Triangle NoTES - July 2010

After the last newsletter I received several communications indicating the requirements for International Air Transport Association (IATA) were different from those of the U.S. DOT. Some indicated IATA was more strict in their shipping requirements. Others indicated IATA was much more lenient and also seemed to ignore the size of the container in favor of the amount of sample contained therein. That seemed odd considering gas expands to the size of the container, so I tried to find the information directly. IATA has an office in Montreal which deals with the questions concerning shipment of dangerous goods. After a few communications, the result was this e-mail confirmation of the more restrictive IATA shipping requirements for flammable gas samples.

 

From: dangood@iata.org
To: Wstollings@aol.com


Subj: RE: shipping flammable gas samples

Wayne,

Gas samples, non-pressurized, flammable may be shipped by air under the following conditions:

For cargo aircraft, you may have up to 5 litres in a package with each sample (inner packaging) being in a glass or metal inner packaging of no more than 2.5 litres capacity;

For passenger aircraft you may have up to 1 litre per package with the inner packaging being no more than 1 litre.

The outer packaging must be a UN specification packaging to Packing Group II standard.

All of the marking, labelling and documentation requirements apply.

Regards,

David BRENNAN
Head of Cargo Safety & Standards
1: +1-514-874 0202 Ext 3289

2: +1-514-874 2660

International Air Transport Association
800, Place Victoria, PO Box 113
Montreal, Quebec, Canada, H4Z 1M1
www.iata.org/dangerousgoods

As this indicates, for air cargo shipments containing a flammable gas there can be no container larger than 2.5 liters used and no more than two such containers can be in the same package. For shipment on a passenger aircraft, only a 1 liter container and one container per package is allowed. This would allow the 1 liter mini-canisters or the 1 liter Tedlar bag in an approved shipping container for any shipment ground or air or two of these 1 liter Tedlar bag approved containers in a single package for road or cargo aircraft. It also would allow any size of our canisters filled with landfill gas to be used for any shipment method, provided our initial pre-charge of helium has not been removed or the sample has not been pressurized above atmospheric pressure (787 mmHg absolute) prior to shipping. Every other shipment is subject to differing sizes and packaging density for the mode of transportation, with air transport being the more restrictive.

I do not doubt checking with the generic UPS, Fed-Ex, or maybe even the IATA hazardous shipping representatives can result in differing information. I have been given conflicting information many times on shipments, which is why I have gone to the sources I have on this very important issue.

To be safe in shipping landfill or other gases, it is the ultimate responsibility of the shipper to comply with the regulations. The easiest way to comply with hazardous shipping is to make the shipment non-hazardous, which is our goal for our customers. To that goal, I have personally discussed these shipments with several technical representatives and administrators of both the U.S. DOT and IATA. We have correspondence on file with the U.S. DOT confirming that if the sample canister is pre-charged as we specify and the concentration of methane in the LFG does not exceed our estimates (~60%) the shipment would not be classified as flammable under the regulations. This is by far the best shipping option given the various conflicting specifications for the different air and ground methods.

Under no circumstances should a 6 liter canister be used to try to ship any gas which is classified as flammable. The risk of fines and possible jail time is definitely not worth the attempt.

Any size of container can be made legal for shipping as long as the gas contained within is sufficiently diluted to bring it below the flammable classification threshold. Make them legal, make them safe, and with no financial or legal risk to yourself during shipping.

Wayne Stollings

Triangle Environmental Services, Inc.

Wstollings@aol.com