Hello everyone and welcome back! In my last blog, we made it clear who needs to be trained by using the definitions available to us in the Canadian TDG Regulations. Now, let’s try to properly interpret what TDG requires as training. It should be noted that the primary purpose of TDG regulations is the safety of dangerous goods in transport and to achieve an acceptable level of safety, it is, of course, essential that the persons managing dangerous goods in transport have adequate competency. To do this, in Part 6 of the TDG, the Regulations clearly state that any person who handles, offers for transport, or transports dangerous goods must have appropriate training and hold a training certificate. To fully understand what constitutes appropriate training, we must refer to article 6.2 and this article states that a person must have a solid knowledge of all the listed topics as well as the dangerous goods that he is called to handle, transport or offer for transport.
Let’s try to understand these topics that are specified and for each of the points, I will name who is responsible under the TDG.
Classification from Part 2 of the TDG. What does classification mean? This consists of defining whether your product meets the characteristics of a dangerous good included in one or more of the 9 hazard classes. Person responsible for this Continue Reading…
Here is one more blog in support of knowing it is autumn even though the weather may not feel like it. The Office of Environmental Health and Hazard Assessment (OEHHA) in California just published a revised list. If you aren’t familiar with the OEHHA, you likely do know about California’s Proposition 65 list. As per usual, the list has changed a few times over the course of the year.
To refresh your memory, the Safe Drinking Water and Toxic Enforcement Act of 1986 is the official name for California’s Proposition 65. The list has to be revised and republished at least once per year. California’s Office of Environmental Health Hazard Assessment (OEHHA) is the agency responsible for the implementation. Chemicals are added or removed from the list when some other “authoritative body” makes a determination regarding a substances ability to cause cancer, birth defects, or other reproductive harm.
Shown below are all of the new substances that were added and or removed by month. They are listed by name, type of toxicity, and Chemical Abstracts Service Registry Number (CAS). Now would be a good time to see not only if you are up to date on the new required “warnings” but if any of your products or substances were added to the new list.
Proposition 65 – Additions and Deletions
Bevacizumab for female developmental effect with CAS 216974-75-3
If you were planning on watching your favorite movie or a TV show on your Macbook Pro on your next flight well instead you may need to take a book.
Following Apple’s recall in June 2019 for certain 15-inch Macbook Pro laptops sold between September 2015 to February 2017, the US Federal Aviation Administration (FAA) has announced that effectively immediately these laptops are prohibited on all US commercial fights. This isn’t a new regulation but rather a reminder of already existing regulations which bans recalled lithium batteries and lithium battery powered devices for air carriers. These Macbook pros contain lithium batteries which may overheat and pose a fire safety risk. This restriction applies to both carry-on and checked in luggage.
Ensure you check your Macbook Pro model to confirm you are not in the recall group.
In June of this year, I was invited to participate in the Commercial Vehicle Safety and Enforcement (CVSE) Inspectors Commercial Vehicle Safety Alliance (CVSA) Challenge in Surrey, BC, Canada as a judge. I know it doesn’t sound fun but honestly, it was awesome.
The challenge was over a 3-day period and the competitors were seven (7) very qualified CVSE inspectors from all over BC to test their skills and knowledge. The winner from this competition would go on to compete in the North American Inspectors Championship (NAIC) in Pittsburgh, PA, USA. The NAIC includes the best of the best inspectors from Canada, the United States and Mexico competing for the title of Grand Champion. This is some serious stuff and of course, comes with bragging rights!
For the provincial competition, the competitors first have to write a series of qualifying exams, which advances them to the provincial competition. This year’s competition consisted of driver interview, dangerous goods cargo tank inspection, coach bus inspection, and dangerous goods packaging inspection.
I came in as a judge for the dangerous goods inspections. We provided some of the dangerous goods packaging with “compliance issues”. That was fun for me. I got to make dangerous goods stuff incorrect on purpose for once.
A few incompliance issues that I added:
put primary and subsidiary hazard labels on opposite sides of the package,
Anyone that has taken a training class with me discovers my secret love of superheroes. There is just something about them that makes life fun. They show up in all sorts of places during training. From signatures on shipping documents to addresses on packages, it is just a little something to make training a little less boring. I bring this up because the National Fire Protection Association (NFPA) has designated the week of October 6th-12th as Fire Prevention Week. This year’s theme is – Not every hero wears a cape. Plan and Practice Your Escape.
According to the NFPA website, some home fires can limit a family to only one or two minutes of time to get out and reach safety. Let that sink in for just a little bit. Two minutes is not a lot of time to make life saving decisions. This is why the goal of this year’s week is to have people make their own home escape plans AND to practice them.
Since Canada first created regulations on the transportation of dangerous goods, those who “handle, offer for transport or transport” dangerous goods must be adequately trained. The question, of course, is what does “adequately” mean? Section 6.2 of the Transportation of Dangerous Goods Regulations (TDGR) says that it means “the person has a sound knowledge of all the topics … that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport,” but that still doesn’t clarify how the employer should verify that the knowledge is “sound.” Now Transport Canada, in consultation with the Canadian General Standards Board (CGSB), has attempted to answer that question.
The proposed standard would establish two levels of training. First, a “general awareness” segment, that should be approximately 2 hours long, which would cover the basics of how the TDGR works. Then, when employees are familiar with those concepts, they would receive “job specific” training, which would specifically address the job functions they do in that organization.
The Labor Day Holiday generally symbolizes the end of summer for many people. For many businesses it is the end of their fiscal year. For parents in many areas it means back to school. For the Pipeline and Hazardous Materials Safety Administration (PHMSA) it means releasing notices of proposed rulemakings. We also have OSHA publishing their Top Ten Violations. Finally, it is time for IATA to publish the list of significant changes for their upcoming edition.
Keep in mind, these changes are in the 61st edition of the IATA. It goes into force January 1, 2020. The other thing to remember is these are just a list of “significant” changes. Some of the changes always seem a bit cryptic to me. Plus, I’m one of those folks that takes the old one and compares it to the new one to better understand exactly how it changed. Guess it comes from being a visual learner.
If you should want to read the list of changes, it can be found here. A brief overview of some of the changes are shown below for quick reference. There is a little something for everyone in the industry. As you read through, there are some times where I added some information to supplement the change as it is stated on the publication.
Brief Summary of Some Proposed Changes by Section:
Another Friday the 13th is upon us. This is the third time we will look at a few superstitions to see if there is any benefit to us in regards to safety. Keep in mind I am using superstition in a broad sense. For this blog, a superstition is any idea or belief that may not be entirely rational or scientific but is still used today.
Superstition #1: Holding Your Breath While Passing a Cemetery
Death is always an odd subject that triggers varied reactions in people. For many it is a sad time due to the loss of a loved one or friend. A wake and funeral are held to honor their passing. For others it is a chance to celebrate someone’s life, like the Second Line Parades in New Orleans. For this particular superstition, you are supposed to hold your breath to prevent recently passed or evil spirits from possessing you to live life again.
From a transport point of view, this probably isn’t too great of an idea and should never be done. In fact, there are several published articles in medical journals stating the negative effects of holding your breath for too long. Some of the negative impacts are issues with blood sugar, coordination and even neurological damage. Imagine a truck driver holding his breath as he passes a cemetery, especially a large one that Continue Reading…
In the vast world called the dangerous goods community, it can sometimes feel like we are specks in the universe, simply just faces in the crowd. The regulations exist, and we follow them. However in certain cases like in the latest NPRM, we do have a voice. What is a NPRM you may ask? It stands for a notice of proposed rulemaking, which derives directly from requests from within the dangerous goods regulatory community to address a variety of provisions within the regulations. That’s right, we can make a difference! The purpose of this is to help clarify, improve, and provide relief from the various regulatory requirements when shipping dangerous goods. As a result of the requests, PHMSA addressed a wide variety of provisions including those addressing packaging, hazardous communication, and incorporation by reference documents. Some of the proposed amendments include revising the basis weight tolerance provided in § 178.521 from ±5% to ±10% from the nominal basis weight reported in the initial design qualification test report for paper shipping sacks, incorporating by reference updated versions of multiple Compressed Gas Association (CGA) publications, and removing the words “manufactured before September 1, 1995” from § 180.417(a) (3) to allow for an alternative report for cargo tanks manufactured after September 1, 1985.
Per PHMSA, these revisions proposed therein are intended to reduce regulatory burdens while maintaining, or enhancing, the existing level of safety. In this NPRM, Continue Reading…
Health Canada recently issued a series of 6 new or updated guidance documents to assist stakeholders in maintaining compliance with various aspects of the Hazardous Products Act/Regulation (“WHMIS 2015”) and assist importers/exporters in comparing the Canadian requirements to those of the US 29CFR OSHA (“HCS 2012”). These documents are reviewed briefly below with the link to the Health Canada site where the full document is available.
a) Joint HC & OSHA Guidance
This 15-page document compares key features between WHMIS 2015 and HCS 2012 from the perspective of jurisdiction and responsibilities. A summary table is included that highlights the areas of: authority (Federal v. Provincial/Territorial or State); and responsibilities (Supplier v. Employer v. Worker) in each country.
The document was published July 31, 2019 and is available in PDF/HTML at:
Following the April 2018 amendment to re-introduce use of concentration ranges for confidentiality purposes, this 20-page document has been issued to provide guidance on how to apply the HPR s. 4.4 and 4.5. This document replaces the information in the Dec. 2016 Technical Guidance document. A table in the document provides a comparison of this aspect between WHMIS 1988, WHMIS 2015 (pre-April 2018 amendment), WHMIS 2015 as amended in 2018 and the US HCS 2012.
The document was published August 2, 2019 and is available in PDF/HTML at: