When is a sample really a “sample”? It is essential to discern what is meant by the word “sample” from a regulatory perspective versus common, everyday language. The International Air Transportation Association’s (IATA’s) Dangerous Goods Regulations (DGR) specify rules at IATA DGR 3.11 for the “Transport of Samples for Further Testing.” However, these rules are specifically for when the hazard class of a substance is uncertain, and it is being transported for further testing for hazard identification. If you are shipping a “sample” for quality control, or customer review, it must be regulated as ordinary dangerous goods. We’ll look at both options.
Transport of Samples for Further Testing
Assign a Tentative Hazard Class and Proper Shipping Name (PSN)
If the hazard class of your material is uncertain, to ship it to the lab, you will have to use the knowledge you have to assign the sample a tentative hazard class, and proper shipping name and UN identification number. If the PSN you have chosen has a choice of packing groups, you must select the most stringent one. (PG I is the most stringent, PG II is a moderate hazard, and PG III is the least hazardous within a hazard class.)
The Proper Shipping Name
There are a few proper shipping names on the IATA DGR 4.2 List of Dangerous Goods that incorporate the word “sample.”
They are:
1. Gas sample, non-pressurized, toxic, flammable, n.o.s.,
2. Gas sample, non-pressurized, toxic, n.o.s., not refrigerated liquid,
3. Gas sample, non-pressurized, toxic, flammable, n.o.s., not refrigerated liquid; and
4. Chemical sample, toxic.
If this is what you’re shipping, you must use one of these appropriate names. If you’ve chosen a different PSN, then you must add the word “sample.” For example: Corrosive solid, n.o.s. sample. It is not necessary to supplement a tentative n.o.s. sample name with the technical name.
Prohibitions
You may not use the “sample” regulations to ship the following materials:
• Anything that is a forbidden substance named in IATA DGR 2.1.1;
• Class 1 explosives;
• Infectious substances; or
• Radioactive materials
In addition, you must comply with special sample rules for self-reactive substances (IATA DGR 3.4.1.2.5) and organic peroxides (IATA DGR 3.5.2.6).
Packaging
These samples must be transported in combination packaging. The net weight of the material must be less than or equal to 2.5 kg. No other goods (dangerous or not) may be in the same package.
Transport of Samples for Quality Control or Customer Review
If a “sample” is being shipped for any other reason than to test for properties/components to determine classification, it must be offered as any other dangerous goods. It must be accurately classified and named. Do not add the word “sample” to the PSN.
Depending on the packaging options tied to the PSN on the IATA DGR 4.2 list of Dangerous Goods, it may be offered as a fully regulated non-bulk package, limited quantity, or excepted quantity.
Fully Regulated
Choose the packing instruction from column I, and the maximum quantity limit from column J to ship by passenger or cargo aircraft. Or use columns K and L to ship by cargo aircraft only. Comply with applicable special provisions noted in column M. Mark and label the package according to IATA DGR Section 7.
Limited Quantity (LTD QTY)
Use columns G and H to ascertain the packing instructions and quantity limit per package, and follow any applicable special provisions noted in column M. Limited Quantities must be shipped in combination packages and cannot weigh more than 66 lbs. (30 kg). UN specification packaging is not required. However, the package must be marked and labelled as if it were a fully regulated package, with the addition of the limited quantity marking.
Excepted Packages
This is one of the most common ways shippers send small samples by air. Check column F for the excepted quantity (EQ) code. Follow the provisions at IATA DGR 2.6.
You will find:
1. quantity limits for the inner packagings as well the maximum net quantity per outer packaging;
2. packing requirements;
3. packaging test standards; and the
4. excepted quantity mark
A copy of the shipper’s declaration is not required.
What Can STARS Do For You?
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Our personalized solutions will minimize compliance risks and reduce your operating costs while simultaneously increasing your profits!
STARS offers personalized training classes on regulatory compliance and how to safely package, ship, store, and transport hazardous materials and dangerous goods.
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