Product Alert Notification: CSB #99 Rev Q

Transcription

1 Product Alert Notification: CSB #99 Rev Q To: Sensitech Customers and Distributors From: Client Services Date: 1 March 2017 Re: 2017 IATA/ICAO Dangerous Goods Regulations, U.S. Department of Transportation (DOT) 49 CFR Parts , and International Maritime Dangerous Goods (IMDG) regulations PLEASE NOTE The U.S. Department of Transportation Pipeline & Hazardous Materials Safety Administration (PHMSA) has temporarily withdrawn its HM-215N Final Rule which puts a hold on new battery regulations. This temporary withdrawal makes the United States out of synch with the implementation of the 2017 IATA Dangerous Goods Regulation, 58 th Edition. The U.S. dangerous goods regulations are adopted by the Department of Transportation (DOT) under the Pipeline and Hazardous Materials Safety Administration (PHMSA). In 2016, PHMSA proposed the HM-215N final rule, which aligns the 49 CFR with the 58 th Edition of the IATA Dangerous Goods Regulations (IATA-DGR) 2016 International Maritime Dangerous Goods regulations (IMDG) ICAO Technical Instructions The final rule HM-215NA was scheduled to be effective January 26, 2017, but was withdrawn five days earlier. This temporary withdrawal is in effect until a department or agency head appointed or designated by the President reviews and approves the regulation. This temporary withdrawal is a direct result of President Trump s executive memorandum placing a freeze on all new regulations. To meet the current U.S. PHMSA requirements, please see the following two letters from David Brennan, Assistant Director, Cargo Safety and Standards, IATA. Further in this document, following the IATA letters is a full review of Sensitech s data collection devices and instructions for proper labelling. Page 1 of 13 (978) (800) FAX (978)

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4 Sensitech Products Lithium Metal Cells TempTale Direct, TempTale 4, TempTale Ultra, TempTale RF, TempTale 4 Bio, TempTale 4 Humidity, TempTale 4 Dry Ice Probe, TempTale 4 Probeless Dry Ice, TempTale 4 USB, TempTale 4 USB Dry Ice, TempTale 4 Multi-Alarm, TempTale 4 USB Multi-Alarm, TempTale Probe and Dual Sensor, VaxAlert USB, VaxAlert, TagAlert, FreezeAlert, ThermoAlert, South African Exporter, Chilean Exporter Reason for Notification The old Lithium Handling Label is still in effect by IATA for a grace period until January 1, Sensitech will continue to communicate any changes that may affect the use of our products to the market as soon as they become available to us. The Sensitech products listed above can be shipped via air, ground, and ocean in accordance with UN 3091, Packing Instruction 970 Section II Excepted Lithium Metal and Lithium Alloy Cells and Batteries, U.S. Department of Transportation 49 CFR Parts , and IMDG Packing Instruction 903. All Sensitech products containing metal cells or batteries meet General Requirements under IATA - PI970, and IMDG PI903. Devices such as radio frequency identification (RFID) tags, watches and temperature loggers, which are not capable of generating a dangerous evolution of heat, may be transported when intentionally active. When active, these devices must meet defined standards for electromagnetic radiation to ensure that the operation of the device does not interfere with aircraft systems. (IATA Dangerous Goods Regulations 2017, PI 970 Section II.) All Sensitech products comply with the current documented requirements as follows: DOT Lithium Battery - Hazardous Material Regulations (HMR; 49 CFR Parts ) IATA 2017 IATA Dangerous Goods Regulations 58 th Edition IMDG 2016 International Maritime Dangerous Goods Regulations Sensitech has performed all necessary testing and can provide documentation supporting our compliance at your request. Page 4 of 13

5 Requirements for Packages Containing Lithium Metal Cells or Batteries To summarize the meaningful change from the 57 th Edition to 58 th Edition 2017 IATA Dangerous Goods Regulations, IATA has changed its Lithium Battery Handling Label or Mark requirements definition from a level to a consignment level when consignments exceed two s. This change in regulation takes effect January 1, o A Consignment is one or more s of dangerous goods accepted by an operator (airline) from one shipper at one time and at one address, receipted for in one lot, and moving to one consignee at one destination address. (IATA, Lithium Battery Guidance Document, Revised 9 March 2016) o Please see specific Sensitech products and the number of s and devices that require the Lithium Battery Handling Label or Mark in the Product Breakdown table at the end of this CSB. IATA has stated there will be a two-year grace period from January 1, 2017 to December 31, 2018 to switch from the current Lithium Battery Handling Label to the new UN 3091 label (or mark, however, the consignment-level labeling requirement will go into effect starting January 1, PI 970 Additional Requirements Section II: Applicable air shipments require a label (see below Product Breakdown for Sensitech specific products that may require a label depending on the number of for consignments with two s or less or for consignments that contain three or more s). Air label examples are shown below. o Labeled shipments must contain the words Lithium metal batteries in compliance with Section II of PI 970 included on the air waybill, when an air waybill is used. The information should be shown in the Nature and Quantity of Goods box of the air waybill. The must be of such size that there is adequate space to affix the mark on one side of the without the mark being folded. PI 970 Additional Requirements Section II: EXCEPTIONS Not Requiring Labeling o s containing (including circuit boards). A Button cell or battery is defined as a round small cell or battery when the overall height is less than the diameter. (IATA, Lithium Battery Guidance Document, Revised 9 March 2016) (Note: The majority of Sensitech s products fall into this category see Product Breakdown table below.) o consignments of two s or less where each contains no more than four cells or two batteries contained in equipment. ** An IATA Shipper's Declaration for Dangerous Goods ** is not required. No additional fees should be incurred based on the use of either of these Lithium Battery Handling Labels (see below). Page 5 of 13

6 Special procedures must be followed in the event the is damaged to include inspection and repacking if necessary. o No transportation via air services allows for damaged s or s. At the time of this publication, ground regulatory (49 CFR, ADR and Transport Canada) authorities have yet to adopt the new Lithium Battery Handling label as presented by the 58 th Edition of the IATA Dangerous Goods Regulations. Until a final rule is issued by the dangerous goods/hazardous materials ground regulatory authorities, the current/existing Lithium Metal Handling label (see below) is required for ground s when required by the appropriate regulation. Current air and ground label (USE for ALL Shipments, within 2-year IATA grace period until January 1, 2019) NEW: Lithium battery label effective January 1, 2017 with a 2-year grace period for switching to the new label from the old label by January 1, 2019 Minimum dimensions: 120 x 110 mm Color: Black with red hatching on a contrasting background Red hatching must be 5mm Page 6 of 13

7 Product Breakdown Sensitech Device Maximum number of Consignment without IATA labeling requirements: Battery Style Comments IATA (Air) Labeling Requirement(s) Consignment: Is the equivalent to the term shipment, means one or more pieces of goods accepted by the airline from one shipper at one time and to one address, receipted for in one lot, and moving on one air waybill or one shipment record to one consignee at one destination address. (1) Shipper & (1) shipment/consignment to (1) airlines to (1) consignee NOTE: Each individual Sensitech device contains a single Lithium Metal Cell (except the TempTale 4 Probeless Dry Ice and TempTale 4 USB Dry Ice contain 2 batteries in one pack) TempTale Direct No Maximum / TempTale Ultra No Maximum / 0.17 grams TempTale 4 No Maximum / Page 7 of 13

8 TempTale 4 Multi-Alarm (non-usb) No Maximum / 0.3 grams of TempTale 4 Bio No Maximum / TempTale 4 Humidity No Maximum / TempTale 4 Dry Ice Probe No Maximum / Page 8 of 13

9 ThermoAlert No Maximum / FreezeAlert No Maximum / TagAlert No Maximum / VaxAlert No Maximum / TempTale Probe and Dual Sensor No Maximum / Page 9 of 13

10 TempTale RF 4 devices or less More than grams of s or less where each contains no more than 4 devices* = s = Label 4 Devices = No Label >4 Devices = Label II (additional TempTale 4 Probeless Dry Ice 2 devices or less More than grams s or less where each contains no more than 2 devices* = s = Label 2 Devices = No Label >2 Devices = Label TempTale 4 USB 4 devices or less More than grams of s or less where each contains no more than 4 devices* = s = Label 4 Devices = No Label >4 Devices = Label Page 10 of 13

11 TempTale 4 USB Dry Ice 2 devices or less More than grams s or less where each contains no more than 2 devices* = s = Label 2 Devices = No Label >2 Devices = Label TempTale 4 USB Multi- Alarm 4 devices or less More than grams of s or less where each contains no more than 4 devices* = s = Label 4 Devices = No Label >4 Devices = Label VaxAlert USB 4 devices or less More than grams of s or less where each contains no more than 4 devices* = s = Label 4 Devices = No Label >4 Devices = Label Page 11 of 13

12 TempTale 4 USB Chilean Exporter 4 devices or less More than grams of s or less where each contains no more than 4 devices* = s = Label 4 Devices = No Label >4 Devices = Label TempTale 4 USB South African Exporter 4 devices or less More than grams of s or less where each contains no more than 4 devices* = s = Label 4 Devices = No Label >4 Devices = Label IMPORTANT MESSAGE: More than 2 s per consignment regardless of the amount of Sensitech requires a Lithium Battery Handling Label or (Mark) unless the device contains a button cell which does not require a label. The presence of the Lithium Battery Handling Label (Mark) on the (s) triggers the requirement for the following statement to be included on the Air Waybill Lithium Metal Batteries in compliance with Section II of PI970" *Reference: IATA, Dangerous Goods Regulations, Packing Instruction 970 Section II (Additional Requirements) Note: Supporting documentation available upon request are Material Safety Datasheets (MSDS) from the specific battery manufacturers and the caution label displayed above. Additionally, we can provide upon request, compliance certifications relative to drop and vibration testing, CE testing, IP Code Testing, and RTCA/DO160 G testing. Page 12 of 13

13 Customer Support If you have any questions about this information, please contact your local Client Services team at one of our Regional Headquarters. USA World Headquarters: or Canada: South America: or (Chile) or (Brazil) EMEA: Asia: Global The information and recommendations set forth in this Product Alert are made in good faith and believed to be accurate as of the date of preparation. The information is provided for your general guidance and is not intended to provide you with legal advice. Sensitech Inc. makes no warranty, expressed or implied, with respect to this information and disclaims all liabilities from reliance on it. Please consult your own legal advisor before taking any action based on the information provided herein. Page 13 of 13