New developments in the harmonization of international standards will change some of the shipping and label designations to which ag retailers have been accustomed. Dealers can expect to see changes beginning early next year, says Steve Hutton, compliance specialist at Dow AgroSciences and chairman of the Interregional Coordinating Council (IRCC) Transportation and Distribution Committee. This committee follows transportation issues and interacts with the U.S. Department of Transportation (DOT) on issues related to the transportation of crop protection products.

Revised sequence

HM-215I is the anticipated rule under which the latest changes to international regulations will be considered for incorporation within the U.S. Hazardous Materials Regulations (HMR), says Joe Delcambre, spokesperson for the U.S. DOT Pipeline and Hazardous Materials Safety Administration. Ag retailers are accustomed to seeing shipping papers starting with the proper shipping name, followed by hazard class, UN number and packing group. It is expected that, consistent with its mandate to conform to international regulations to the greatest extent practicable, the U.S. DOT may propose to adopt a revised sequence, placing the UN number first.

The revised sequence already has been adopted for incorporation within the International Maritime Dangerous Goods Code (IMDG Code) and the International Civil Aviation Organization’s Technical Instructions on the Safe Transport of Dangerous Goods by Air (ICAO TI). The revised IMDG Code and the ICAO TI will come into effect on January 1, 2007. However, the IMDG Code provides a one-year grace period, making the change mandatory January 1, 2008.

Under the current HMR, both sequences of information are authorized. Crop protection companies will be making the transition to the standard starting in 2007; in the interim, retailers can expect to see two sequences: proper shipping name followed by UN number, or UN number followed by proper shipping name, Hutton says.

Warning labels

Global harmonization will also come into play as it relates to warning labels. A new marking for substances hazardous to the aquatic environment (marine pollutants) has been adopted within the Globally Harmonized System or the Classification and Labeling of Chemicals and the UN Model Regulations on the Transport of Dangerous Goods. The DOT will likely consider adoption of this marking within the HMR once it is implemented within the ICAO TI and IMDG Code (expected in 2009), along with a transition period to allow its implementation without undue cost to industry.

Consistent with the elements of the Globally Harmonized System on the Classification and Labeling of Chemicals adopted within the UN Model Regulations on the Transport of Dangerous Goods, HM-215I also may propose to adopt revised criteria for the classification of toxic materials, which would appear in the IMDG Code and the ICAO TI on January 1, 2007.

In terms of oral toxicity, the DOT reports that solids LD50 of 200 to 300 mg/kg not currently subject to the Model Regulations would be regulated as 6.1 PG III. Liquids LD50 of 300 to 500 mg/kg currently subject to the regulations as 6.1 PG III would not be regulated. For more information on toxicity criteria (including dermal and inhalation toxicity), go to hazmat.dot.gov/regs/intl/GHS_Presentation.ppt#14.

Shipping paper retention

The IRCC Transportation and Distribution Committee chair also reminds ag retailers about the change in the shipping paper retention period. Shippers must now keep shipping papers for two years versus one year and 10 days. The regulation went into effect on January 9, 2006. Although a company undergoing an audit might not be penalized now for not having papers from two years back, it should have proper documentation in place by January 2007, Hutton says.

Ag retailers also should be alert to a change in the definition of a hazardous materials employee and employer. “Employer” is defined as a person who employs or uses at least one hazardous materials employee on a full-time, part-time or temporary basis. This could have ramifications for some dealers, Hutton says.

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