A sampling of what you've missed in the January/February 2005 issue of HAZMAT Packager & Shipper...

As a Subscriber, you would have learned ....

that in the 46th edition of the IATA Dangerous Goods Regulations (DGR), consolidators, freight forwarders and IATA cargo agents employed by the shipper to undertake the shipper's responsibilities may sign the Shipper's Declaration for Dangerous Goods. The signer must be trained as required by subsection 1.5. Changes in the IATA Dangerous Goods Regulations

that the old format shipper's declarations may continue to be used given that where a subsidiary risk entry is required, it must be placed in brackets following or below the class or division number and the additional certification statement concerning air transport requirements must be added. This is permitted in order to use a stock of old format Shipper's Declarations before converting to the new format as required by the 46th edition of the IATA DGR. The preferred sequence is UN number; Proper shipping name; Class or Division, subsidiary risk in brackets; and Packing group (if applicable). Changes in the IATA Dangerous Goods Regulations

that RSPA has established a delayed compliance date of January 1, 2006 for HM-215G and that many of the detailed changes are to specific entries in the Hazardous Materials Table. The entire HMT, § 172.101, has been reprinted in the final rule due to the numerous changes, although the changes are not individually highlighted. Many of the changes are relative to the different physical states in which entries could exist in order to identify the physical state which the entry covers. Approximately 70 new entries were added to cover the alternative physical state of those entries. HM-215G Final Rule Published

that, in response to comments submitted relative to separating the requirements for "repair" and "routine maintenance" for all IBCs, the text of final rule HM-215G was mistakenly repeated. HM-215G Final Rule Published

Air Eligibility Mark As proposed in the Notice of Proposed Rulemaking, § 172.321 the requirement for the "air eligibility marking" was removed, as was reference to that marking and in § 173.25 (overpacks). In the preamble, though, RSPA notes that the use of such a marking is not prohibited. HM-215G Final Rule Published

that it is not the case that a company can relieve itself of all responsibility to comply with the hazardous materials regulations by engaging a third party to prepare and offer hazardous materials for transportation on its behalf. The third party is acting as an agent for the company engaging the third party to ship and the company "may be held responsible for the third party's non-compliance with the [HMR]". Comments on DOT Interpretations

that at the December 2004 UN session the Sub-Committee reversed their decision and decided not to approve those amendments developed at the previous (July 2004) session that would extend the UN criteria for classification of substances based on hazard to the environment to all materials. The decision was based on the belief of the majority of delegations that materials classified in Classes 1 through 8 always should be considered as potentially hazardous to the environment - without the need for specific marking or other identification as such. Therefore, for these materials additional identification as a hazard to the environment is unnecessary, and from a practical point of view would not fundamentally alter the typical response to incidents involving the materials. UN Committee of Experts Meets

The Transportation Security Administration (TSA) in an interim final rule has extended the deadline for implementing the fingerprint based checks for truck drivers holding a Commercial Drivers License (CDL) Hazardous Material Endorsements (HME) from January 31 to May 31, 2005. Other changes of importance were also made. TSA Issues Interim Final Rule

Most of the changes proposed by DOT under docket NPRM HM-228 pertain to limited quantities, consumer commodities and the "small" quantity exceptions. The proposed amendments would have the effect of significantly limiting the hazardous materials permitted for transport by aircraft under these exceptions, and in other cases of significantly reducing the package quantities authorized for air transport. Carriage by Aircraft