This article, from Alan Walsh (Compliance Engineer, Renishaw plc), was originally published in the Spring 2019 edition of World Trade Matters (pages 58-59).
The Dangerous Goods Regulations
The increase in popularity of electronic devices powered by lithium batteries has raised public awareness of the dangerous goods regulations, whether it is a checklist at the post office, notifications during online flight check in or the notices displayed at airport security. Lithium batteries, aerosols, adhesives, metal powders and flammable liquids are among the most commonly shipped dangerous goods.
Each mode of transport has a dedicated set of dangerous goods regulations – road, rail, inland waterway, sea and air. While 90% of international freight is carried by sea, shippers who transport dangerous goods in bulk are familiar with the International Maritime Dangerous Goods Code as an integral part of their shipping operations. As lead times come under pressure, it is the IATA (International Aviation Transport Association) dangerous goods regulations which impact many small and medium shippers, as we will now discuss.
Training and Shipping Information
All fully regulated shipments require a shipper’s declaration for dangerous goods to be presented to the courier alongside the commercial and export control documentation. However, the requirements for shipping smaller quantities often require more attention. The IATA dangerous goods regulations require those preparing dangerous goods for shipment by air to attend an approved training course. Whilst these training requirements only apply to shippers, packers and those handling dangerous goods, ensuring compliance involves more business functions than we may initially expect.
For manufactures of materials and articles classified as dangerous goods, the process begins with classifying the item. This can require a variety of tests to determine the properties of the material. In addition, the manufacturer must produce a safety data sheet (SDS) for substances and mixtures. Although SDSs are not legally required for finished articles such as batteries, many manufacturers provide transport information in a similar format. Distributors of such items must ensure all the documentation required for transportation, such as SDSs and test reports, is sourced from the manufacturer through effective supply chain management. The rebranding of raw materials requires the creation of a new SDS by the producer, which will involve verifying the tests conducted by the original manufacturer.
Product design, packaging and shipping
Shipping processes are not always associated with product design and marketing strategy activities. However, decisions made during this phase of the product lifecycle can impact the costs and ease of distribution, particularly if the product is powered by lithium cells or batteries. If proprietary cells are purchased to integrate into a custom designed battery pack, the new battery pack will require independent testing before it can be transported. In addition, businesses need to ensure that their battery packs and battery powered products comply with any territory specific electrical safety certifications before they can be placed on the market in many countries.
The regulations also need to be considered during the design change process. Changes to the batteries used in the product, the adhesive used for installation or the accessories supplied can all have an impact on shipping operations. Once the relevant products are identified as dangerous goods with the appropriate UN code classification in IT systems, this indicator can be used to drive regulatory approval of design changes to the product or its packaging.
Systematic shipping of dangerous goods
While those making occasional shipments can follow the packing instruction within the regulations for each shipment, a manual approach isn’t a practical proposition for routine shipments. Using IT systems to print dangerous goods text against part numbers on warehouse orders ensures shippers check the package is prepared correctly and that the correct text is communicated to the courier on the shipping documentation.
Within the IATA dangerous goods regulations there are state (country) and carrier (airline) variations in addition to the core regulations. Intelligent business systems can allow for state variations, so that destination specific requirements can be accommodated in the same way as for the Export Control regulations. However, the system data requires verification when the regulations are updated each January because new variations may be introduced.
Working with the courier
The shipper will require an agreement with the courier to transport each class of dangerous goods that they wish to ship. The courier may choose to audit the shipper’s despatch facility to ensure they are applying processes that demonstrate due diligence. It is common practice for the shipper to integrate their despatch processes with the business systems used by the courier to ensure the effective communication of dangerous goods information. For example, some couriers require dangerous goods notes to be placed under the barcode label on shipping labels for easy reference.
Collaboration between couriers and shippers reduces any delays caused by operator (airline) variations. These variations are used to communicate the specific requirements of individual airlines in addition to the core regulations. In some regions the requirements for supporting documentation are more stringent than those in the IATA dangerous goods regulations and the regulations for transporting by road may be different, so good communication with local distribution hubs is essential.
As more companies strive to access international markets through e-commerce, they may find that an understanding of the dangerous goods regulations and the integration of the requirements into their operations becomes increasingly relevant. Annual changes to the IATA dangerous goods regulations may impact shipping operations based on content or destination, so ongoing vigilance of the regulations in addition to the packages being shipped is of the utmost importance.
*Since this article first appeared in World Trade Matters, the 61st edition of the IATA dangerous goods regulations has been published. This requires shippers to make a test summary available upon request for any lithium chemistry battery they present for shipment.
Written by Alan Walsh, Compliance Engineer at Renishaw plc