Lithium
Safety Tips for Items with Lithium-Ion Batteries

Lithium-Ion Batteries in Our Lives

If there is one thing most of us have in common, it is how often we come in contact with items that use lithium-ion batteries. Whether it’s a laptop computer, cellphone, camera, or even an electronic cigarette, we rely on lithium ion batteries for many different purposes. Unfortunately for some consumers, when lithium-ion batteries fail, they do in devastating fashion. When a lithium battery explodes, it can cause a fire that generates temperatures up to 1000° F and can cause severe 3rd degree burns as the video below demonstrates.

What can we do to prevent such a catastrophic event from occurring while we utilize these everyday items that use lithium-ion batteries? Below is a list of safety tips when using items with lithium-ion batteries.

Lithium Battery Safety Tips

  • Only use the charger that came with your device. If you need to buy a new one, make sure the replacement is recommended for the use of your device by the manufacturer. Just because a charger fits in your device doesn’t mean that it is safe to use.

 

  • Do not overcharge your device. It is recommended that once your device is fully charged that you should unplug it.
  • Keep your device out of extremely high or low temperature locations. Do not place the battery in direct sunshine, or store the battery inside cars in significant hot or cold weather.
  • Do not expose the battery to water or allow the battery to get wet.
  • Do not use your device if you notice any damage to the battery after dropping it. If you suspect damage to the battery, take your device to the service center for inspection.
  • Do not carry or store the batteries together with necklaces, hairpins, or other metal objects.
  • Do not disassemble or modify the battery in any way. Modifying your electronic significantly increases the risk of explosion
  • Only transport your items with lithium-ion batteries in a containers that are specially designed and follow D.O.T guidelines.

As always, should you have any questions regarding lithium-ion batteries, please contact ICC Compliance Center at 1.888.442.9628 (USA) or 1.888.977.4834 (Canada).


Sources
http://batteryuniversity.com/learn/archive/lithium_ion_safety_concerns

http://www.genuinecells.com/blogs/safety-precautions-for-the-lithium-ion-batteries/

Lithium
Another Lithium Battery Recall

New Recall of Laptop Computer Battery Packs

An expanded recall of laptop computer battery packs for Panasonic battery packs used in Toshiba laptop computers was made on Wednesday January 4th, 2017.

The lithium-ion battery packs can overheat and cause burns and fire hazards.

This expanded recall involves Panasonic lithium-ion battery packs installed in 41 models of Toshiba Satellite laptops, including the Satellite models affected by the March 2016 recall. Toshiba has expanded the number of battery packs to include those sold between June 2011 and November 2016. The battery packs also were sold separately and installed by Toshiba as part of a repair. Battery packs included in this recall have part numbers that begin with G71C (G71C*******). Part numbers are printed on the battery pack.

If your battery pack is part of the recall, power off the laptop, remove the battery and follow the instructions to obtain a free replacement battery pack. Until a replacement battery pack is received, you should use the laptop by plugging into AC power only. Battery packs previously identified as not affected by the March 30, 2016 recall are included in this expanded announcement.

To see if your device is eligible for exchange, go to http://go.toshiba.com/battery or call Toshiba America Information Systems toll-free at 866-224-1346 any day between 5 a.m. and 11 p.m. PT.

As always, ICC is here for all of your safety needs. Contact us today for our Lithium Battery Multi-Modal transport course, packaging and marks and labels needed.

Source: http://www.recallowl.com/Consumer+Recalls/Recreational+Products/Toshiba+Expands+Recall+of+Laptop+Computer+Battery+Packs+Due+to+Burn+and+Fire+Hazards

Services
Inspector Issue

Gaining Regulatory Knowledge

Many of us have heard the phrase, “a little knowledge is a dangerous thing” at some point in conversation with people. What’s interesting is the phrase was originally “A little learning is a dangerous thing“. It comes from Alexander Pope’s poem called “An Essay on Criticism“. This phase can be applicable when you work in an area with ever-changing regulations. The key is to get more knowledge.

A prime example can be found in a September 2016 newsletter from Responsible Distribution Canada (RDC). This group was formerly called the Canadian Association of Chemical Distributors. In Volume 6 Issue 37 is the headline “Issue being reported with some WHMIS 2015 Inspectors RE: MSDS vs SDS“. In the article, RDC was contacted by a paint manufacturer. The manufacturer indicated that a Health Canada inspector was on the job site causing problems. At issue is the following:

“The HC inspector apparently said the paint manufacturer’s MSDS sheet was not acceptable because a “Safety Data Sheet” should now be supplied instead of a “Material Safety Data Sheet”. The inspector added that this change became effective in 2015 and said that the word “Material” should not be mentioned on the technical sheets.”

According to the manufacturer they have yet to convert to WHMIS 2015. In this case it is the inspector in error and a classic case of a little knowledge being dangerous.

Why?

Let’s discuss why. Canada aligned the Workplace Hazardous Materials Information System (WHMIS) with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in February 2015. This is why it is called WHMIS 2015. A part of the new regulation is to move from using the term “material safety data sheets” to just “safety data sheets”. There is a multi-year transition plan or phase in period in place before the new regulation goes into full effect. Here is where the inspector gets in trouble. It is during Phase 1 of the phase in plan that the terminology shifts. The dates for Phase 1 are February 11, 2015 to May 31, 2017. Since the paint manufacturer has yet to convert to WHMIS 2015, they still have time as allowed under Phase 1. They are in the right.

The inspector is aware of the changes in WHMIS 2015 which is great but also qualifies as a “little bit of learning”. Where he is “dangerous” is the fact that he was not aware of the time periods involved with the phase in of the new regulations. He was trying to force a regulatory change that is not yet mandatory. Had the inspector been more familiar with the new regulations this issue would not have happened.

Another part of Pope’s poem is the phrase, “To err is human, to forgive divine“. While this is a lovely sentiment, in the world of business and compliance it just isn’t possible. For a link to the complete RDC newsletter, click here.

Don’t be a “danger” to your business. Get trained beyond “a little bit of learning”. ICC Compliance Center offers a full range of courses including WHMIS 2015. Call us today for compliance audits and the multiple courses and learning platforms we offer.

Oil drum spill
When Are You Required to Report a Hazardous Spill?

Reportable Quantities & Environmental Release

Unfortunately accidents seem to happen at the most inconvenient times. Whether you fall, crash, slip, or spill, it is often the aftermath that defines who we are. After all, there is no use crying over spilled milk. However if you spill hazardous goods, the aftermath can be a bit more complicated.

It is important when hazardous materials are spilled that it is addressed in a way that prevents any further damage to the environment or health of the community. But when is it necessary to report a hazardous spill to the proper authority? The Federal Government has established Reportable Quantities (RQ) for instances when hazardous substances are released in the environment. If a hazardous substances released in the environment in an amount that is equal or exceeds its RQ, it is required that it is reported to the federal authorities. A list of Reportable Quantities san be found in the latest 49 CFR.

Chemical Spill Guidelines

Specific guidelines are in place if hazardous materials are spilled during transportation. Whether you are loading, driving, unloading, or storing hazardous materials, you are required to adhere to the same guidelines. There are times when hazardous goods are transferred from one carrier to another. According to the D.O.T, whenever material is being transferred from one carrier to another, the upstream carrier remains responsible until the material is fully in the possession of the downstream carrier, no matter who is unloading the material.

Once the material has been delivered to the final intended consignee and the goods are no longer in transit, the final consignee becomes responsible for filing the report for spills that occur during the unloading process. If during the transportation of hazardous goods a spill takes place that meets or exceeds the reportable quantity (RQ), immediately contact the National Response Center (NRC).

You will need to provide the following information per the Environmental Protection Agency (EPA):

  • Your name, location, organization, and telephone number
  • Name and address of the party responsible for the incident; or name of the carrier or vessel, the railcar/truck number, or other identifying information
  • Date and time of the incident
  • Location of the incident
  • Source and cause of the release or spill
  • Types of material(s) released or spilled
  • Quantity of materials released or spilled
  • Medium (e.g. land, water) affected by release or spill
  • Danger or threat posed by the release or spill
  • Number and types of injuries or fatalities (if any)
  • Weather conditions at the incident location
  • Whether an evacuation has occurred
  • Other agencies notified or about to be notified
  • Any other information that may help emergency personnel respond to the incident

If you have questions about chemical spills or reportable quantities, contact us here at ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-44834 (Canada).

Environmental Update
Chemical Spill Cooperation

Atchison, Kansas Chemical Spill

A little less than a month ago a small town near Kansas City, Kansas got a nasty surprise. According to local news reports a chemical spill at MGP Ingredients in Atchison caused quite stir around 8:00 in the morning.

The Kansas City Star reported the spill resulted in a mixing of Sodium Hypochlorite and Sulfuric Acid. The reaction of the two chemicals created a thick fog that covered much of downtown and areas north and west of there. Several areas were told to evacuate while others were told to “shelter in place” with doors and windows shut. Click here to view a video taken by drone of the chemical plume. By 11:00 am officials reported the spill under control and people were allowed back into their homes and business. The Environmental Protection Agency (EPA) sent personnel to assist in the investigation.

Thanks to a good communication between MPG Ingredients, the City of Atchison and the local Fire/Emergency crews there were no serious injuries reported. Those caught in the fog, roughly 34 townspeople, had respiratory issues including coughing and difficulty breathing. At the time the article was written, there was no word on the number of affected MGP employees.

The key take away from this story is the communication element. It took less than 3 hours for this spill to be handled and for folks to be safely back at home, school or work. If MGP Ingredients had not reported the spill promptly, then the number of injuries would be higher. If local officials had not responded as quickly as they did by using the radio and social media, then the number of injuries would be much higher. If the local fire crew had not known what was needed to help the fog dissipate, then the number of injuries would be much higher.

There are always those that complain about updating hazard communication plans, workplace labels, safety data sheets, and evacuation plans. For those my response is simple. Here is the reason we do this. Here is why they are needed. Given the scope of the cloud and the area it covered, consider how many people were at risk. Had things been handled differently a much worse outcome is a definite.

As always, ICC Compliance Center is here to help you with all of your regulatory needs. For more information on our supplies and services visit our website: http://www.thecompliancecenter.com.

IMDG
Changes for IMDG Code 38th Edition

Next year signals the start of a new biennium for transportation of dangerous goods. Ocean shippers should take a look at what’s in store in the new International Maritime Dangerous Goods Code (IMDG) which has been updated to reflect the most recent revisions of the UN Recommendation for the Transport of Dangerous Goods.

Compared to other regulations, the IMDG Code has a rather complex method of implementing changes. The IMDG Code 38th Edition was published in November of this year, so it will be referred to as the 2016 edition. However, the changes will not go into effect for 2016. Instead, shippers and carriers may start to use the new edition as of January 1, 2017. But a transition period of one year is given, so the changes are not mandatory until January 1, 2018. A new edition of the Code will be published near the end of 2018, but there will be another transition period of a year during which the 38th edition can still be used.

IMDG Transition Timeline
IMDG Transition Timeline

Think of it this way – during odd-numbered years you can use the current edition of the code, or the previous one. During even-numbered years, you must use the latest code published.

So, what changes can we expect for ocean shipment? It turns out that this biennium will not be one of massive changes, but will reflect adjustments and tweaks, as well as the introduction of a few new shipping descriptions. Here’s a list of the most significant changes for the 38th Edition.

  1. The classification sections for gases, flammable liquids, toxic substances and corrosives will now include definitions of materials prohibited from transport. These will be materials that can polymerize or decompose violently under the normal conditions of ocean transport.
  2. A new section 2.0.0.2, addresses when the shipper believes a named substance has hazards beyond those assigned by the regulations.
  3. In section 2.3.2.2, an alternate measurement of viscosity (using kinematic viscosity) can now be used in adjusting the packing group of viscous flammable liquids.
  4. A new type of flammable solid, called polymerizing substance, has been added to the classification criteria for Division 4.1.
  5. New shipping names have been added to the Dangerous Goods List in Volume 2. These include names for the new polymerizable substances (UN3531 to UN3534); new names for engines of various types, which have been split from vehicles (UN3528 to UN3550); and a new entry for polyester resin kits which have a solid, rather than liquid, base (UN3527).
  6. The new entries on the Dangerous Goods List have required the creation of new packing instructions for them.
  7. For UN1950, AEROSOLS, there is a new packing instruction, LP200, which will allow spray cans to be shipped in “large packagings” (combination packagings exceeding 450 Litres capacity per outer packaging.)
  8. New ISO standards have been incorporated into the packaging instructions for Class 2 gases.
  9. The “OVERPACK” marking has now been assigned a minimum letter height of 12 mm.
  10. Lithium batteries have changed in several ways to reflect new UN standards. First, the Code has introduced the new lithium battery handling mark, and the new lithium battery class 9 label. Both of these have a transition period of two years, and become mandatory in 2019. These are addressed in the revised Special Provision SP188 and the new SP384.
  11. Lithium batteries that are prototypes or low production samples have a new packing instruction, P910.

While shippers of dangerous goods by ocean have slightly longer to adapt to the new regulations than do air shippers, it’s important to remember that ocean shipments are usually longer as well. Don’t get caught out when your shipment suddenly becomes non-compliant mid-ocean.


If you have questions about the coming requirements for shipping dangerous goods by ocean, contact us here at ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-44834 (Canada).

Frequently Asked Questions
FAQ – GHS Symbols on SDS in Canada and the United States

Frequently Asked SDS Symbols Questions

How many times have you thought you understood a requirement, only to second guess yourself about whether you got that right or not? It could be something relatively straight forward, or something a bit more complicated. Everyone has these moments occasionally, especially with the implementation of GHS around the world. At ICC, two of the questions that seem to pop up from time to time, revolve around symbols on SDSs.

Do GHS pictograms have to appear on an SDS?

The answer: No. The ‘pictogram,’ specifically, doesn’t have to appear. This answer, in part, boils down to terminology.

In both Canada, under WHMIS 2015 Hazardous Products Regulations (HPR) requirements, and in the United States, under Hazcom 2012 requirements, Section 2 of an SDS is required to list the label ‘information elements’ that are applicable to the product. Hazard ‘symbols’ being one of the required ‘information elements’.

In both the United States and in Canada, ‘pictogram’ is defined as a “symbolalong with other “elements, such as a border or background color”. So a complete GHS ‘pictogram’ is actually two part; a graphic symbol on the inside, and a frame surrounding it. Both countries include an allowance only to show a ‘symbol’ (ie. not a ‘pictogram’), or, just the name of the symbol, on the SDS [Hazcom 2012, Appendix D, Table D.1, Item 2(b); WHMIS 2015 Hazardous Products Regulations, Schedule 1, Item 2(b)].

So … no complete ‘pictogram’ is required on the SDS in the US or in Canada.

If I choose to show a complete ‘pictogram’, and not just the ‘name’ of the symbol on the SDS in Section 2, do I have to use a red frame?

The answer: No. the ‘pictogram’ would not have to show a red frame on the SDS.

As mentioned above, in both countries, what is required on the SDS is the ‘symbol’ and not the complete ‘pictogram’ [Hazcom 2012, Appendix D, Table D.1, Item 2(b); HPR, Schedule 1, Item 2(b)]. What that means, is that if you choose to include a complete ‘pictogram’ on your Hazcom 2012 or WHMIS 2015 SDS (ie. the ‘symbolplus the frame), you can include the frame in the color you prefer since the requirement on the SDS is for the ‘symbol’ only and not the ‘pictogram’. There is no specific requirement in Hazcom 2012 or the HPR to have a red framed pictogram on the SDS. The red frame requirement is only on the label (Hazcom 2012, Appendix C, Section C.2.3.1; HPR, Part 3, Section 3.1).

As an example, Section 2 of an SDS for a product classified as a Flammable Liquid – Category 3 and an Eye Irritant – Category 2A, may appear as any of the following 3 options:

Option 1 Option 2 Option 3
Label elements Label elements Label elements
Hazard pictogram(s) Hazard pictogram(s) Hazard pictogram(s)
Insert GHS Red flame & Exclamation Mark Insert GHS Black flame & Exclamation Mark Exclamation Mark

Don’t Forget

The above SDS information is applicable in Canada and the United States. Section 2 SDS requirements may vary, depending on what region of the world you are dealing with.

Should you have any questions regarding SDS’s, please contact ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).

Safe Holiday Decorating

Holiday Safety

December means festivity and cheer for many. Many offices, including ours, enjoy bringing the festivities to work by decorating our offices, cubicles, and other office areas.

Safety is always important, festive occasions included. Safety+Health suggest the following to help prevent injuries while celebrating on the job. (Safety+Health Magazine)

Safe decorating

  • Don’t stand on a chair to hang decorations. Use a stepladder, and make sure to read and follow the instructions and warnings on the label. And never hang decorations from fire sprinklers – they can prevent the sprinklers from operating properly. OSHA regulations state that stacked materials should never be closer than 18 inches below fire sprinklers.
  • Planning to string decorative lights or other electrical items in your workspace? The Electrical Safety Foundation International, a nonprofit organization, states that workers should:
    • Be sure that all electrical items are certified by a nationally recognized independent testing lab.
    • Inspect all lights, decoration and extension cords for damage before using.
    • Avoid overloading electrical outlets with too many decorations or electrical devices – they can overheat and cause a fire.
    • Never try to make a three-prong plug fit into a two-prong outlet.
    • Turn off all indoor and outdoor electrical decorations before leaving.

ICC Compliance Center offers a variety of safety courses to train employees on the hazards in the workplace. Visit our website and view our safety courses for more information

From our ICC family to yours, have a safe and happy holiday season.

TDG
HO! HO! HO! TDG Under the Tree – Proposed Harmonization

The November 26th Canada Gazette I provides an early “gift” to the regulated community which may help relieve boredom over the holiday season.

Harmonization Transportation Style

Although the DG world (unlike WHMIS/OSHA) has been fairly well harmonized under the UN Recommendations for some years now, there have been issues from time to time with; the editions standards referenced in the TDG regulations (TDGR); differences between DOT/TDG requirements for pressure receptacles; and confusion in the status of cross-border shipments when special permits (DOT) or equivalency certificates (TDG) are applied to consignments (for brevity, we’ll refer to these both under the generic term “permit for equivalent level of safety”- PELS).

Ambling Along

An example of the former is the Table of Safety Standards in TDGR 1.3. The recognized edition of the UN Recommendations is the 17th Ed. (2011)- despite the fact that we’re currently looking at the 19th Ed. (2015) and are on the verge of the 20th (2017). This can lead to confusion since the modal regulations are usually consistent with the current edition of UN Recommendations.

To help resolve this issue, and presumably to reduce the amount of catch-up amending necessary, Transport Canada proposes to expand the listing of “ambulatory references” – refer to the latest edition (i.e. “as amended from time to time” rather than a specific date)- for equivalency of other regulations and some selected technical standards.

Canada-US Regulatory Cooperation

Issues reviewed at the joint Canada-US Regulatory Cooperation Council are also appearing in this harmonization proposal.

The US DOT is following a parallel track, with proposed amendment HM-215N published in September, to include similar provisions in 49 CFR. (see Barbara’s Blog of Oct. 13, 2016)

U.S. Publishes Proposed Rule HM-215N on International Harmonization

Key aspects of this initiative include expanding the reciprocity provision to fill and use US DOT pressure receptacles in Canada rather than only accepting those which had been filled within the US. Requalification, repair, marking, etc. must be in accordance with the country where it’s done.

TDGR Parts 9 and 10 also would extend recognition of US PELS regardless of the existence of a Transport Canada-issued corresponding permit, reducing the need to apply for, or determine the existence of, a similar provision. The PELS number would have to appear on the shipping document. Application of the reciprocity would continue to be disallowed for things that are forbidden in TDGR or are not regulated under 49CFR. Each country’s regulations would still have to be reviewed regarding general special case/special provision exemptions.

Additionally, “one-time movement approvals” (OTMA) for moving damaged tank cars, for example, would be recognised in each country to facilitate dealing with situations where the car must be moved to safely empty and repair the means of containment.

Safety Marks, Labels, and Placards

Lithium Battery Mark, Label and Placard

The adoption of the “new” lithium battery mark will replace the provision for marking equivalent wording on packages subject to SP 34. This includes indicating the UN number of the contents instead of just the battery type by name. All SP34 packages will require the mark, but a notation on documentation will no longer apply.

The TDGR also will adopt the new lithium battery Class 9 label for packages requiring this hazard label. As with the other modal/US regulations/proposals, the mandatory use will have a 2-year transition period.

Placarding May not be Harmonized

The TDGR amendment as proposed will require the use of a placard corresponding to the lithium battery Class 9 label instead of a standard Class 9 placard when means of containment require placards.
This is at odds with the 49CFR HM-215N proposal to maintain the use of a “regular” Class 9 placard despite the new lithium battery Class 9 label (“…Class 9 placards, when used, must conform to the existing requirements in …172.560”).
Ditto final (i.e. adopted) IMDG Code Amendment 38-16 -see 5.3.1.1.2: “For dangerous goods of class 9 the placard shall correspond to the label model No. 9 as in 5.2.2.2.2; label model No. 9A shall not be used for placarding purposes.” – i.e. must use the standard Class 9, not the lithium version.

Updating to Current International Regulations

Other proposals will “catch up” the TDGR with many of the changes in the UN Recommendations regarding classifications and listings in TDGR Schedule 1 with applicable editing of special provisions (e.g. specific entries for the various types of combustion engines, solid/liquid polyester resin kits, etc.).

Overpack Marking Clarified

Included in 2 dozen or so “typographical corrections and minor miscellaneous changes” is the removal of the need to mark “Overpack” when the DG marks are visible; but when it is required it must be in minimum 12 mm high characters.

Other Safety Marks (in addition to lithium batteries discussed above)

The proposed amendment will adopt the international standard Class 9 convention of underlining the “9” on both labels and placards.
Also the new “fumigation” label is included in the Appendix to Part 4, presumably to catch up with the information included in the amendment in SOR/2014-159.

Missing from this proposal however, is the requirement for a 2 mm thickness for the inner border line on labels, as currently specified in the UN Recommendations, 49 CFR, IATA DGR and the IMDG Code.

The amendment will not, of course, be finalized until published in Gazette II, with a proposed 6 month general transition period (but until Dec.31, 2018 for the lithium battery mark and lithium battery Class 9 label). There is a 60 day comment period on the proposal and the detailed version may be consulted at:

http://www.gazette.gc.ca/rp-pr/p1/2016/2016-11-26/html/reg3-eng.php


If you have any questions about these changes and how they can affect your operations, please contact us here at ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).

Lithium
FedEx Grants Extension on Lithium Battery Mark for Air Transport

New Lithium Battery Marks

The 58th Edition of the IATA Dangerous Goods Regulations has introduced new package markings for air transport of lithium batteries. For fully-regulated (Section I) batteries the UN has introduced the dedicated lithium battery Class 9 label, showing a battery graphic in the lower half. For low-powered batteries that are exempted under Section II, IATA has introduced a new version of the Lithium Battery Handling label (the one marked “CAUTION”).

The new Lithium Battery Handling mark (no longer classified by IATA as a “label”) was designed to eliminate the text portion, making the mark no longer dependent on a specific language. Instead of using text to indicate type of battery, this mark will use the UN number, making it easy to identify the batteries no matter what language the handlers speak.

New Lithium Battery Mark and Pictogram

ICAO (International Civil Aviation Organization) and IATA (International Air Transport Association) intend this new handling mark and the new lithium battery Class 9 label to be phased in over the next two years, to become mandatory on January 1, 2019. This will allow people to use up old stocks, and train their staff to recognize the new symbols while still using the old ones.

FedEx Implementation

However, FedEx introduced a variation (FX-05 in the IATA DGR) that requires shippers to mark the UN number on Section II batteries as of January 1, 2017, two years before ICAO and IATA make it mandatory. This has caused concern among shippers who were not planning on changing to the text-free version so soon.

Therefore, FedEx has decided to extend the deadline for implementing the UN number requirement until July 1, 2017. At that point, the shipper must either change to the new handling mark, or start marking the UN number beside the old handling label (“CAUTION”). Of course, shippers have the option to comply immediately if they prefer.

FedEx notes that this would only be an issue for Section II batteries. Batteries shipped under section IB would require both the handling label (or mark), as well as the Class 9 label, shipping name and UN number as regular dangerous goods.


If you have questions about the coming requirements for shipping lithium batteries by air, contact us here at ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-44834 (Canada).