3D rendered IBC
New ASTM Standard for IBCs

Neatly stacked IBCs

ASTM IBC Standards

Recently I wrote a blog about our boxes meeting ASTM standards. For those that weren’t aware, I described ASTM International as an international standards organization that develops and publishes voluntary technical standards for a wide range of products including packaging. In addition to providing standards in the development of corrugated boxes, ASTM can provide guidance in testing hazardous materials packaging, specifically in this case hydrostatic testing of Intermediate Bulk Containers.

Hydrostatic Testing for IBCs is outlined in 49 CFR §178.803 and §178.814.

This states:

The hydrostatic pressure test must be conducted for the qualification of all metal, rigid plastic, and composite IBC design types intended to contain solids that are loaded or discharged under pressure or intended to contain liquids.

However, the current regulations have been described as “limited” on the specific details of how to perform the test. (See video below)

This guide provides the detail on how to conduct pressure testing on IBCs and will provide a more consistent process for container manufacturers, testing labs, and regulatory agencies. The new standard will thus help manufacturers pass performance tests and qualify their container designs to meet requirements of the U.S. Department of Transportation’s Title 49 Code of Federal Regulations as well as the United Nations recommendations on the transport of dangerous goods. The new standard will be published as ASTM D8134 and the scope is listed below:

Scope

Single Packaging
Change Notice: BX-23CA

Dear Valued Customer,

In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to BX-23CA (PK-MT121).

  1. The clear tape required for closure of this packaging has changed from 3M #305 48mm wide clear tape to 3M #375 48mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.

Click here to view our packing instructions and certificate downloads »

If you have any questions or concerns, please contact our customer relations center at 888-442-9628 in the USA, 888-977-4834 in Canada.

Thank you,
Michael S. Zendano
Packaging Specialist

ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 4

Variation packaging cushioning material, excepted quantity packaging, UN packaging testing, distributor deadlines for WHMIS 2015, Mexico GHS, and compatibility

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Variation Packaging (4GV) Cushioning Material

Q. Can I substitute a different cushioning material in a variation box?
A. In general: “No.” When a UN-standardized package is specified. The various regulations (49 CFR, IATA DGR, IMDG Code, and TDGR), or the standards referenced within them, restrict the user to assembling the package according to the manufacturer’s instructions. These instructions are based on the components used in the submitted test/design reports on which the approval is based. 49 CFR §178.601(g)(4)(iv) even goes to the point of specifically requiring the same type of cushioning as was used in the submission.

Excepted Quantity Packaging

Q. Is it always necessary for the shipper to have performance test results on packaging used to ship “excepted quantities”?
A. This depends on the mode or jurisdiction of transport. 49 CFR [§173.4a(f)], IATA DGR (§2.6.6) and IMDG Code (§3.5.3) all require that the shipper ensure that testing has been done and documented. This doesn’t need to be externally certified or approved. TDGR [§1.17.1(3)] does not require specific testing, only that packaging is “… designed, constructed, filled, Continue Reading…
Help Make the ERG Better

Emergency Response Guidebook

Calling All ERG Users

Many have heard the phrase, “Calling all cars” used in an emergency situation. The phrase references back to the old police radio days. It was used to call all patrol cars to help other officers. The phrase was the title for an old radio show back in the 1930’s, but also more recently as an episode of HBO’s “The Sopranos”.

How is that phrase being used here? The Pipeline and Hazardous Materials Safety Administration (PHMSA) has put out the call for input on ways to improve the Emergency Response Guidebook, or ERG. The new version is due for publication in 2020. To see the full notice go to https://www.gpo.gov/fdsys/pkg/FR-2018-05-23/pdf/2018-11055.pdf

What is the ERG?

It is a booklet that provides technical information and advice for those responding to emergencies involving hazardous materials as defined in 49 CFR. It is used mainly by emergency personnel such as police, fire-fighters, paramedics or other emergency responders. First issued in 1973, PHMSA’s goal is for all emergency response folks to have immediate access to it. As time has progressed there is a free online version and a downloadable app. Other countries may also have their own versions of the ERG. It is updated every 4 years.

It is broken down by the following color-coded sections:

  • White pages – At the start of the booklet, gives the instructions for how to use it and Continue Reading…
DOT 49 CFR USA
No Placards, No CDL Endorsement – USA Only

Truck Driving on highway at sunset

Hazmat Certification Under Placarding Exemption

The US DOT recently issued a “Letter of Interpretation” (LoI) regarding the lack of a need for a driver to have a hazmat (hazardous materials) endorsement on the CDL (Commercial Driver’s License) when transporting Class 9 hazmat within the US, despite the presence of Class 9 placards.

Changing Modes without Removing Placards

This situation is likely to occur when foreign shipments arrive which did not have the equivalent to the US 49 CFR §172.504(f)(9) conditional exception for Class 9 placarding, and are to be transported to their US destination.

An example would be if a Class 9 consignment arrives by vessel, which has placarding in conformance with the IMDG Code, and is picked up for road transport without removing the placards.

Even if the placards are not removed, there is not a requirement for the hazmat-endorsed CDL (equivalent to a TDG training certificate- for readers North of the 49th, metonymically speaking).

Note that, despite the exception for an actual Class 9 placard, §172.504(f)(9) does require bulk packages to be marked with at least the UN number.

Key to the Endorsement Exemption

49 CFR §383.93(b)(4) invokes the need for a hazmat CDL when the definition of hazmat in 383.5 is met. For substances defined as hazardous in 49 U.S. Code §5103(a) and (other than infectious substances/ biotoxins in 42 CFR §73) requiring placards, the CDL endorsement is required.

Thus, for most Continue Reading…

Prop 65
California Proposition 65 Warnings – After August 30, 2018

California horizon

California Proposition 65 Update

By now, you may or may not have heard the Prop 65 regulation in California was ‘recently’ updated. Wait, what? Prop 65 was updated? Yes … Yes it was. In August of 2016, the California ‘Office of Administrative Law adopted amendments to Article 6, for Clear and Reasonable Warnings, in the California Code of Regulations’.

The goals of the amendments were to make the necessary warnings stand out more, to give the public more information on what chemicals they are actually being exposed to, to update information to be more in-line with current technology, and to update responsibilities for companies. The changes will be fully in force at the end of this summer, August 30, 2018.

What do the new warnings look like?

The new warning requirements not only require companies to list at least one specifically listed chemical by name, but they also introduce a pictogram component to warnings. A bright yellow exclamation mark triangle.

As an example, a previous liquid chemical product perhaps was sold in a 5 gallon (18.9 Liter) container. The container was big enough to have a fairly large sized label on it, and the product was known to contain Toluene, Naphthalene and Benzene.

Those three chemicals are listed on California’s Prop 65 list as known to cause developmental harm, male reproductive harm, and/or cancer.

Prior to the 2016 amendments, the statement you would Continue Reading…

Lithium
How to Ship Damaged or Defective Lithium Batteries

Swollen lithium polymer batteries. Dangerous and harmful electronic waste

Regular Damaged or Defective or Dangerous Damaged or Defective?

There is a fair amount of interest in the topic of preparing Damaged or Defective (DoD) lithium batteries for transport and how to make a determination of the degree of hazard they present.

The current (20th) 2017 Edition of the Recommendations on the Transport of Dangerous Goods (UN Model) Regulations have addressed the former (packaging for transport) aspect, but the documents currently posted have not yet established firm protocols for the latter.

The situations involving recalls of defective, unsafe batteries and incidents during transportation has sustained the efforts to find better ways of dealing with them. The topic has been under discussion at the United Nations Sub-Committee of Experts on the Transportation of Dangerous Goods (TDG) in most sessions over the last several years.

For this discussion we’ll refer to cells/batteries that do not meet the UN Manual of Test criteria due to damage or defect, without specific safety hazards, as “regular” DoD; and those that “are liable to disassemble rapidly, react dangerously, produce a flame or a dangerous evolution of heat, or produce a dangerous emission of toxic, corrosive or flammable gases or vapours” as “dangerous” DoD.

This distinction is proposed for clarification in the next version (21st Edition) of the UN Model. See, for example, working document ST/SG/AC.10C.3/2018/51:
http://www.unece.org/fileadmin/DAM/trans/doc/2018/dgac10c3/ST-SG-AC.10-C.3-2018-51e.pdf

Batteries or Reactive Substances?

As a technicality, we should pause to consider the basic Continue Reading…

June is National Safety Month
NSC National Safety Week 2018
No 1 Gets Hurt Campaign

If you have followed my blogs for any length of time you know both my husband and myself are in the safety field. Several of our friends are as well. Inevitably when we are together the talk will come back to work. Of particular interest are the safety issues we notice on a daily basis. It could be people not wearing the appropriate PPE or standing on a stool to reach something in a cabinet. We then get into some of the unsafe things we see outside of work. This includes drivers on cell phones. By the end of the conversation, we are simply bewildered at how unaware people are about safety.

Take heart though, there is a month dedicated to the safety cause. June is National Safety Month. This year’s theme is “No 1 Gets Hurt”.

The National Safety Council (NSC) has outlined topics for each week of the month to be used at work and home. They even provide free downloadable resources in English and Spanish for each topic upon signup. I encourage you to do so as the resources are great. The link to the NSC site can be found here. Right in the middle of the page is a link for you to get your own materials. All you have to do is register. Let’s take a look at each Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: May 21

Limited quantities, manufacture expiry dates, regulated or not regulated, and reclassifying flammables to combustibles.

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Limited Quantity Limits (TDG)

Q. Customer called and asked if he can ship a box with 16 liters of UN1219 in inner containers as a limited quantity through ground in Canada.
A. The max according to the TDG is 1 L for limited quantity, so they can’t ship limited quantity.

Manufacture Expiry Dates

Q. Can you tell me if both the manufacturer and expiration dates are required to be on each label? Or if we have the option of just stating the manufacture date and verbiage that states the product is good for two years after the manufacture date? Also, would you happen to know which regulatory agency monitors these types of things?
A. The expiration date or manufactured date are not requirements of a GHS label. OSHA and The Globally Harmonized System of Classification and Labelling of Chemicals considers this supplementary Information, which is permissible as long as it doesn’t contradict any other information on the label, but they are not required components of the label.

Combustible materials (49 CFR)

Q. We have some drums of a material classified as NA1993 Combustible Liquid and only ever Continue Reading…

2018 Safe + Sound Week
2018 OSHA Safe + Sound Week

2018 Safe + Sound Week

OSHA Safe + Sound Week Set for August 2018

Back in the 14th century, sailing ships were a primary means of trading goods. To protect goods on these vessels they were insured against loss or damage. The best news for the insurance companies was to receive word that the ship had returned “safe and sound”. The word “safe” was an indication of all crew members were accounted for without injury. The word “sound” told the company the ship had not suffered any serious damage. Since then we continue to use the phrase in our daily life.

The week of August 13-19 has been designated as Nationwide Safe + Sound Week for 2018. The week is presented by the Occupational Safety and Health Administration (OSHA), National Safety Council, American Industrial Hygiene Association (AIHA), and the National Institute for Occupational Safety and Health (NIOSH) just to name a few. The goal is to “raise awareness and understanding of the value of safety and health programs“. All business and companies are encouraged to participate because “safe workplaces are sound business“.

The Core Elements of Safe + Sound Week

The focus of the week is on three core elements. It covers management leadership, worker participation and find and fix hazards.

  • Management leadership is a demonstrated commitment at the highest levels of an organization to safety and health. It means that business owners, executives, managers, and supervisors make safety Continue Reading…