| Introduction |
The domestic air shipping
rules are very similar in most countries, and if you stick to the same shipper
to and from you can usually assume the same process both ways. For instance,
in the U.S.A., 49CFR (version 2004) regulates dangerous goods shipping
(see sections 171-173, 175, 178; for 2003 see here), your country might have similar laws. You have
to always consider the laws of both the shipping and receiving country.
International dangerous goods shipping (packing, labelling, shipping papers,
loading, transport, etc) is regulated by the international body IATA (International Air Transport
Association) and the rules are very similar to 49CFR. Air carriers will
usually only accept shipments that are packed and labelled according to
IATA rules, and if you are a so-called known shipper (trusted customer with
a DG contract).
You can usually not just drop off/pick up your package at a branch location
but you need either an institution or company to receive the shipment for
you, and for the return, pack and ship it for you at your field location
(e.g., a shipping forwarder that does DG packing/shipping). The same applies
if you ship bottles somewhere abroad for analysis. These companies that
issue shipping papers and do the packingand forwarding but are not air carriers
are also termed Indirect Air Carriers (IAC), or shipping/freight forwarders.
Note: transporting Hazardous
Materials on roads / by vehicle is (in most countries) also regulated. |
|
| Shipping
& Packing |
Contact the shipper months
in advance if you use them the first time. Carriers that ship hazardous
cargo on a contract basis (not your small packages contract of your institution)
are for instance UPS and American Airlines Cargo - FedEx does not ship DG
internationally.
AA Cargo has experience with scientific hazardous cargo. It takes up to
2 months to become a known shipper in order to be able to ship with them
(or any other cargo carrier). See details below on how to become a known
shipper. You can also use UPS, they have a HazMat group in every country
(call UPS and ask for the number of the DG group).
Talk to the environmental health & safety people
at your University/Institution, or your University's chemical waste disposal
staff (and/or HazMat) about the shipment, insurance and liability issues.
For U.S. regulations on any hazardous material, look at 49CFR,
subpart B first (2003, scroll to page 252 for sodium hydroxide solution). |
|
|
Codes
|
|
| AACargo |
American
Airlines Cargo
(air carrier) |
| IATA |
International
Air Transport Association
(organization, airlines) |
| ICAO |
International
Civil Aviation Organization (U.N. body)
|
| CFR |
Code
of Federal Regulations (law, U.S.)
|
| DG |
Dangerous
Goods (term)
|
| DOT |
Department
of Transportation
(government body, U.S.)
|
| FAA |
Federal
Aviation Administration
(government body, U.S.)
|
| FedEx |
Federal
Express (air carrier)
|
| HazMat |
Hazardous
Materials (regulatory term) |
IAC
|
Indirect
Air Carrier (TSA / FAA administrative term)
|
| MSDS |
Material
Safety Data Sheet (term)
|
| NaOH |
Sodium
Hydroxide (name)
|
| OSHA |
Occupational
Safety & Health Administration (workplace safety) |
| PAL |
Precise
Account Locator (administrative term) |
| PG |
Packaging
Group (regulatory term) |
| TSA |
Transport
Security Administration |
| UPS |
United
Parcel Service (air carrier) |
| 1H1 |
dangerous
goods packing container type
(plastic pail, non-removable lid) |
| 4G |
DG
carton packing type
(regulatory term)
|
|
| Packing
personnel |
Training:
an IATA certified hazardous material packer must do the packing.
You can possibly obtain such a certificate yourself by attending a hazardous
materials IATA course at your university/institute if they offer one.
A normal University chemical safety and hazardous waste handling course
is not enough.
These courses may in some institutions be free of charge for employees,
however at ASU they cost around 300 US$, private companies specialized in
training charge about 450 US$.
If the shipper accepts you as a packer or not is not guaranteed, and you
should consult with both your institution's HazMat people and the cargo
representative of the cargo company you use.
See 49CFR 172.704 if you qualify as a hazardous materials
cargo packer. |
|
| Packing material |
(see 49CFR 178)
We
suggest packing group 2: inner container, absorbent, outer container, labels,
paperwork
- inner container: "glass ampoules"
or "glass receptacle" (Giggenbach-bottles) with a high-vacuum stopcock;
- absorbent: flakes of vermiculite
(mica);
- outer packing: a 1H1 plastic
drum - the same ones you often see for example for paint on construction
sites, tall white plastic buckets (pail) with several enforcement plastic
rings near the top and a handle) with one-way sealable lid (cost: ca. US$3);
get an extra lid per pail for the return shipment. Do not use screw top lids!
See 49CFR 178.509 and links below;
- marking: (note marking is not
labeling!)
- orientation/up arrows (can
be a label);
- proper shipping name and
UN ID# (see HazMat table, UN 1824); 49CFR 172.
- labeling: must be according to
DOT rules (check with hazardous material staff).
- note: a label is not a
placard;
- hint: NaOH (aq., conc.)
packed in this manner is a class 8 liquid (corrosive), UN 1824, PG2, according
to 49CFR.
- shipping papers: for what you
need per pial or pack, see 49CFR 172.201-205:
- 4 MSDS for conc. NaOH solution;
- 1 Air Waybill (e.g., American
Airlines Cargo Air Waybill - get one at the drop-off location);
- 1 Cargo "IAC Known Shipper
Acceptance Info" form (get or fill out at drop-off location, bring ID);
- other documents as specified
by 49CFR.
As an additional (optional) measure, the bottles at ASU (where this shipping
method is used) are packed in tennis ball
saver containers (max. cylindrical OD of bottle & valve: 60 mm).
|
|
| Ship
bottles as cargo |
- Never ship NaOH in luggage
or as "water samples".
- Do not show up at the airport
without having talked to airline cargo personnel in advance;
- Drop off your package well
before the plane takes off but try to drop it off on the same day as the
plane departs. Airlines are not allowed to store it hazardous materials for
long, so pick up package soon after you arrive at destination. If possible
put your package on the same plane that you fly on. With AACargo there is
usually enoughtime if you drop it off 1 hour before departure (e.g., after
you have checked in yourself, also internationally);
- For AACargo, find the shipper's
cargo drop-off location in the cargo section of your airport beforehand.
|
|
| The "known
shipper" issue |
With most air carriers,
you can only ship cargo (e.g., using AA Cargo) if you are a known shipper.
How to become one... this is info based on experience with American Airlines
Cargo. Procedures at other airlines may vary. You can only become a known
shipper if they approve your PAL application, and visit you:
Download the registration
form for a PAL (Precise Account Locator) number on the aacargo
AACargo web site and call them. They usually sit on it for a month and then
contact you. Be persistent and keep calling, try to talk to a real person.
Once you have applied for a PAL, there will be background checks required
by the Dept of homeland security, FBI & CIA. This takes time... they
want to know that your university/institute really exists and after giving
you a PAL, will send someone out to visit you/the Dept. Some more information
can be found here.
You receive your PAL by
mail or fax, which includes a shipping contract on the same form (this is
not for an actual physical shipment but to establish a business relationship).
there are background checks required by the DHS, FBI & CIA. This takes
time... they want to know that your University/Institute really exists and
will send someone out to visit you/the Dept. Letterhead certificates from
your institution's president won't help, but former UPS and FedEx bills
in your Department's name will do - they will ask for that before they send
the person out to meet you/check up on you. You will have to fax or mail
this form back, and provide the evidence indicated above. You can only ship
AA cargo if you are a known shipper
.
If that evidence is sufficient,
you will be contacted to make an appointment for a business inspection with
an AACargo representative. During that visit, the verified known shipper validation form
is filled out and signed. Make very sure you have a photocopy! The next
step is packing & shipping. |
|
| Links |
| Agencies |
|
|
| HazMat
shippers |
|
|
| Pails
& packing |
|
|
|
| Cargo
limitations |
Quantity:
if it goes to/from the US, the total per cargo airplane is up to 2 liters
of concentrated NaOH (passenger planes: 1 liter).
You should prepare packages that are below 1 L because not in every case
will you be able to get cargo aircraft transport.
(e.g., 70 mL NaOH before sampling, 150 mL
after sampling, so you can fit 6 bottles into one pack)
It can also take around ten days only between Europe and North America,
let alone less frequented routes...
If you want to see how
nit-picky it can get, see this example
of the transport of Infectious Substances
and Diagnostic Samples.
Note the fines here - they are significantly lower than for sodium hydroxide.
|
|
| Authors
/ contact |
Information compiled by:
Florian M. Schwandner (ASU)
and
Toby Fischer (UNM),
1st uploaded:
January 2005;
updates:
April 2005.
|
|
| Disclaimer |
This site provides
information about the regulations designed to help scientists to transport
NaOH-filled Giggenbach bottles safely and according to air cargo rules.
No responsibility, accuracy or liability is assumed by the authors or
IAVCEI. No third party interest.
We thank Bill Lorentz (AA Cargo), Terry Hamner (UPS) and Henry Walsh (ASU)
for advice. |
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