[Nhcoll-l] New headache (solved)

Mon Jul 2 10:16:13 EDT 2018

ICAO is not airlines, but the internationally recognised UN body 
governing civil air aviation rules (Convention on International Civil 
Aviation). They stipulate dangerous good regulations on 
international/intergovernmental level. Some countries recently decided 
that they would discontinue with UN regs, but as long as this is not 
glued into national laws (i.e. the Internationally accepted ICAO rules 
no longer apply in a given state and this state discloses itself from 
international air traffic), this international agreement persists.

https://www.icao.int/about-icao/History/Pages/icao-and-the-united-nations.aspx

IATA is a rip-off of the UN-ICAO regs, and the a handy business model of 
the association of airlines to resell their expensive handbook on yearly 
basis.

A180 allows you to sell-train to be compliant; so yes, you need to be 
(self-) trained, but you no longer must be IATA-certified (e.g. we 
offered such trainings repeatedly at SPNHC conferences).

No longer are initial IATA certification and yearly IATA 
requalifications needed (as required under previous exempted quantities 
shipping). Training & requalifications are another excellent business 
model by the way: let others pay to re-qualify to your copied rules on 
yearly basis. We are happy to have escaped from this (thanks to Andy's 
enormous efforts!)

Cheers
Dirk

Am 02.07.2018 um 15:52 schrieb Ellen Paul:
>
> Thanks, Dirk, but that is IATA (airline restrictions). Not TSCA, which 
> is a U.S. law - Toxic Substances Control Act and entirely separate 
> from IATA.
>
> That being said - I agree entirely that it is a good idea to carry a 
> copy of the IATA/ICAO standard with you.
>
> As I recall (and Andy can confirm) it is not just packaging and 
> labeling. Don't you also have to be trained and certified? In which 
> case, talk to the shipping dept at your institution because their 
> staff are generally trained and certified.
>
> Ellen
>
> Ellen Paul
> Ellen Paul
> Executive Director
> Ornithological Council <https://birdnet.org/>
> Providing Scientific Information about Birds
>
> On 7/2/18 9:42 AM, Dirk Neumann wrote:
>> 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:
>> http://www.zsm.mwn.de/ich/
>>
>> ---------
>>
>> 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)
>>
>> Visit our section at:
>> http://www.zsm.mwn.de/ich/
>>
>>
>>
>>
>>
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>>
>> _______________________________________________
>> NHCOLL-L is brought to you by the Society for the Preservation of
>> Natural History Collections (SPNHC), an international society whose
>> mission is to improve the preservation, conservation and management of
>> natural history collections to ensure their continuing value to
>> society. Seehttp://www.spnhc.org  for membership information.
>> Advertising on NH-COLL-L is inappropriate.
>
>
>
> _______________________________________________
> Nhcoll-l mailing list
> Nhcoll-l at mailman.yale.edu
> https://mailman.yale.edu/mailman/listinfo/nhcoll-l
>
> _______________________________________________
> NHCOLL-L is brought to you by the Society for the Preservation of
> Natural History Collections (SPNHC), an international society whose
> mission is to improve the preservation, conservation and management of
> natural history collections to ensure their continuing value to
> society. See http://www.spnhc.org for membership information.
> Advertising on NH-COLL-L is inappropriate.

-- 
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:
http://www.zsm.mwn.de/ich/

---------

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)

Visit our section at:
http://www.zsm.mwn.de/ich/

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