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Shipping Empty Calibration Gas Cylinders? YOU are legally liable!

Dangerous Goods.jpgTraditionally shipping dangerous goods has been managed by logistic experts who have the training and certification to transport dangerous goods by road, sea or air.

The regulations surrounding the shipping of dangerous goods will differ depending upon which goods they are, where you are shipping them, and the method of transport.

Dangerous goods are generally classified in the same way around the world, under UN regulations. They are grouped primarily into different “classes,” which represent similar types of goods (see our blog, “Key facts to know when shipping specialty and pure gases”).

Calibration gases used for gas detection applications generally fall under class 2, with three sub-divisions:

  • 2.1 Flammable gases
  • 2.2 Non-flammable, non-toxic gases
  • 2.3 Toxic gases

The majority of calibration gas mixtures used in gas detection applications are classified as UN 1956, 2.2 non-flammable / non-toxic gases.

It is important to understand that these classifications are for transportation of the goods and do not relate to occupational health standards or exposure standards.

Did you know that under the Australian Code for Transportation of Dangerous Goods regulations that a gas mixture of 2000 ppm chlorine is considered non-toxic and is classified as a UN 1956, Class 2.2 gas mixture.

All occupational health and safety professionals would know that concentrations of 2000ppm chlorine is very toxic (TWA: 1 ppm   STEL:0.5ppm )

So you must consider these issues when shipping and handling dangerous goods, even class 2.2 DG’s rated as non-flammable/non-toxic gases.

Toxicity in regards to the transportation of dangerous goods is not equivalent to occupational health and safety standards.

Recently companies are putting the responsibility of returning empty or near empty calibration gas cylinders on the end user to send cylinders back to the manufacturer via Australian post or other means.

Are these calibration gas cylinders considered dangerous goods?

Each different type of calibration gas is contained inside a cylinder at a high pressure. This pressure represents a potential danger, as well as the danger of the gases themselves. Once a cylinder is empty, or near to empty, it may no longer be classified as dangerous goods. The cut-off point is 200kpa (29psi or 2BAR).

Calibration gas cylinders (class 2.2) containing pressure of 2 bar or more are considered dangerous goods.

Calibration gas cylinders (class 2.1 or 2.3) are never exempt even when completely empty.  These mixtures are always considered DG.

Historically many calibration gas cylinders are received back to suppliers with gas still in them without proper DG paperwork. This should be a major concern for end users who are managing calibration gas at their facility.

Liability & Chain of Responsibility

When you consign dangerous goods, you are accepting responsibility for the products being correctly packed & declared. While there is liability in every step of the supply chain (e.g. consignee, driver, courier company, receiver, etc), ultimately the consignee is primarily responsible. Goods can only be handled correctly, if they are first correctly identified. If you do not take care to correctly consign DG’s, you can face serious penalties, including fines, & even time in prison. This is why it is very important that a consignee fully understands the applicable dangerous goods regulations, and their responsibilities.

This article is intended as an outline of information only, and should be followed with a proper dangerous goods certification course, if any reader plans to become a shipper of dangerous goods.


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