TSCA-listed substance and 
> requires this form. But even if you don't need an APHIS import and 
> certificate of treatment, it makes sense to include this form with 
> your hand-carries and shipped imports.
>
> Are you sure you don't think the OC is worth $20 to you?
>
> Thanks.
>
> Ellen
>
> Ellen Paul
> Ellen Paul
> Executive Director
> Ornithological Council <https://birdnet.org/>
> Phone (301) 986 8568
> Providing Scientific Information about Birds
>
>
>
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-- 
Dirk Neumann

Tel: 089 / 8107-111
Fax: 089 / 8107-300
*new email: neumann(a)snsb.de*

Postanschrift:

Staatliche Naturwissenschaftliche Sammlungen Bayerns
Zoologische Staatssammlung München
Dirk Neumann, Sektion Ichthyologie / DNA-Storage
Münchhausenstr. 21
81247 München

Besuchen Sie unsere Sammlung:
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---------

Dirk Neumann

Tel: +49-89-8107-111
Fax: +49-89-8107-300
*new email: neumann(a)snsb.de*

postal address:

Bavarian Natural History Collections
The Bavarian State Collection of Zoology
Dirk Neumann, Section Ichthyology / DNA-Storage
Muenchhausenstr. 21
81247 Munich (Germany)

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