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Trade Compliance

Information on Dangerous Goods

  • By Sumit Gupta
  • May 10, 2020

Information on Dangerous Goods

Shipping dangerous goods around the globe can be a tough task. It is a complex and highly regulated process. There are many transport regulations that shippers must stay current with in order to have the proper knowledge to remain compliant, stay safe, and avoid penalties.

What Is A Dangerous Good? :-

Dangerous goods (DG) are any substance or article than can harm a person, property, or environment during transport. Whether a product is considered a dangerous good depends on various factors such as flammability, concentration of the substance, or whether it is shipped via ocean or air. It is the shipper’s responsibility to determine if their goods meet the requirements to be classified as dangerous goods, depending on their mode of transport. It is important to remember to look for “hidden” dangerous goods—items that may just be a small part of a product. Any time you ship something that could be a DG (liquids, powders, creams, gels, batteries, etc.), it is important to still report it. Carriers and forwarders want proof this material was noted and is actually non DG, rather than not being noted at all.

Process For Shipping A DG :-

In order to be qualified to ship dangerous goods, there are regulatory training requirements to complete. Once an employee takes the proper training courses and has an established ongoing DG program in place, they can earn a DG certification. A DG program consists of written policies and standard operating procedures in place as a foundation.

A DG shipper’s responsibilities include compliance, classification and declaration, packing, marking and labelling, and documentation. Declaring any potentially dangerous goods should be done during logistics booking. Customer invoice and packing list should be as descriptive as possible as well. There are a few DG documents that are needed depending on the scenario. A Safe Transport Report is typical for goods shipping out of mainland China. A MSDS report is need for DG shipping out of Hong Kong, the US, and generally the rest of the world. These reports provide technical and safety data, but it is important that they are filled out properly to reflect 100% compliancy to current regulations. Dangerous Goods Regulations (DGR), 61st Edition is mandatory to follow for Air shipments, and IMO IMDG Code 39-18 is mandatory for Ocean shipments.

Lithium Batteries :-

It is to be noted that lithium batteries are special cases that require special certifications and handling. In fact, damaged, defective, or recalled lithium batteries cannot be transported by air at all. There are also different rules to follow depending on whether you are shipping lithium-ion or lithium metal batteries.

For lithium-ion, it is important to understand your batteries’ capacity Watt-Hour. For lithium metal, you will need to know the aggregated lithium content. These numbers will refer you to different sections of regulations to follow.

How the batteries are packed is important too. Depending on whether the batteries are loose, inside equipment, or packed with equipment as spares will determine what needs to be done to remain DG transport compliant. Expect there to be different requirements, documentation and labelling, allowed battery output, batteries per package, allowed gross weight and more based on this. These requirements will again differ depending on whether you are shipping by air, ocean, or truck. Batteries must be packed against the current version of regulations to be valid.

Once the shipper has completed these documents and steps, the cargo moves on to the forwarder who will check each document and piece before sending it all to the carrier (whether that be a plane, boat, truck, etc.) The carrier will do once last check before acceptance and transport.

Classification can change due to mode of transport, even in the middle of shipping. Air transport typically has stricter limitations than ocean, for example. If cargo went from being ocean freight, then to express air to get to the customer, classification may change and could now be a DG. This is why it is crucial to know your route, plan ahead, and document goods properly if they have potential to be DG at any time during transport.

The ability to ship a dangerous good all depends on if the carrier accepts the shipment. Being diligent and following the process will provide the best chance for this.

Ramifications For Non-Compliance :-

It is essential to be compliant with DG rules and processes because there are ramifications that can occur if not. A non-compliance DG shipment could result in:

  • Carrier Rejection
  • Shipment Delays
  • Penalties, Legal Liability, and Fines
  • Serious Injury or Death if the cargo is not properly declared and therefore not stored properly

Real Incident: UPS cargo plane, a Boeing 747-400F, crash in Dubai caused by lithium batteries on September 3, 2010. The final report said the fire that caused the crash started in part of the cargo hold that contained lithium batteries. This, according to the report, is the reason the fire later engulfed other materials. “No items posing a flammable fuel load or capable of acting as an ignition source were visually identified except for batteries and battery containing devices,” the report said.

As of September 15th, 2019, the penalty for China dangerous goods misdeclaration is that ocean carriers can charge anywhere from $4000 to $15000 or more per container. Receiving only a fine for non-compliance is the best case scenario. The worst case scenario would also include serious injury, harm, or even death. This is why it is important to choose your suppliers carefully—so that they can help to properly handle and declare the DG.

Tips For Successfully Shipping A DG :-

To be successful with shipping dangerous goods, here is a summary of a few things to keep in mind and to practice.

  • Be detailed and diligent in preparing your documents, and update all of your documents before they expire.
  • Remember, all batteries, powders, liquids, creams, and gels will require an MSDS
  • A shipment can change from non-DG to DG mid shipment
  • DG training is not enough without a solid DG program in place
  • Vet your shipper thoroughly

By remembering these tips and taking the necessary precautions, we can all be safe and successful in shipping dangerous goods.

4PL Consultancy has a team of experts in Tariff classifications of wide variety of Product lines – Medical spares, Aerospace, Radiation Oncology machines & spares etc.

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