UN 3091, Lithium Metal Button Cells contained in equipment, by International Air – within limits below

COMMODITY: Lithium metal button cell batteries contained equipment, with no spare batteries; Not exceeding 1 gram (g) lithium metal content per cell. Unlimited packages per consignment.

MODE OF TRANSPORTATION: International Air


OVERVIEW

This transport data sheet is for shipments of button cell lithium metal batteries with specific exceptions, when contained in the equipment with which they will be used. They are not subject to the regulations, except for the extensive requirements contained in Packing Instruction 969, General Requirements and Section II.

This transport data sheet does not cover various special provisions for: prototype batteries, special approvals, damaged or defective batteries, combinations of lithium ion and metal batteries or combinations of lithium batteries both contained in and packed with equipment, and batteries in vehicles.

PROPER SHIPPING NAME:Lithium metal batteries
contained in equipment
LABEL:No
IDENTIFICATION NUMBER:UN 3091PLACARD:No
HAZARD CLASS/DIVISION:9EMERG. INFO TRANSMITTAL: No
PACKING GROUP:NoneTRAINING:Special
DOCUMENT:SpecialPACKAGING:Special
MARKING:No

DANGEROUS GOODS TABLE

____________________________________________________________

Classification

This transport data sheet uses the small lithium metal cells and batteries exceptions in IATA Packing Instruction 969 Section II, with the specific exceptions for button cells. Excepted lithium metal cells may not exceed 1 gram (g) lithium metal content each.

A battery is a collection of cells (Duracell 9v). Cells are often circular or cylindrical. A single cell “battery” (CR123A) is considered a cell, and must not exceed 1g lithium metal content. A “button cell” (DL 1/3N) means the height of the cell is less than the diameter (per IATA guidance). “Coin cells” (e.g., CR2032) look like coins and are button cells.

Lithium cells and batteries must meet requirements of the UN Manual of Tests and Criteria. The manufacture must record the test results and maintain them (indefinitely).

Citation: IATA DGR, PI 969 Section II


PACKAGING INFORMATION

Packaging must meet the general requirements of IATA DGR PI 969:

  1. Cells must be packed as follows:
    • protected against short circuits;
    • protected against unintentional activation of the equipment; and
    • the outer packaging must be quality, strong, and rigid and not defective or damaged.
  2. The equipment must be packed in strong rigid outer packagings constructed of suitable material of adequate strength and design in relation to the packaging’s capacity and its intended use.
  3. A package may contain more than one piece of equipment, up to a maximum of 5 kg net of lithium metal batteries.
  4. There is no gross weight limit for equipment containing lithium metal batteries.
  5. There is no limit of the number of packages in a shipment.

Citation: IATA DGR, PI 969


SHIPPING PAPER REQUIREMENTS

1) A dangerous goods declaration is not required.

2) The batteries do not need to be noted on the air waybill.

Citation: IATA DGR PI 970 Section II, Additional Requirements


CARTON MARKING

There are no marking requirements. The lithium battery mark is not required.


OVERPACKS

Packages may be placed in an overpack, and there are no marking requirements. The overpack may also contain packages of dangerous goods or non-dangerous goods not subject to the regulation provided they are chemically compatible. Cartridges for tools, blank are allowed.


Training

Each person who prepares a package for transport containing lithium cells or batteries, including cells or batteries packed with, or contained in, equipment in accordance with the conditions and limitations of this transport data sheet, must receive adequate instruction on these conditions and limitations, commensurate with their responsibilities.


UN 0014: BLANK 1.4S AMMO, INTERNATIONAL AIR

REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET

COMMODITY: Blank small arms ammunition (shotshell, rimfire and centerfire) as 1.4S; 25 kg net maximum per package; 50 caliber / 8 gauge or less, inert bullets or tracer only; or above 50 Cal/8 gauge with an EX approval.

MODE OF TRANSPORTATION: International Air

CLASSIFICATION & REQUIREMENTS

PROPER SHIPPING NAME:Cartridges, small arms, blankLABEL:1.4S
IDENTIFICATION NUMBER:UN0014PLACARD:N/A
HAZARD CLASS/DIVISION:1.4SEMERGENCY:Yes
PACKING GROUP:NoneTRAINING:Every 2 Years
DOCUMENT:SpecialPACKAGING:PI 130
MARKING:Yes  

DANGEROUS GOODS LIST

LIMITED QUANTITIES

Unlike other modes of transport, small arms ammunition is forbidden to ship as a limited quantity by international air. Industry is not pursuing the ability to ship ammo as LQ by international air because:

  • Unlike other modes where LQ has significant cost savings, the only exception by air is from package testing; there is no exception from shipping papers or labeling.
  • Unlike other modes where the 5 kg limitation applies to each inner package, the 5kg limit in international air applies to the entire shipping case. A majority of ammunition packages would not qualify.
  • Many airlines have filed variations prohibiting LQ shipments.
lq

As a consequence, industry got the LQ surface mark approved for LQ air transport domestically in the USA, and obtained an example in IATA that the LQ surface mark may remain on the package and be ignored in international air. This eliminates the labor to remove it, and allows the package to be LQ during the international journey on the surface leg subsequent to air transport.

forbidden

Therefore the LQ-Y mark should never be used.

Citations: IATA 2.8.3.5 (operator restrictions); Dangerous Goods List Columns G & H (LQ is forbidden); 7.1.5.5 and Figure 7.2.A (the ground LQ mark is allowed and ignored)

PACKAGING INFORMATION

Cartridges, small arms, blank, 50 cal or less may be self-classified by the manufacturer (without an EX approval) as UN 0014, Cartridges, small arms, blank, Division 1.4S explosive and packaged without written government approval, as follows :

  • The package must be tested, and bear the specification package mark.
  • The maximum gross weight is typically 400 kg (882 pounds) per package (bearing in mind the maximum net weight is 25 kg for passenger aircraft or 100 kg for cargo-aircraft-only).
  • Ammunition must be packed per Packing Instruction 130; inner and intermediate packaging is allowed but not required. These outer packagings are allowed:
  • The packaging codes are specifications with minimum standards of construction and maximum gross weights.

Citation: IATA 6.0.4.1 marking, 6.2 specifications, 6.3 testing

SHIPPING PAPER REQUIREMENTS

International air transport is subject to the requirements of IATA, the International Air Transport Association. A special document is required called a Dangerous Goods Declaration (DGD) in addition to any standard bill of lading. Fill out the DGD as follows in four sequences:

Sequence 1 – Dangerous Goods Identification

The sequence is: “UN 0014, Cartridges, small arms, blank, 1.4S”. There is no packing group.

For multiple products, each change to Sequence 1 must be on a new line.

Sequence 2 – Quantity and Type of Packing

The sequence is “QUANTITY PACKAGING:MATERIAL-TYPE X NET-QUANTITY, NEQ”, e.g. “5 fibreboard boxes X 11 kg, 1 kg NEQ”. Quantity is the number of shipping cases (packages). The degree of rounding is not specified, but may be to the nearest kilogram, and should be consistent between the DGD, package and overpack markings. Packaging type is material and type, e.g. “fibreboard boxes” or “steel drums”. Metric units must be used, which for solids is “kg”, not capitalized. For ammunition, NEQ is the powder and primer mix; however the amount of primer mix is often only 1/100th of the powder and may be lost in the rounding.

For multiple products, each change to Sequence 2 must be on a different line, e.g. different net weight, but Sequence 1 does not have to be repeated if together. See IATA DGR Figure 8.1.K.

When overpacks are used:

  • Packaging in overpacks must be listed first.
  • The wording “Overpack Used” must be inserted on the declaration form immediately after all the entries in the overpack.
  • When a consignment consists of multiple overpacks each overpack must have an identification marking any alpha-numeric format) and be marked with the total quantity of dangerous goods within the overpack including the unit of measurement.
  • The total quantity(ies) shown on the Shipper’s Declaration must match the total quantity(ies) shown on the overpack.
  • Multiple overpacks with identical contents must be identified as follows: “Overpack Used X (number of identical overpacks)”, (see IATA Figure 8.1.L and Figure 8.1.N, examples 8 and 10). Multiple overpacks with different contents must be identified by listing them separately

Sequence 3 –Packing Instruction

Write the number of the applicable packing instruction, “130”.

Sequence 4 – Authorizations

Normally the EX number should be provided and attached. This UN number does not require EX approvals for 50 caliber / 8 gauge and below. Instead, make a statement and cite USG-05, a US government variation stating that they require EX numbers, but that small arms ammunition is excepted per 49 173.56(h), e.g. “These articles are of the kind described in 49 CFR 173.56(h), and are authorized by USG-05 without documentation”.

Citation: IATA 8.1.6.9

CARTON MARKING & LABELING

Packages containing small arms ammunition must display the following markings and at least 6mm (1/4”) high, or an appropriate size for packages which are ≤5 kg net, as follows:

  • Proper shipping name – “Cartridges, small arms, blank”
  • UN# – “UN 0014”
  • the full name and address of the shipper and the consignee, located on the same package surtace and near the proper shipping name, if the package dimensions are adequate;
  • the net quantity, in kilogram units abbreviated “kg” in lower case letters, e.g. “15.2 kg”. This quantity must be marked adjacent to the UN number and proper shipping name. It may be rounded to the nearest kilogram, or to a desired level of decimals for better accuracy and alignment with the overpack weight. The net quantity should be identical to that shown on the Dangerous Goods Declaration document.
  • the specification package marking, placed in a location and of such size relative to the package as to be readily visible. Must be pre-printed or affixed, and not handwritten. For packages with a gross weight exceeding 30 kg the marking, or a duplicate thereof, must appear on the top or on the side of the package. For example:

The 1.4S hazard label must be applied as follows:

  • When the package dimensions are adequate, labels must be located on the same surface of the package near the proper shipping name marking.
  • Labels should be affixed adjacent to the shipper’s or consignee’s address appearing on the package.
  • Unless the package dimensions are inadequate, the label(s) must be affixed at an angle of 45 degrees (diamond shaped) to the surrounding markings.

The LQ mark is not valid on ammo in international air transport, but may remain on the package and be ignored in air transport, and be valid for further surface transport when the air journey is over.

Citation: IATA 6.0.4.1, 7.1.4, 7.1.5, 7.2.6.2

OVERPACK MARKINGS

Examples of overpacks include pallets and specification packages placed in another packaging. International air transport is subject to the requirements of IATA, the International Air Transport Association, which requires unique pallet markings.

Unless all markings and labels representative of all dangerous goods in the overpack are clearly visible, the overpack must be marked with:

  • the word “OVERPACK” in letters at least 12 mm (1/2”) high;
  • UN number
  • proper shipping name
  • hazard label
  • full names and addresses of the consignor and consignee

The following requirements apply even if all markings are visible:

  • If there is more than one UN number in an overpack, write each UN number and the total quantity of dangerous goods for each UN number.
  • If there are two or more overpacks, name and mark each pallet with a unique identification mark (which may be in any alpha-numeric format) and the total quantity of dangerous goods, as indicated on the Dangerous Goods Declaration.

Normally we would use this OVERPACK sticker for domestic shipments:

However since there is so much information required, we print it on a piece of paper instead, with OVERPACK and the UN number in 1/2″ print, and affix it to the pallet:

Citation: IATA 7.1.7

UN 0012: AMMO, DOMESTIC ROAD, RAIL, AIR & VESSEL (US FLAG CARRIER ONLY)

COMMODITY: Small arms ammunition (shotshell, rimfire and centerfire) as 1.4S – 50 caliber / 8 gauge or less, inert bullets or tracer only; or above 50 Cal/8 gauge with an EX approval.

NOTE: Use LQ Data Sheet instead if package < 30 KG, primers are protected from other cartridges and ammo is in inner packages in an outer container. Use this data sheet for loose un-oriented “bulk” packs.

MODE OF TRANSPORTATION: Domestic Road – Less than truck load (LTL) and truck load (TL) service

OVERVIEW

PROPER SHIPPING NAME:Cartridges, small armsLABEL:None
IDENTIFICATION NUMBER:UN0012PLACARD:None
HAZARD CLASS/DIVISION:1.4SEMERG. INFO:Required
PACKING GROUP:NoneTRAINING:Required
DOCUMENT:RequiredPACKAGING:PI 130
MARKING:Required  

HAZARDOUS MATERIALS TABLE

(1)Sym-
bols
(2)Hazardous materials descriptions and proper shipping names(3)Hazard class or Division(4)Identifi-cation Numbers(5)PG(6)Label Codes(7)Special provisions(§172.102)(8)Packaging (§173.***)(9)Quantity Limitations(see §§173.27 and 175.75)(10)Vessel
stowage
Excep-tionsNon-
bulk
BulkPassenger aircraft/ rail
Cargo aircraft onlyLoca-
tion
Other
(1)(2)(3)(4)(5)(6)(7)(8A)(8)(8C)(9A)(9B)(10A)(10B)
Cartridges, small arms1.4SUN0012 none6362None25kg100kg0125

CLASSIFICATION

Cartridges, small arms 50 cal or less with inert bullets (including tracers but no incendiary or exploding bullets) may be self-classified by the manufacturer as UN 0012, Cartridges, small arms, Division 1.4S explosive. No EX approval is required.

Citation: 49 CFR §173.56(h)

PACKAGING

Package the ammunition as follows:

  • Ammunition must be packed according to Packing Instruction 130. No inner package is required. This allows a loose un-oriented jumble pack in a box or drum.
  • The maximum gross weight is limited to 400 kg (882 pounds) per package.

Citation: 49 CFR §173.62

SHIPPING PAPER REQUIREMENTS

1) Shipping description together and in order with no other information interspersed:

“UN 0012, Cartridges, small arms, 1.4S”

2) The total quantity before or after the shipping description, in pounds and/or kilograms (lb or kg), covered by the shipping description in terms of net explosives mass, or the net mass, i.e. the weight of the powder and primer mix (primer mix may be negligible compared to powder) in the ammunition or the weight of the ammunition without any packaging. The degree of decimals or rounding is not specified, the recommendation is to use whole units, e.g. 5 lbs.

3) The number and type of packages, before or after the shipping description, e.g. “10 boxes” or “10 drums”. Commonly understood abbreviations may be used, e.g. “bx” or “drm”.

HMDESCRIPTIONWEIGHT/LBS.
 XUN 0012, Cartridges, Small Arms, 1.4S
(Insert net weight or net explosives weight)

Citation: 49 CFR §172.202

PACKAGE MARKINGS

Packages containing small arms ammunition must display the following markings on one side as follows:

“UN 0012” ½” tall, or ¼” tall for 30 kg max, or an appropriate size for 5 kg max; “CARTRIDGES, SMALL ARMS”; the specification package marking.

In addition, each carton may have to be marked with the consignor’s or the consignee’s name and address, see 49 CFR §172.301(d) for exceptions.

Citation: 49 CFR §172.30049 CFR §172.301(d)

OVERPACK MARKINGS

An overpack is:

  • a pallet
  • a spec packaging within a non-spec packaging, normally used for consolidation

The “Overpack” marking is required if at least one representative marking is not visible of the UN number, proper shipping name and the specification packaging marking for every hazardous material in the overpack. If any of these are not visible at least once in the overpack, all markings and labels should be reproduced on one side of the over, in addition to the “OVERPACK” mark.

The word “OVERPACK” may be a sticker, stenciled, or on a printed sheet of paper. It must be at least 0.5” tall as of 12/31/2016. It does not have to have a surrounding border.

Citation: 49 CFR §173.25

ILLUSTRATIONS OF PROPERLY PREPARED DOCUMENT AND SHIPPING CARTON

Option 1:

HMDESCRIPTIONWEIGHT/LBS.
XUN0012 Cartridges, Small Arms, 1.4SNet Explosive Mass = X,XXX KG (propellant weight, or optionally the net weight in the US only)(Insert gross or net weight)

Option 2:

HMDESCRIPTIONWEIGHT/LBS.
XUN0012 Cartridges, Small Arms, 1.4S(Insert gross, net or net explosives weight)

* Per 49 CFR §172.301(d), the package must be marked with the consignor or consignee’s name and address unless the package is:

(1) Transported by highway only and will not be transferred from one carrier to the other;

(2) Part of a carload lot, truckload lot or freight container load, and the entire contents of the rail car, truck or freight container are shipped from one consignor to one consignee.

ALKALINE BATTERIES WITH MINIMAL REGULATION, INCLUDING NI-MH – INTERNATIONAL AIR

COMMODITY: Alkaline batteries, including Ni-MH Nickel Metal Hydride. These are mostly not regulated as dangerous goods except for basic packaging requirements to prevent short circuits and damage, and reporting is required in the rare case of an incident. Some additional requirements apply to sea and air transport, but the shipments are not generally impeded compared to non-hazardous goods.

MODE OF TRANSPORTATION: International Air

OVERVIEW

PROPER SHIPPING NAME:Batteries, dry; Batteries, nickel-metal hydrideLABEL:No
IDENTIFICATION NUMBER:None, or UN 3496 for Ni-MHPLACARD:N/A
HAZARD CLASS/DIVISION:None, or 9 for Ni-MHEMERG. INFO:No
PACKING GROUP:NoneTRAINING:No
DOCUMENT:Air Waybill onlyPACKAGING:Special
MARKING:No

DANGEROUS GOODS TABLE

CLASSIFICATION

Alkaline batteries, including nickel-metal hydride (Ni-MH), are mostly not regulated.

Citation: 49 CFR 172.101 HazMat Table, entry for Batteries, dry, sealed, n.o.s. 

SPECIAL PROVISIONS

These batteries are mostly exempted from the dangerous goods regulations, and the remaining requirements are contained in SP A199 for Ni-MH batteries or in SP A123  for all other alkaline batteries. The results are the same between SP A123 and A199 except the way they must be noted on the air waybill. The full text of the special provisions follow (certain parts of these may be replicated in other sections of this transport data sheet):

SPECIAL PROVISION A123 – SEALED ALKALINE BATTERIES OTHER THAN NI-MH

A123 This entry applies to Batteries, electric storage, not otherwise listed in Subsection 4.2–List of Dangerous Goods. Examples of such batteries are: alkali-manganese, zinc-carbon and nickel-cadmium batteries. Any electrical battery or battery powered device, equipment or vehicle having the potential of a dangerous evolution of heat must be prepared for transport so as to prevent:

(a) a short-circuit (e.g. in the case of batteries, by the effective insulation of exposed terminals; or, in the case of equipment, by disconnection of the battery and protection of exposed terminals); and

(b) unintentional activation.

The words “Not Restricted” and the Special Provision number must be included in the description of the substance on the Air Waybill as required by 8.2.6, when an Air Waybill is issued.

SPECIAL PROVISION A199 – NI-MH ALKALINE BATTERIES

A199 The UN number UN 3496 is only applicable in sea transport. Nickel-metal hydride batteries or nickel-metal hydride battery-powered devices, equipment or vehicles having the potential of a dangerous evolution of heat are not subject to these Regulations provided they are prepared for transport so as to prevent:

(a) a short circuit (e.g. in the case of batteries, by the effective insulation of exposed terminals; or, in the case of equipment, by disconnection of the battery and protection of exposed terminals); and

(b) unintentional activation.

The words “Not Restricted” and the Special Provision number must be included in the description of the substance on the Air Waybill required by 8.2.6, when an Air Waybill is issued.

Citation: IATA 4.4, SP 123 and A199

PACKAGING

Any electrical battery or battery powered device, equipment or vehicle having the potential of a dangerous evolution of heat must be prepared for transport so as to prevent:

(a) a short-circuit (e.g. in the case of batteries, by the effective insulation of exposed terminals; or, in the case of equipment, by disconnection of the battery and protection of exposed terminals); and

(b) unintentional activation.

Also follow the following USA requirements. Batteries and battery-powered device(s) containing batteries must be prepared and packaged for transport in a manner to prevent:

(1) A dangerous evolution of heat;

(2) Short circuits, including but not limited to the following methods:

(i) Packaging each battery or each battery-powered device when practicable, in fully enclosed inner packagings made of non-conductive material;

(ii) Separating or packaging batteries in a manner to prevent contact with other batteries, devices or conductive materials (e.g., metal) in the packagings; or

(iii) Ensuring exposed terminals or connectors are protected with non-conductive caps, non-conductive tape, or by other appropriate means; and

(3) Damage to terminals. If not impact resistant, the outer packaging should not be used as the sole means of protecting the battery terminals from damage or short circuiting. Batteries must be securely cushioned and packed to prevent shifting which could loosen terminal caps or reorient the terminals to produce short circuits. Batteries contained in devices must be securely installed. Terminal protection methods include but are not limited to the following:

(i) Securely attaching covers of sufficient strength to protect the terminals;

(ii) Packaging the battery in a rigid plastic packaging; or

(iii) Constructing the battery with terminals that are recessed or otherwise protected so that the terminals will not be subjected to damage if the package is dropped.

ADDITIONAL AIR TRANSPORT PACKAGING – BATTERIES >9V

For a battery whose voltage exceeds 9 volts—

(1) When contained in a device, the device must be packaged in a manner that prevents unintentional activation or must have an independent means of preventing unintentional activation (e.g., packaging restricts access to activation switch, switch caps or locks, recessed switches, trigger locks, temperature sensitive circuit breakers, etc.).

Citation: 49 CFR 172.102 Special Provision 130 

INCIDENT REPORTING

For transportation by aircraft, a telephone report in accordance with §171.15(a) is required if a fire, violent rupture, explosion or dangerous evolution of heat (i.e., an amount of heat sufficient to be dangerous to packaging or personal safety to include charring of packaging, melting of packaging, scorching of packaging, or other evidence) occurs as a direct result of a dry battery.

Additionally, for all modes of transportation, a written report submitted, retained, and updated in accordance with §171.16 is required if a fire, violent rupture, explosion or dangerous evolution of heat occurs as a direct result of a dry battery or battery-powered device.

Citation: 49 CFR 172.102 Special Provision 130 

DOCUMENTATION REQUIREMENTS

There is no  requirement for a dangerous goods declaration (shipping paper).

The words “Not Restricted” and the Special Provision number must be included in the description of the substance on the Air Waybill required by 8.2.6, when an Air Waybill is issued.

CARTON MARKING

There are no mandatory carton marking requirements.

The following illustration shows a sticker available from LabelMaster. There is a scenario for US domestic air transport where this is one of a couple options. This is not recommended for international air shipments, but does not need to be removed if present.

TRAINING

None.

ALKALINE BATTERIES WITH MINIMAL REGULATION, INCLUDING NI-MH – US DOMESTIC AIR

COMMODITY: Alkaline batteries, including Ni-MH Nickel Metal Hydride.

MODE OF TRANSPORTATION: US Domestic Air

OVERVIEW

These are mostly not regulated as dangerous goods except for basic packaging requirements to prevent short circuits and damage, and reporting is required in the rare case of an incident. Some additional requirements apply to sea and air transport, but the shipments are not generally impeded compared to non-hazardous goods.

PROPER SHIPPING NAME:Batteries, dry, sealed, n.o.s.LABEL:No
IDENTIFICATION NUMBER:NonePLACARD:No
HAZARD CLASS/DIVISION:NoneEMERG. INFO:No
PACKING GROUP:NoneTRAINING:No
DOCUMENT:NoPACKAGING:Special
MARKING:No

HAZMAT TABLE

CLASSIFICATION

Alkaline batteries, including nickel-metal hydride (Ni-MH), are mostly not regulated.

Citation: 49 CFR 172.101 HazMat Table, entry for Batteries, dry, sealed, n.o.s.

SPECIAL PROVISION 130

These batteries are mostly exempted from the hazardous materials regulations, and the remaining requirements are contained in SP 130. The full text of SP 130 follows (certain parts of this may be replicated in other sections of this transport data sheet):

130 “Batteries, dry, sealed, n.o.s.,” commonly referred to as dry batteries, are hermetically sealed and generally utilize metals (other than lead) and/or carbon as electrodes. These batteries are typically used for portable power applications. The rechargeable (and some non-rechargeable) types have gelled alkaline electrolytes (rather than acidic) making it difficult for them to generate hydrogen or oxygen when overcharged and therefore, differentiating them from non-spillable batteries. Dry batteries specifically covered by another entry in the §172.101 Table must be transported in accordance with the requirements applicable to that entry. For example, nickel-metal hydride batteries transported by vessel in certain quantities are covered by another entry (see Batteries, nickel-metal hydride, UN3496). Dry batteries not specifically covered by another entry in the §172.101 Table are covered by this entry (i.e., Batteries, dry, sealed, n.o.s.) and are not subject to requirements of this subchapter except for the following:

(a) Incident reporting. For transportation by aircraft, a telephone report in accordance with §171.15(a) is required if a fire, violent rupture, explosion or dangerous evolution of heat (i.e., an amount of heat sufficient to be dangerous to packaging or personal safety to include charring of packaging, melting of packaging, scorching of packaging, or other evidence) occurs as a direct result of a dry battery. For all modes of transportation, a written report submitted, retained, and updated in accordance with §171.16 is required if a fire, violent rupture, explosion or dangerous evolution of heat occurs as a direct result of a dry battery or battery-powered device.

(b) Preparation for transport. Batteries and battery-powered device(s) containing batteries must be prepared and packaged for transport in a manner to prevent:

(1) A dangerous evolution of heat;

(2) Short circuits, including but not limited to the following methods:

(i) Packaging each battery or each battery-powered device when practicable, in fully enclosed inner packagings made of non-conductive material;

(ii) Separating or packaging batteries in a manner to prevent contact with other batteries, devices or conductive materials (e.g., metal) in the packagings; or

(iii) Ensuring exposed terminals or connectors are protected with non-conductive caps, non-conductive tape, or by other appropriate means; and

(3) Damage to terminals. If not impact resistant, the outer packaging should not be used as the sole means of protecting the battery terminals from damage or short circuiting. Batteries must be securely cushioned and packed to prevent shifting which could loosen terminal caps or reorient the terminals to produce short circuits. Batteries contained in devices must be securely installed. Terminal protection methods include but are not limited to the following:

(i) Securely attaching covers of sufficient strength to protect the terminals;

(ii) Packaging the battery in a rigid plastic packaging; or

(iii) Constructing the battery with terminals that are recessed or otherwise protected so that the terminals will not be subjected to damage if the package is dropped.

(c) Additional air transport requirements. For a battery whose voltage (electrical potential) exceeds 9 volts—

(1) When contained in a device, the device must be packaged in a manner that prevents unintentional activation or must have an independent means of preventing unintentional activation (e.g., packaging restricts access to activation switch, switch caps or locks, recessed switches, trigger locks, temperature sensitive circuit breakers, etc.); and

(2) An indication of compliance with this special provision must be provided by marking each package with the words “not restricted” or by including the words “not restricted” on a transport document such as an air waybill accompanying the shipment.

(d) Used or spent battery exception. Used or spent dry batteries of both non-rechargeable and rechargeable designs, with a marked rating up to 9-volt that are combined in the same package and transported by highway or rail for recycling, reconditioning, or disposal are not subject to this special provision or any other requirement of the HMR. Note that batteries utilizing different chemistries (i.e., those battery chemistries specifically covered by another entry in the §172.101 Table) as well as dry batteries with a marked rating greater than 9-volt may not be combined with used or spent batteries in the same package. Note also that this exception does not apply to batteries that have been reconditioned for reuse.

Citation: 49 CFR 172.102 Special Provision 130

PACKAGING

Batteries and battery-powered device(s) containing batteries must be prepared and packaged for transport in a manner to prevent:

(1) A dangerous evolution of heat;

(2) Short circuits, including but not limited to the following methods:

(i) Packaging each battery or each battery-powered device when practicable, in fully enclosed inner packagings made of non-conductive material;

(ii) Separating or packaging batteries in a manner to prevent contact with other batteries, devices or conductive materials (e.g., metal) in the packagings; or

(iii) Ensuring exposed terminals or connectors are protected with non-conductive caps, non-conductive tape, or by other appropriate means; and

(3) Damage to terminals. If not impact resistant, the outer packaging should not be used as the sole means of protecting the battery terminals from damage or short circuiting. Batteries must be securely cushioned and packed to prevent shifting which could loosen terminal caps or reorient the terminals to produce short circuits. Batteries contained in devices must be securely installed. Terminal protection methods include but are not limited to the following:

(i) Securely attaching covers of sufficient strength to protect the terminals;

(ii) Packaging the battery in a rigid plastic packaging; or

(iii) Constructing the battery with terminals that are recessed or otherwise protected so that the terminals will not be subjected to damage if the package is dropped.

ADDITIONAL AIR TRANSPORT PACKAGING – BATTERIES >9V

For a battery whose voltage exceeds 9 volts—

(1) When contained in a device, the device must be packaged in a manner that prevents unintentional activation or must have an independent means of preventing unintentional activation (e.g., packaging restricts access to activation switch, switch caps or locks, recessed switches, trigger locks, temperature sensitive circuit breakers, etc.).

Citation: 49 CFR 172.102 Special Provision 130

INCIDENT REPORTING

For transportation by aircraft, a telephone report in accordance with §171.15(a) is required if a fire, violent rupture, explosion or dangerous evolution of heat (i.e., an amount of heat sufficient to be dangerous to packaging or personal safety to include charring of packaging, melting of packaging, scorching of packaging, or other evidence) occurs as a direct result of a dry battery.

Additionally, for all modes of transportation, a written report submitted, retained, and updated in accordance with §171.16 is required if a fire, violent rupture, explosion or dangerous evolution of heat occurs as a direct result of a dry battery or battery-powered device.

Citation: 49 CFR 172.102 Special Provision 130

DOCUMENTATION REQUIREMENTS

There is no shipping paper requirement.

Conditionally, for batteries >9 volts: An indication of compliance with Special Provision 130 must be provided by including the words “not restricted” on a transport document such as an air waybill accompanying the shipment. This is not required if “not restricted” is marked on the package.

The air way bill option is mandatory when shipping per IATA. This method is recommended, and only use the “not restricted” sticker on the package for US domestic air when control of the airway bill is not convenient.

CARTON MARKING

There are no mandatory carton marking requirements.

Conditionally, only for batteries >9 volts, an indication of compliance with Special Provision 130 must be provided by marking each package with the words “not restricted” if this information does not appear on the air way bill. This option should only be used when when control of the air way bill is not convenient.

This illustration shows a sticker available from LabelMaster. Only the words “Not Restricted” are required (which could be printed on a mailing label or printed on the box,

TRAINING

None.

UN 3481: MORE THAN 2 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT (2020 SCOPE); BY DOMESTIC ROAD, RAIL & VESSEL

REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET

COMMODITY:

A) 2020 Scope, or More Than 2 Small Lithium Ion Batteries In Equipment
B) Equipment with batteries not installed, but packed with it.

MODE OF TRANSPORTATION: Domestic Road, Rail & Vessel

OVERVIEW

PROPER SHIPPING NAME:Lithium ion batteries contained in equipmentLABEL:No
IDENTIFICATION NUMBER:UN 3481PLACARD:No
HAZARD CLASS/DIVISION:9EMERG. INFO:No
PACKING GROUP:NoneTRAINING:No
DOCUMENT:SpecialPACKAGING:Non-spec
MARKING:Special

HAZMAT TABLE

(1)Sym-bols(2)Hazardous materials descriptions and proper shipping names(3)Hazard class or Division(4)Identifi-cation Numbers(5)PG(6)Label Codes(7)Special provisions(§172.102)(8)Packaging (§173.***)(9)Quantity Limitations(see §§173.27 and 175.75)(10)Vesselstowage
Excep-tionsNon-
bulk
BulkPassenger aircraft/ rail
Cargo aircraft onlyLoca-
tion
Other
(1)(2)(3)(4)(5)(6)(7)(8A)(8)(8C)(9A)(9B)(10A)(10B)
GLithium ion batteries contained in equipment including lithium ion polymer batteries
9UN30919A54, A101
1851851855 kg35 kgA

CLASSIFICATION

Lithium cells and batteries must meet requirements of the UN Manual of Tests and Criteria. The manufacture must record the test results and maintain them (indefinitely).

This transport data sheet uses some of the small cells and batteries exceptions in 49 CFR 173.185(c). The criteria are:

  • may not exceed lithium ion batteries of 100 Watt-hours (Wh) each, or lithium ion cells not exceeding 20 Wh each.
  • Starting in 2016 lithium ion batteries using this exception must be marked with the watt-hour rating

The 2020 Scope has 4 batteries; only two batteries are allowed in the equipment to eliminate package marking or documentation. However, normal marking and documentation do not apply, and are replaced with special limited requirements.

Citation: 49 CFR 173.185(a), 49 CFR 173.185(c)

PACKAGING INFORMATION

Packaging must meet the general requirements of 49 CFR 173 Subpart B. Lithium batteries must be packaged in a manner to prevent short circuits, movement within the outer package and accidental activation of the equipment. Specification packaging does not apply.

Citation: 49 CFR 173 Subpart B, 49 CFR 173.185(b), 49 CFR 173.185(b)

SHIPPING PAPER REQUIREMENTS

Normal documentation requirements are waived and replaced with specific requirements. The text is performance-based, and not prescribed other than it must contain the following information:

(A) An indication that the package contains “lithium metal” or “lithium ion” cells or batteries, as appropriate;

(B) An indication that the package is to be handled with care and that a flammable hazard exists if the package is damaged;

(C) An indication that special procedures must be followed in the event the package is damaged, to include inspection and repacking if necessary; and

(D) A telephone number for additional information.

A document could be purchased, or the following text could be produced on Avery labels:

Citation: 49 CFR 173.185(c)(3)(iii)

CARTON MARKING

This handling label is required for air and can be used for all modes. The same information can be used in a different format for other modes, but it is recommended just to keep one sticker and use it for all shipments.

A phone number must be provided on the handling label. It could be an emergency phone number as required for many other hazardous materials, but this is not required, and it could be an office phone number. It should have the country code for international shipments.

The handling label must be at least 120 mm (4.7 inches) wide by 110 mm (4.3 inches) high. However, markings of 105 mm (4.1 inches) wide by 74 mm (2.9 inches) high may be used on when the package is too small for the larger mark.

Citation: 49 CFR 173.185

OVERPACKS

There are no hazardous materials marking or labeling requirements for overpacks of packages of equipment containing lithium cells or batteries when shipped according with this transport data sheet. This can be deduced from the fact that the air mode portion of 173.185 has overpack marking requirements, but it is not included in the general requirements for all modes. 

It may be easier for comprehension of personnel to adhere to standard overpack marking protocols in 173.25, unless there is enough extra labor to merit training about this peculiarity, and mark the overpack as follows:

Citation: 49 CFR §173.185(c)(4)(ii)§173.25

UN 3481: LAPTOP COMPUTERS W/ LITHIUM ION BATTERY INSTALLED, NO SPARE BATTERIES; BY DOMESTIC ROAD, RAIL & VESSEL

REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET

COMMODITY: Lithium ion battery contained in equipment, with no spare batteries

MODE OF TRANSPORTATION: Domestic Road, Rail & Vessel

OVERVIEW

PROPER SHIPPING NAME:Lithium ion batteries contained in equipmentLABEL:No
IDENTIFICATION NUMBER:UN 3481PLACARD:No
HAZARD CLASS/DIVISION:9EMERG. INFO:No
PACKING GROUP:NoneTRAINING:No
DOCUMENT:NoPACKAGING:Non-spec
MARKING:No

HAZMAT TABLE

(1)Sym-bols(2)Hazardous materials descriptions and proper shipping names(3)Hazard class or Division(4)Identifi-cation Numbers(5)PG(6)Label Codes(7)Special provisions(§172.102)(8)Packaging (§173.***)(9)Quantity Limitations(see §§173.27 and 175.75)(10)Vesselstowage
Excep-tionsNon-
bulk
BulkPassenger aircraft/ rail
Cargo aircraft onlyLoca-
tion
Other
(1)(2)(3)(4)(5)(6)(7)(8A)(8)(8C)(9A)(9B)(10A)(10B)
GLithium ion batteries contained in equipment including lithium ion polymer batteries
9UN30919A54, A101
1851851855 kg35 kgA

ABOUT LITHIUM BATTERIES

“Lithium Cells” are cylindrical. They can be very short, e.g. a lithium metal CR1620 coin cell / button cell, or longer like a CR2. “Lithium Batteries” are articles containing combinations of cells (e.g. a 9v battery contains multiple cells), and may be rectangular. Lithium ion energy is typically but not always synonymous with being rechargeable, whereas lithium metal is non-rechargeable. Cell phones and laptops use rechargeable lithium ion batteries which provide high output power for short periods of time, while goods such as optics may use lithium metal cells which provide long term low output power.

Lithium batteries which are improperly manufactured or packaged may self-ignite in flame, and are not extinguishable with small amounts of water.

CLASSIFICATION

Lithium cells and batteries must meet requirements of the UN Manual of Tests and Criteria. The manufacture must record the test results and maintain them (indefinitely).

This transport data sheet uses the small cells and batteries exceptions in 49 CFR 173.185(c). The criteria are:

  • may not exceed lithium ion batteries of 100 Watt-hours (Wh) each, or lithium ion cells not exceeding 20 Wh each. Starting in 2016 lithium ion batteries using this exception must be marked with the watt-hour rating.
  • only four cells or two batteries may be installed in the equipment
  • no spare batteries may be packed with the equipment.

Shipments meeting these criteria are excepted from package marking or documentation.

Citation: 49 CFR 173.185(a), 49 CFR 173.185(c)

PACKAGING INFORMATION

Packaging must meet the general requirements of 49 CFR 173 Subpart B. They must be packaged in a manner to prevent short circuits, movement within the outer package and accidental activation of the equipment. This may be done by closing the laptop, as the power button is on the inside, and packing it to prevent movement in the package. Specification packaging does not apply.

Citation: 49 CFR 173 Subpart B, 49 CFR 173.185(b), 49 CFR 173.185(b)

SHIPPING PAPER REQUIREMENTS

Normal documentation requirements are waived when transported by road. Equipment containing lithium cells or batteries is still hazmat, but are not marked “HM” on the shipping document because they are not subject to documentation requirements in 49 CFR 173 Subpart C.

HMDESCRIPTIONWEIGHT/LBS.
Laptop computer(Insert gross or net weight)

Citation: 49 CFR 173.185

CARTON MARKING

There are no hazardous materials marking or labeling requirements for packages of equipment containing lithium cells or batteries when shipped according with this transport data sheet.

Citation: 49 CFR 173.185

OVERPACKS

There are no hazardous materials marking or labeling requirements for overpacks of packages of equipment containing lithium cells or batteries when shipped according with this transport data sheet.

Citation: 49 CFR §173.25

UN 3175: WIPES IN PACKETS (NOT REGULATED)

REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET

COMMODITY: Wipes containing RemOil® with or without MoistureGuard; Brite Bore, 40-X Bore Cleaner; when packaged in packets are not regulated as hazmat / dangerous goods anywhere, by any mode.

MODE OF TRANSPORTATION: All

NOTE: Hazardous flammable liquids absorbed in non-hazardous solids are regulated as hazardous materials, with certain exceptions. Wipes not regulated when there is 10mL maximum of flammable liquid, other than Packing Group I, and the wipe is packaged in a sealed packet. The regulatory path from UN 3175 to be exempted from the regulations is described below.

OVERVIEW – this shows the fully regulated version.

PROPER SHIPPING NAME:Solids containing flammable liquid, n.o.s. (petroleum distillates)LABEL:Flammable solid
IDENTIFICATION NUMBER:UN 3175PLACARD:Flammable solid
HAZARD CLASS/DIVISION:4.1EMERG. INFO:Yes
PACKING GROUP:IITRAINING:Yes
DOCUMENT:YesPACKAGING:Yes
MARKING:Yes  

HAZARDOUS MATERIALS TABLE

(1)Sym-bols(2)Hazardous materials descriptions and proper shipping names(3)Hazard class or Division(4)Identifi-cation Numbers(5)PG(6)Label Codes(7)Special provisions(§172.102)(8)Packaging (§173.***)(9)Quantity Limitations(see §§173.27 and 175.75)(10)Vesselstowage
Excep-tionsNon-
bulk
BulkPassenger aircraft/ rail
Cargo aircraft onlyLoca-
tion
Other
(1)(2)(3)(4)(5)(6)(7)(8A)(8)(8C)(9A)(9B)(10A)(10B)
Solids containing flammable liquid, n.o.s.3UN3175II4.147, IB6, IP2, T3, TP33
15121224015 kg50 kgB

BASIS OF THE REGULATORY EXCEPTION

Wipes containing RemOil or other flammable liquids, are not regulated when meeting certain criteria, per similar special provisions of the USA, and international ocean and air transport regulations. The criteria are:

  1. First, there can be no free liquid at the time of filling to be classed into UN 3175, unless  flammable solid testing is done.
  2. To then exit the regulations:
    1. Package in a sealed packet
    2. Have no more than 10 mL of liquid absorbed
    3. Liquid must be PG II or III (not PG I)
    4. Have no free liquid

RemOil packets qualify, as they are sealed, contain less than 10 mL of RemOil, RemOil and other Remington cleaners are PG II or less, and the wipes have no free liquid. The special provisions are shown below for the USA, IMDG and ICAO TI.

SPECIAL PROVISION 47 – USA

“Mixtures of solids that are not subject to this subchapter and flammable liquids may be transported under this entry without first applying the classification criteria of Division 4.1, provided there is no free liquid visible at the time the material is loaded or at the time the packaging or transport unit is closed. Except when the liquids are fully absorbed in solid material contained in sealed bags, for single packagings, each packaging must correspond to a design type that has passed a leakproofness test at the Packing Group II level. Small inner packagings consisting of sealed packets and articles containing less than 10 mL of a Class 3 liquid in Packing Group II or III absorbed onto a solid material are not subject to this subchapter provided there is no free liquid in the packet or article.”

SPECIAL PROVISION 216 – INTERNATIONAL MARITIME REGULATIONS 

“Mixtures of solids which are not subject to the provisions of this Code and flammable liquids may be transported under this entry without first applying the classification criteria of class 4.1, provided there is no free liquid visible at the time the substance is loaded or at the time the packaging or cargo transport unit is closed. Each cargo transport unit shall be leakproof when used as a bulk container. Sealed packets and articles containing less than 10 mL of a packing group II or III flammable liquid absorbed into a solid material are not subject to the provisions of this Code provided there is no free liquid in the packet or article.”

SPECIAL PROVISION A46 – INTERNATIONAL MARITIME REGULATIONS 

Mixtures of solids which are not subject to these Instructions and flammable liquids may be transported under this entry without first applying the classification criteria of Division 4.1, providing there is no free liquid visible at the time the substance is packaged and, for single packagings, the packaging must pass a leakproofness test at the Packing Group II level. Small inner packagings consisting of sealed packets or articles containing less than 10 mL of a Packing Group II or III flammable liquid absorbed into a solid material are not subject to these Instructions provided there is no free liquid in the packet or articles.

SOME OTHER EXCEPTIONS

Depending on the flash point, RemOil® and other flammable liquids may be partially or fully excepted as combustible liquids from the hazardous materials regulations, and in some cases international regulations. Some specifics are given in the relevant transport data sheet. These exceptions are not needed when the flammable liquids are incorporated into wipes, meeting certain criteria. In case of a full exception, then the criteria above are not necessary. RemOil, with a flashpoint of 105F, does not qualify for a full exception except in wipes.

Citation: 49 CFR 172.102 SP47; IMDG SP216; ICAO TI SP A47

UN 1993: REMOIL® LIQUID, W/ OR W/O MOISTUREGUARD; BY INTERNATIONAL AIR

REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET

COMMODITY: RemOil®, with or without MoistureGuard; in liquid form, in outer packages up to 60 L (15.8 gallons).

MODE OF TRANSPORTATION: International Air

OVERVIEW

PROPER SHIPPING NAME:Flammable liquid, n.o.s. (petroleum distillates)LABEL:Yes
IDENTIFICATION NUMBER:UN 1993PLACARD:N/A
HAZARD CLASS/DIVISION:3EMERG. INFO: Yes
PACKING GROUP:IIITRAINING:Required
DOCUMENT:YesPACKAGING:Spec
MARKING:Yes  

DANGEROUS GOODS LIST

CLASSIFICATION

RemOil has a flashpoint of 105F, and therefore it is a PG III flammable liquid. It is comprised of petroleum distillates and petroleum oil. These are both dangerous goods, and in pure forms would be shipped as UN 1268 Petroleum Distillates, N.O.S. and UN 1268 Petroleum Products, N.O.S.

It is shipped as UN 1993 with the proper shipping name “Flammable liquid, n.o.s. (petroleum distillates)”. The abbreviation n.o.s. means “not otherwise specified”. N.O.S. entries are used when a specific proper shipping name does not exist, or the product is a mixture. Since petroleum distillates are the primary component, they are used for the technical name in parentheses.

Citations: IATA Chapter 3.2; Dangerous Goods List

LIMITED QUANTITIES


RemOil liquid is eligible for LQ-Air up to 1oL per shipping case. However Remington’s policy is to mark packages of RemOil as LQ for surface.  Therefore the LQ-Y mark should never be used.Unlike other modes where LQ has significant cost savings, the only exception by air is from package testing; there is no exception from shipping papers or labeling.

Many airlines have filed variations prohibiting LQ shipments, which would necessitate labor to obliterate the Y-mark. There is an example in the IATA DGR that the LQ surface mark may remain on the package and be ignored in international air. This eliminates the labor to remove it, and allows the package to be LQ during the international journey on the surface leg subsequent to air transport.

Citations: IATA 2.8.3.5 (operator restrictions); Dangerous Goods List Columns G & H (LQ is forbidden); 7.1.5.5 and Figure 7.2.A (the ground LQ mark is allowed and ignored)

PACKAGING INFORMATION

RemOil is classified as UN 1993, PG III, and therefore must be packed according to Packing Instruction 355:

  • The package must be tested, and bear the specification package mark, for example:
  • The maximum gross weight is typically 400 kg (882 pounds) per package (bearing in mind the maximum net capacity is 60 L for passenger aircraft or 220 L for cargo-aircraft-only).
  • The outer packaging codes are specifications with minimum standards of construction and maximum gross weights.

Citation: IATA 6.0.4.1 marking, 6.2 specifications, 6.3 testing

SHIPPING PAPER REQUIREMENTS

International air transport is subject to the requirements of IATA, the International Air Transport Association. A special document is required called a Dangerous Goods Declaration (DGD) in addition to any standard bill of lading. Fill out the DGD as follows in four sequences:

Sequence 1 – Dangerous Goods Identification

The sequence is: “UN 1993, Flammable liquid, n.o.s. (petroleum distillates), 3, PG III”.

For different UN numbers each change to Sequence 1 must be on a new line. For different bottle sizes of the same Sequence 1 information, Sequence 1 can be done once and associated with more than one line in Sequence 2 (read below).

Sequence 2 – Quantity and Type of Packing

The sequence is “QUANTITY PACKAGING:MATERIAL-TYPE X NET-QUANTITY”, e.g. “5 fibreboard boxes X 4.5 kg”. Quantity is the number of shipping cases (packages). The degree of rounding is not specified, but may be to the nearest kilogram, and should be consistent between the DGD, package and overpack markings. Packaging type is denoted by material and type, e.g. “fibreboard boxes” or “steel drums”. Metric units must be used, which for liquids is “L” for liters, upper case; metric units are case sensitive, e.g. kg is lower case.

For multiple products, each change to Sequence 2 must be on a different line, e.g. different net weight, but Sequence 1 does not have to be repeated if together. See IATA DGR Figure 8.1.K.

When overpacks are used:

  • Packaging in overpacks must be listed first.
  • The wording “Overpack Used” must be inserted on the declaration form immediately after all the entries in the overpack.
  • When a consignment consists of multiple overpacks each overpack must have an identification marking any alpha-numeric format) and be marked with the total quantity of dangerous goods within the overpack including the unit of measurement.
  • The total quantity(ies) shown on the Shipper’s Declaration must match the total quantity(ies) shown on the overpack.
  • Multiple overpacks with identical contents must be identified as follows: “Overpack Used X (number of identical overpacks)”, (see IATA Figure 8.1.L and Figure 8.1.N, examples 8 and 10). Multiple overpacks with different contents must be identified by listing them separately

Sequence 3 –Packing Instruction

Write the number of the applicable packing instruction, “355”.

Sequence 4 – Authorizations

Use this to describe any government authorizations, e.g. EX numbers for explosives. This column is likely not applicable to RemOil, and may be left blank.

The following example is for a pallet of RemOil 2-oz bottles, and a second pallet with both 2-oz and RemOil and ammunition. The dashed red line is put there to distinguish the two different pallets, and is not part of the document. For more information, see IATA Figure 8.1.N on shipping liquids and solids on the same pallet.

Citation: IATA 8.1.6.9

CARTON MARKING & LABELING

Upper case letters are not required, but are better than lower case to meet the text size requirements uniformly. Packages containing small arms ammunition must display the following markings and at least 6mm (1/4”) high, or an appropriate size for packages which are ≤5 kg net, as follows:

  • Proper shipping name – “FLAMMABLE LIQUID, N.O.S. (PETROLEUM DISTILLATES)”
  • UN# – “UN 0012”
  • the full name and address of the shipper and the consignee, located on the same package surtace and near the proper shipping name, if the package dimensions are adequate;
  • per IATA requirements, the net quantity, in liters, abbreviated “L” in upper case, e.g. “0.34 L”. The “L” has to be in upper case per the specifications of the metric system (“kg” has to be lower case). The net quantity must be marked adjacent to the UN number and proper shipping name. It may be rounded to the nearest liter, or to a desired level of decimals for better accuracy and alignment with the overpack weight. The net quantity should be identical to that shown on the Dangerous Goods Declaration document.
  • the specification package marking, placed in a location and of such size relative to the package as to be readily visible. Must be pre-printed or affixed, and not handwritten. For packages with a gross weight exceeding 30 kg the marking, or a duplicate thereof, must appear on the top or on the side of the package. For example:

The Class 3 hazard label must be applied as follows:

  • When the package dimensions are adequate, labels must be located on the same surface of the package near the proper shipping name marking.
  • Labels should be affixed adjacent to the shipper’s or consignee’s address appearing on the package.
  • Unless the package dimensions are inadequate, the label(s) must be affixed at an angle of 45 degrees (diamond shaped) to the surrounding markings.

The surface LQ mark is not valid in international air transport, but may remain on the package and be ignored in air transport, and be valid for further surface transport when the air journey is over. See IATA 7.1.5.5 and IATA Figure 7.2.A.

Citation: IATA 6.0.4.1, 7.1.4, 7.1.5, 7.2.6.2

OVERPACK MARKINGS

Examples of overpacks include pallets and specification packages placed in another packaging. International air transport is subject to the requirements of IATA, the International Air Transport Association, which requires unique pallet markings.

Unless all markings and labels representative of all dangerous goods in the overpack are clearly visible, the overpack must be marked with:

  • the word “OVERPACK” in letters at least 12 mm (1/2”) high;
  • UN number
  • proper shipping name
  • full names and addresses of the consignor and consignee

The following requirements apply even if all markings are visible:

  • If there is more than one UN number in an overpack, write each UN number and the total quantity of dangerous goods for each UN number.
  • If there are two or more overpacks, name and mark each pallet with a unique identification mark (which may be in any alpha-numeric format) and the total quantity of dangerous goods, as indicated on the Dangerous Goods Declaration.

Normally we would use this OVERPACK sticker for domestic shipments:

However since there is so much information required, we print it on a piece of paper instead, with OVERPACK and the UN number in 1/2″ print, and affix it to the pallet. Following are two examples corresponding to the example shippers declaration above, one for RemOil alone on a pallet, and another for both RemOil and ammo on the same pallet:

Citation: IATA 7.1.7

NA3178: SMOKELESS POWDER FOR SMALL ARMS (FLAMMABLE SOLID); BY DOMESTIC TRANSPORTATION ALL MODES

REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET

COMMODITY: Smokeless powder for small arms; classified by EX approval as a flammable solid; up to 8 pounds per bottle and 100 pounds net per shipment.

MODE OF TRANSPORTATION: Domestic Road, Rail, Vessel and Air, with limitations

OVERVIEW

PROPER SHIPPING NAME:Smokeless powder for small armsLABEL:Yes
IDENTIFICATION NUMBER:NA 3178PLACARD:If with other hazmat exceeding 1000 lbs. gross aggregate
HAZARD CLASS/DIVISION:4.1EMERG. INFO:Yes
PACKING GROUP:ITRAINING:Required
DOCUMENT:YesPACKAGING:Special
MARKING:Yes

HAZMAT TABLE

(1)Sym-bols(2)Hazardous materials descriptions and proper shipping names(3)Hazard class or Division(4)Identifi-cation Numbers(5)PG(6)Label Codes(7)Special provisions(§172.102)(8)Packaging (§173.***)(9)Quantity Limitations(see §§173.27 and 175.75)(10)Vesselstowage
Excep-tionsNon-
bulk
BulkPassenger aircraft/ rail
Cargo aircraft onlyLoca-
tion
Other
(1)(2)(3)(4)(5)(6)(7)(8A)(8)(8C)(9A)(9B)(10A)(10B)
DSmokeless powder for small arms (100 pounds or less)
4.1NA3178I4.116
None171NoneForbidden7.3 kgA

CLASSIFICATION

Per 49 CFR 173.171, Smokeless powder for small arms which has been classed in Division 1.3 or Division 1.4 may be reclassed in Division 4.1 (flammable solid), subject to certain conditions. An EX approval is required, but the EX number does not need to be marked per 172.320 since it is a flammable solid and no longer an explosive.

Citation: 49 CFR 171.171(a)

MODAL LIMITATIONS

Road: Maximum 100 pounds net mass per transport vehicle, e.g. a trailer. A motor vehicle with multiple trailers could have 100 pounds in each trailer, or a truck with cargo compartment could have 100 pounds and haul a trailer with an additional 100 pounds.

Rail: Maximum 100 pounds net mass per transport vehicle, e.g. a rail car.

Vessel: Maximum 100 pounds net mass per freight container, not to exceed four freight containers per vessel.

Air: Passenger aircraft is forbidden. Maximum 100 pounds net mass per cargo aircraft. Per Column 9b of the hazardous materials, each package is limited to 7.3 kg (16 pounds).

Citation: 49 CFR 171.171(b)

PACKAGING INFORMATION

Smokeless powder may be transported as Division 4.1 flammable solids when packaged as follows:

  • in a configuration examined and approved in an EX approval.
  • in a Packing Group I certified package (per the hazardous materials table). While explosives are packaged as PG II by default, this alternative method uses PG I packaging, a higher standard than PG II.
  • only combination packagings with inner packagings not exceeding 3.6 kg (8 pounds) net mass are authorized. Inner packagings must be arranged and protected so as to prevent simultaneous ignition of the contents.
  • 49 CFR 173.171 allows the configurations authorized in an EX approval to be modified as follows. Different brands and sizes of approved flammable solid smokeless powder inner packages may be combined in a 4G fiberboard box tested to Packing Group I, but not necessarily tested with the mixture of packages just described. All inside containers must be packed to prevent shifting (e.g. with packing materials), and the net weight of smokeless powder in any one box may not exceed 7.3 kg (16 pounds) or the certified gross weight capacity of the specification outer packaging, whichever is lower. There is no 16 pound limit for authorized packages which do not use this provision, except on aircraft, e.g. a box might contain six 5-pound bottles, but if this is modified with other brands or sizes then the 16 pounds net limit applies.

Citation: 49 CFR 172.10149 CFR 171.171(c) and (d)

SHIPPING PAPER REQUIREMENTS

1) Shipping description together and in order with no other information interspersed:

“NA 3178, Smokeless powder for small arms, 4.1, PG I”.

2) The total quantity before or after the shipping description, in pounds and/or kilograms (lb or kg), covered by the shipping description.

3) The number and type of packages, before or after the shipping description, e.g. “10 boxes” or “10 drums”. Commonly understood abbreviations may be used, e.g. “bx” or “drm”.

4) Since this is a flammable solid, there is no EX marking or shipping paper requirement, and no net explosives quantity required.

HMDESCRIPTIONWEIGHT/LBS.
 XNA 3178, Smokeless powder for small arms, 4.1, PG I(Insert gross or net weight)

Citation: 49 CFR 172.202

CARTON MARKING

Packages containing flammable solid smokeless powder must display the following on one side:

Label: Flammable solid hazard label

Markings

1) Identification number: “NA 3178” ½” tall, or ¼” tall for 30 kg max, or an appropriate size for 5 kg max;

2) Proper shipping name: “SMOKELESS POWDER FOR SMALL ARMS”;

3) the specification package marking.

4) In addition, each carton may have to be marked with the consignor’s or the consignee’s name and address, see 49 CFR §172.301(d) for exceptions.*

5) Since this is a flammable solid, there is no EX number marking requirement.

Citation: 49 CFR §172.301172.400

* Per 49 CFR §172.301(d), the package must be marked with the consignor or consignee’s name and address unless the package is:

(1) Transported by highway only and will not be transferred from one carrier to the other;

(2) Part of a carload lot, truckload lot or freight container load, and the entire contents of the rail car, truck or freight container are shipped from one consignor to one consignee.

OVERPACKS

The “OVERPACK” marking is only required if the package markings and label are not visible at least once, in which case the  “overpack” marking (e.g. sticker) is required on only one side of the pallet or overpack box, and the UN number, proper shipping name and hazard label must be replicated, preferably next to the overpack marking..

Remington policy is to apply the overpack and package markings and labels to all pallets, regardless of visibility of product underneath. The Overpack sticker can be replaced by a sheet of paper or label that says “OVERPACK” in 1/2″ letters or bigger, e.g. on a paper list of goods applied to the overpack.

Citation: 49 CFR §173.25