January 2013
IMDG Amendment 36 Authorization and DOT HM215K and L Final
Rule updates
Harmonization Changes
International Maritime Dangerous Goods Code
Amendment 36 is authorized for use January 1, 2013 and becomes mandatory for
international water transportation of hazardous materials on January 1, 2014.
Remember that during the odd year of 2013, Amendment 35 or Amendment 36
of the IMDG Code may be used for international water transportation
of Hazardous Materials.
49CFR Shipping Paper Sequence Change
Effective January 1, 2013, Only the “new” hazardous materials shipping description sequence (ISHP) which lists
the UN Identification Number first (I) followed by the Proper Shipping Name (PSN) (S), Hazardous Class (H) and
Packaging Group (P), will be accepted by the carrier for any mode of hazardous materials transportation whether
domestic or international. This sequence is already the standard for the IMDG (water) and the ICAO (air)
regulations.
+35C
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January 2013
ORMD-Air
The U.S. Department of Transportation has phased out the ORM-D
classification for air shipments in harmonizing with the ICAO international
air regulations. The last day to ship packages that were properly classified
and marked as ORM-D-AIR is December 31, 2012. On January 1, 2013, no
new ORM-D AIR packages may be offered or accepted for transportation.
The replacement for this phased out ORM-D classification is the new air
limited quantity marking which is the black and white diamond with the “Y”
in the middle as (shown below) along with other applicable markings and
labels for air shipments of consumer commodity materials [49 CFR 172.315
(d)(2)]. Note that the international IATA Dangerous Goods Regulations never
recognized the “ORM-D AIR” hazard classification. Also, there are new
quantity limitations for this classification listed in 49CFR173.27.
New Cargo Aircraft Only (CAO) Label
Ensure that you comply with the new packaging labeling requirement for cargo moved by air. Use the new CAO
label with the words "Cargo Aircraft Only" at the top instead of the word "Danger".
This label is the only acceptable CAO label that can be used as of January 1, 2013.
Limited Quantities and ORM-D Shipments
The transitional provisions for the ORM-D exception has been extended until
December 31, 2020 for domestic highway, rail and vessel transportation. In
addition, the DOT in HM215K Final Rule reinstated the shipping paper exception for
cargo marked as ORM-D when shipped by vessel. Limited quantity exceptions are also
authorized for certain Division 1.4S explosives, compressed gases and.
certain fire extinguishers. We do not recommend that you go backwards but
that you continue to move towards the Limited Quantities exception due to the fact that
the international community and the industry are moving in that direction.
Packages Closure Instructions
Shipper who sells or transfers a packaging or closes and offers a package for
transportation must maintain manufacturer notification (including closure instructions)
for 90 days once a package is offered to the initial carrier.
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January 2013
New UN number additions to the hazardous materials table and dangerous list
There are 11 new additions to the hazardous materials table and dangerous goods list and many other changes in
the table.
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UN3497 Krill Meal - PGII
UN3497 Krill Meal - PGIII
UN3498 Iodine Monochloride, Liquid
UN3499 Capacitor
UN3500 Chemical Under Pressure, N.O.S.
UN3501 Chemical Under Pressure, Flammable, N.O.S.
UN3502 Chemical Under Pressure, Toxic, N.O.S.
UN3503 Chemical Under Pressure, Corrosive, N.O.S.
UN3504 Chemical Under Pressure, Flammable, Toxic, N.O.S.
UN3505 Chemical Under Pressure, Flammable, Corrosive, N.O.S.
UN3506 Mercury Contained In Manufactured Articles
Deleted entries from the hazardous materials table and dangerous goods list
The following two hazardous materials entries are deleted from the regulations.
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UN3492 Toxic By Inhalation Liquid, Corrosive, Flammable, N.O.S.
UN3493 Toxic By Inhalation Liquid, Corrosive, Flammable, N.O.S.
Emergency Response Phone Number
The newly added UN3497 “Krill Meal” entry noted above does not require an emergency response phone number
similar to the fish meal entry in 49CFR172.604. The list of 16 entries in this section of the regulations has now
been increased to 17 entries that are excepted from the emergency response phone number requirement along with
all hazardous cargo shipped under the “Limited Quantity” exception.
IMDG Amendment 36 Notes
Excepted Quantities
The excepted quantity volume code for the various silanes has changed to“E0”
in column 7b of the dangerous goods list.
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January 2013
Special Provisions
Special Provision 240 applies to vehicles powered by batteries, such as, scooters, e-bikes,
wheelchairs, etc. Hybrid vehicles must be consigned under one of the following: UN 3166 Vehicle,
flammable gas powered or UN 3166 Vehicle, flammable liquid powered, as appropriate.
Vehicles which contain a fuel cell shall be consigned under the entries UN 3166 Vehicle, fuel cell,
flammable gas powered or UN 3166 Vehicle, fuel cell, flammable liquid powered, as appropriate.
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Special Provision 304 is now about transporting non-activated batteries
Special Provision 360 is for lithium battery powered vehicles consigned under UN3171
Special provision 361 is for electric double layer capacitors with energy storage capacity > 0.3
Wh (Watt Hours)
Special Provision 362 is for liquids, pastes or powders that are pressurized with a propellant
Special Provision 363 is for dangerous goods in equipment where the dangerous goods are in
excess of the limited quantity index
Packaging Provisions
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There are new packing instructions for chemicals under pressure such as UN3500 – UN3505
Package Marking Provisions
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The marking of the identification number on packages must be a minimum of 12 mm (.047 in)
in height, including the prefix UN, except for packages of < 30 L/ kg, where the info must be 6
mm in height
New warning mark for containers that use dangerous goods for cooling or conditioning purposes
Dry Ice
Special Provisions for dry ice – IMDG 5.5.3
Note the special provisions applicable to packages and cargo transport units containing substances presenting a risk
of asphyxiation when used for cooling or conditioning purposes (such as dry ice (UN 1845) or nitrogen,
refrigerated liquid (UN 1977) or argon, refrigerated liquid (UN 1951)).
5.5.3.1 Scope
5.5.3.1.1 This section is not applicable to substances which may be used for cooling or conditioning purposes when
transported as a consignment of dangerous goods. When they are transported as a consignment, these
substances shall be transported under the relevant entry of the Dangerous Goods list in Chapter 3.2 in accordance
with the associated conditions of transport.
5.5.3.2.4 Persons engaged in the handling or transport of cooled or conditioned cargo transport units shall be
trained commensurate with their responsibilities.
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January 2013
5.5.3.6 Marking of cargo transport units
When solid carbon dioxide (CO2 - dry ice) or other expendable refrigerant is used for cooling purposes, a warning
sign should be affixed to the outside of the doors so that it is clearly visible to any person operating the doors. The
sign should warn of the possibility of an asphyxiating atmosphere….
The IMDG Code recommends the following wording for the documentation of the shipment if the refrigerant is
carbon dioxide:
“UN1845 Carbon Dioxide, Solid, As Coolant”. The transport document may be in any form, provided it contains
the information required in 5.5.3.7.1. This information shall be easy to identify,
legible and durable.” The transport document may be in any form, provided it contains the
information required in 5.5.3.7.1
When solid carbon dioxide (CO2 - dry ice) is used for cooling
purposes, the container/vehicle is externally marked or labeled
in a conspicuous place, such as, at the door end, with the words:
"DANGEROUS CO2 (DRY ICE) INSIDE. VENTILATE
THOROUGHLY BEFORE ENTERING
IBC Stacking vs. non stacking
6.5.2 Marking
6.5.2.2 Additional marking
6.5.2.2.2 Amend the symbols to read as follows:
178.910 Marking of Large Packagings.
All Large Packages manufactured, repaired or remanufactured after January 1,
2015 must be marked with the symbol applicable to a Large Package designed for stacking or not designed for
stacking, as appropriate. The symbol must be not less than
100 mm by 100 mm as follows:
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January 2013
Polymetric Beads (UN2211)
Cargo transport units must be marked with a warning mark including the
words “CAUTION – MAY CONTAIN FLAMMABLE VAPOR” or “CAUTION – MAY
CONTAIN FLAMMABLE VAPOUR” with lettering having a height of at least 25 mm (1 inch). The mark must
be affixed to each access point in a location where it will be
easily seen by persons prior to opening or entering the cargo transport unit and must
remain on the cargo transport unit until the following provisions are met:
(1) The cargo transport unit has been completely ventilated to remove any
hazardous concentrations of vapor or gas;
(2) The immediate vicinity of the cargo transport unit is clear of any source of
ignition; and
(3) The hazardous materials have been unloaded.
Criterion for large packaging to successfully pass the stack test is also being added.
New UN Number Marking Requirements for Non Bulk-Packagings.
One of the most broadly applicable changes is the new minimum size requirements for UN numbers markings on
non-bulk packagings in 49CFR172.301. Generally the UN number marking will have to be 12 mm in height. The
proposed height for packages smaller than 30L/Kg is 6mm, an appropriate size for packages of 5L/Kg or less. This
is a provision you should consider implementing as soon as possible. It becomes effective January 1, 2014.
Questions on hazardous materials shipments may be directed to [email protected]
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