IATA Regs -- The Details

["Roy A. Parker" <70472.711@CompuServe.COM>]

Todd,
 
> Current IATA regs require use of a 4"x4" certification for excepted
> quantities of hazardous materials (DGR Section 2.7) which is attached
> directly to the outside of the package.  For materials with a subrisk
> of category 6 (toxic), there is no minimum threshold for identifying
> these materials.  Recently we were unable to send an international
> shipment containing limited quantity amounts (nano to pico grams) of
> radioactive vanadium chloride (LD50 = 350 mg/kg).
 
     1. IATA-97 does not apply to labeled radioactive material packages.
        It only applies to radioactive materials in excepted packages in
        which there  are substances of other risk categories in excepted
        quantities.
 
        Toxic substances  of Division  6.1 if Packing Group I because of
        inhalation  toxicity  are  forbidden  under  the  provisions  of
        excepted quantities.
 
        Infectious substances  of Division  6.2 are  forbidden under the
        provisions of excepted quantities.
 
     2. Radioactive vanadium  chloride could  either  be  shipped  as  a
        labeled  radioactive   material  package  with  a  Division  6.1
        subsidiary risk; or
 
     3. If the  radioactive material  is limited  quantity it  could  be
        shipped  as   a  labeled  Division  6.1  shipment  provided  the
        provision of radioactive material excepted package were met.
 
 
> Apparently, all international airlines were refusing any package that
> was identified as having any type of category 6 hazard.
 
     1. It is  true that  many, but  not all  airlines, will  not accept
        labeled Division  6.1 toxic  substances packages.  Check IATA-97
        Section 2.9.4 List of Operator Variations for carriers that will
        not accept labeled Division 6.1 toxic substances packages.
 
     2. FX-02 in  IATA-97 Section  2.9.4  List  of  Operator  Variations
        states:
 
          Primary or subsidiary risk Division 6.1 materials with Packing
          Group I  or II  with an  origin  and  destination  within  the
          U.S.A., will  be accepted only if in approved D.O.T. Exemption
          packaging.
 
          Primary  or   subsidiary  risk  Division  6.1  materials  with
          Packaging  Group   I  or   II  will   only  be   accepted  for
          International transport with preapproval.
 
          Poison Inhalation  Hazard (PIH)  with a hazard zone "A" or any
          Class 2  substance with  a toxic  primary or  subsidiary  risk
          label will not be accepted.
 
> (I didn't check FedEx because of their Paris hub -- which does not
> allow limited quantity packaging.)
 
     1. It is  the  French  government  that  does  not  accept  limited
        quantity or  "Y" packaging  not FedEx.   See  FRG-02 in  IATA-97
        Section 2.9.2 List of State Variation.
 
     2. The above  prohibition does  not apply  to Radioactive Material,
        Excepted Package  - Limited  Quantity of Material, UN2910, which
        is acceptable  to  and  from  France.    (The  limited  quantity
        prohibition in  France is  only applicable  to "Y" packaging for
        the other hazard classes.)
 
Roy A. Parker, Ph.D.
Radiation Physics Consultant to
Federal Express Corporation
E-Mail: 70472.711@compuserve.com
Tel: 504-924-1473
Fax: 504-924-4269