Learning a new transport regulation is tough. Even if you are familiar with other modes, learning the intricacies of a new one is difficult. In our courses, we spend a good deal of time going over a basic shipping descriptions (ISHP) and breaking down each part of it. Time is also spent on UN versus ID numbers, proper shipping names, hazard classes and packing groups. We also bring in the List of Dangerous Goods (LDG) and talk about where to find the ISHP. This leads to a discussion on technical names, aircraft types and other symbols shown in the LDG. Eventually we land on the topic of Special Provisions in Column M. We explain these are additional requirements for any given entry or as we like to call it – the curve balls. Some are helpful and relieve parts of the regulation while others complicate it.
Note – If you don’t understand the terms used in the above paragraph, you may need training.
IATA added some new Special Provisions a few years ago that cause additional stress for new shippers. We are referring to the A800 series. There are 5 special provisions starting with A801 and going up to A805. So, what is the big deal with these and new shippers? If we take a moment to look at each one, you’ll see why someone new to handling and transporting dangerous goods would be easily frustrated or confused.
Special Provision A801:
- Regulatory Text – A technical name is not needed for this entry if it is a controlled substance and a national law or international Convention prohibits its disclosure (see 4.1.2.1(d)).
- UN numbers impacted – This applies to all packing groups of UN1544 and UN3140 for Alkaloids.
- Possible Issue – Those two entries have the star symbol beside them in the LDG indicating a technical name(s) is needed. However, A801 tells us a technical name isn’t needed “if it is a controlled substance”. It then never really defines or describes what a controlled substance is.
- Helpful hint – Some examples of alkaloids are caffeine, codeine, cocaine and morphine. It makes sense not to list those as technical names then because it could attract some unwanted attention to your shipment.
Special Provision A802:
- Regulatory Text – Notwithstanding the absence of a packing group in column E, substances and articles assigned to these entries must be packed in UN Specification packagings that meet packing group II performance standards. This does not apply when aerosols are prepared for transport in accordance with the limited quantity provisions or for lithium batteries prepared in accordance with Section IB of Packing Instructions 965 or 968.
- Note: For the purposes of identification and documentation the packing group as shown in Table 4.2 applies and is to be used in the completion of the Shipper’s Declaration, regardless of a packaging required to meet a higher packing group performance standard as indicated above.
- UN numbers impacted – Multiple without an assigned Packing Group
- Possible Issue – Many believe that if there is no packing group listed in the LDG, it means UN Specification Packaging is not needed and that any additional information needed for picking packaging would be in the packing instructions. However, A802 requires a shipper to use UN rated packaging that meets Packing Group II level standards. There is more in the packing instruction therefore you must read the notes carefully! Despite having packaging that meets level II, it does not change the Packing Group in the LDG. Shipper’s do not list the II on the shipper’s declaration.
- Helpful hint – Your UN Specification Packaging must have an X or Y as part of its UN specification code and the shipping description is exactly what the List of Dangerous Goods indicates it is with no changes. In most, if not all cases, this packaging requirement will be listed in the actual packing instruction.
Special Provision A803:
- Regulatory Text – Notwithstanding the assignment of a packing group III in column E, substances assigned to these entries must be packed in UN Specification packagings that meet packing group II performance standards. This does not apply when the substances are prepared for transport in accordance with the limited quantity provisions.
- Note: For the purposes of identification and documentation the packing group as shown in Table 4.2 applies and is to be used in the completion of the Shipper’s Declaration, regardless of a packaging required to meet a higher packing group performance standard as indicated above.
- UN numbers impacted – Multiple with Packing Groups I, II, or III assigned.
- Possible Issue – Here the focus is on materials assigned to Packing Group III. New shippers will then choose to use a UN Specification Packaging with a Z as part of the code. However, A803 requires a shipper to use packaging that meets Packing Group II level standards. In essence, more secure packaging. But, you are still required to list the III on the shipper’s declaration on your paperwork.
- Helpful hint – Your UN Specification Packaging must have an X or Y as part of its code. The shipping description will maintain its III for the packing group which is exactly what the LDG indicates it is. In most, if not all cases, this packaging requirement will be listed in the actual packing instruction.
Special Provision A804:
- Regulatory Text – Notwithstanding the assignment of a packing group III in column E, substances assigned to these entries must be packed in UN Specification packagings that meet packing group I performance standards.
- For the purposes of identification and documentation the packing group as shown in Table 4.2 applies and is to be used in the completion of the Shipper’s Declaration, regardless of a packaging required to meet a higher packing group performance standard as indicated above.
- UN numbers impacted – UN2803 Gallium and UN2809 Mercury.
- Possible Issue – Again, the LDG tells us the Packing Group is III meaning for all other cases you should use UN Specification Packaging with a Z as part of the code. However, A804 requires a shipper to use packaging that meets Packing Group I level standards. A much more secure packaging than one would think is needed. And, you are still required to list the III on the shipper’s declaration on your paperwork.
- Helpful hint – Your UN Specification Packaging can only have an X as part of its code. The shipping description will maintain the III for the packing group as the LDG says. Again, this packaging requirement will be listed in the actual packing instruction.
Special Provision A805:
- Regulatory Text – Notwithstanding the requirement to package UN 1845 in accordance with Packing Instruction 954, Carbon dioxide, solid (dry ice) may be placed directly within an overpack that meets the requirements of Packing Instruction 954 to cool other dangerous goods. The other dangerous goods must be packaged in accordance with the relevant packing instructions. See Figure 8.1.J.
- UN Numbers impacted – UN1845 Dry Ice or UN1845 Carbon dioxide, solid
- Possible Issue – When dry ice is used as a coolant for dangerous goods, Packing Instruction 954 tells a shipper to put the dry ice inside the UN packaging. This provision though allows you to put the package into an overpack and then put the dry ice AROUND it. Both the dry ice and the package are in the overpack but not in the same package.
- Helpful hint – Anytime dry ice is used for air shipments, there are going to be some uniqueness. Take time to fully understand the packaging and documentation for dry ice on its own before using it as a coolant. IATA provides a great checklist specifically for dry ice shipments. They are found at the back of the IATA or for free download in multiple languages at https://www.iata.org/en/programs/cargo/dgr/download/.
Special Provision A806:
- Regulatory Text – Subsidiary hazard class or division number(s) must be shown on the Shipper’s Declaration where an article contains more than one dangerous goods or the dangerous goods has subsidiary hazard(s) shown in Table 4.2. The assignment of the primary and subsidiary class or division must be determined as set out in 3.12.5 and 3.12.6.
- UN numbers impacted – Many with a proper shipping name that starts with “articles containing”.
- Possible Issue – Because these materials are articles, it can be difficult to classify them. Be sure to read the details in 3.12.5 and 3.12.6 so as not to miss any possible subsidiary hazards. Ultimately it is the shipper’s responsibility to classify and identify materials appropriately.
- Helpful hint – Many of these “articles” are forbidden for air transport. A few may be transported on a cargo aircraft with prior approval if the requirements of Special Provision A2 are met. Always rely on test data, safety data sheets, and experience with products before making final decisions on proper shipping names.
Special Provision A807:
- Regulatory Text – This entry must not be used for Disilane or other pyrophoric gases.
- UN numbers impacted – UN1954 Compressed gas, flammable, n.o.s. and UN3161 Liquefied gas, flammable, n.o.s.
- Possible Issue – Again, this is a classification and identification issue. Since UN1954 and UN3161 are somewhat generic in nature, IATA wants to be sure the correct proper shipping name is chosen for any given material.
- Helpful hint – Always rely on test data, safety data sheets, and experience with products before making final decisions on proper shipping names and which entry of the LDG used.
Take heart shippers everywhere. The more you work within a transport regulation and specifically for your products, the easier it gets.
At Hazmat University, we offer accurate and latest online hazmat training courses that cover a wide range of information – including discussions on special provisions and their requirements – and can make it easier for you to comply with all the necessary regulations.
We offer training courses for hazmat handling and shipping by ground, air, as well as vessel. We also offer multi-modal training courses that cover all the relevant regulatory requirements from Title 49 of the Code of Federal Regulations (49 CFR), the International Air Transport Association (IATA), the International Civil Aviation Organization (ICAO), and the International Maritime Dangerous Goods (IMDG) Code.
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Call us today at 844-769-2815 or get in touch with us online to place your order or to explore what kind of initial or recurrent online hazmat training course may be appropriate for your career needs.
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