Single Packaging
ISTA Series 6: 6-FEDEX-A Testing vs. Standard UN Testing

When we think of UN Testing, several things may come to mind. We have the drop test which evaluates the package’s ability to handle collisions, the vibration test which simulates movements created by a motorized vehicle, the Cobb test which is designed to ensure the fiberboard will not disintegrate when exposed to water, and the stacking test which checks the integrity of the package by stacking various weights over the top of it. However, those that want to test their packages under the ISTA 6-FEDEX-A requirements for packages 150 lbs. or under are finding it to be difficult to get a passing grade.

What Are The Differences?

Under standard testing, each sample is dropped only one time at a specific height for a total of 5 drops total from 5 different samples.

Under the ISTA 6-FEDEX-A testing, 1 complete sample is dropped 10 times focusing on every corner and edge of the package. Any significant leaking on either of these tests would result in a failure, which makes the ISTA testing very difficult to pass because of the number of drops. In addition, flat and elongated packages must go through a bridge or concentrated impact test procedure. This procedure consists of dropping a wooden box measuring 12″ x 12″ x 12″ dense wooden box weighing 21 lbs. on the midpoint of the package.

Under standard testing, the stacking test is usually employed. This a 24-hour test in which the boxes must be subjected to the force applied to the top surface equivalent to the total weight of identical packages which might be stacked during transport. ISTA 6-FEDEX-A testing specifically requires the dynamic compression test. This consists of a computerized control system which exerts a specific amount of force upon the boxes to determine if any damage to the sidewalls occurs.

Although ISTA 6-FEDEX-A testing doesn’t require the Cobb moisture test, it does require a vibration test similar to standard testing. Both tests are completed by using a rotary vibration table designed to simulate the movements from motor vehicles. However, with ISTA 6-FEDEX-A testing, certain items require a vibration test from a Random Vibration Tester. This vibration testing reproduces 3 consecutive sequences at 15 minutes each of random vibration profiles which simulate air vibration as well as truck vibration.


If ISTA 6-FEDEX-A testing is in your future when shipping hazardous goods, you may find it challenging to find packaging that will pass the rigorous amount of drops and impact testing that are performed. Contact ICC Compliance Center for your custom packaging needs.

Safety Data Sheets (SDS)
Who is Authoring Your SDS? – Dare to Compare

Authoring safety data sheets (SDS) is a technical job and requires a thorough understanding of various regulations depending on the destination country. Companies may promote themselves as experts, but how can you be sure?

Some companies may contract SDS work out unbeknownst to you and act as the middle-person. This in turn can lead to delayed responses as they try to understand/interpret your questions and/or get in touch with the contractor.

An SDS is a valuable and critical component of your dangerous goods product and deserves as much attention as the finished product itself. When looking for an SDS authoring company ask them questions such as the following to be sure you are selecting the right one.

  1. How many SDS have they authored?
  2. Do they understand the rules/regulations if the authoring is done manually?
  3. Can they verify the accuracy of the data if using authoring software?
  4. How long have they been authoring SDSs?
  5. Is there a team of qualified peers to contact if necessary?
  6. What process/procedure is in place to guarantee non-disclosure and safeguard any confidential business information (i.e., formulations)?
  7. Are they using authoring software?
  8. Can the SDS be integrated into a user-friendly multi-location labeling system?
  9. What type of training do they have in place for SDS authors?
  10. How many ingredients are present in their library/database?
  11. What associations do they belong to and/or are active in?
  12. How many languages can they translate an SDS to?
  13. Where or how are they storing your SDS?
  14. Can you obtain access to the completed SDS 24/7 on a dedicated site?
  15. Can you search your SDS database by fields such as CAS number, product name, or part number?
  16. What industries have they written SDS for?
  17. Are you required to complete/provide minimum information prior to starting your SDS work?
  18. Do they ask for clarification of your SDS or supporting data to ensure all information needed for a compliant SDS is obtained?
  19. Can they answer your questions as to why products were classified a certain way?

If these questions cannot be answered with confidence – or worse yet the vendor tries to pass over these questions nonchalantly – then you should continue your search. Of course you may have additional questions after reading the list. But, the above questions should give you a good reference point when deciding who to choose as your vendor. Sadly if the price is too good to be true be wary about the old adage, “You get what you pay for.” This is not an area where your business can afford a mistake.


ICC Compliance Center has a team of full-time regulatory specialists who have years of experience and are certified/recognized in their field of expertise. Contact us about authoring, reformatting, updating, and translating your SDSs. Ask us your tough questions by calling 888.442.9628 (USA) or 888.977.4834 (Canada).

WHMIS 2015
WHMIS 2015 – The Great SDS “Headache” – Concentrations

New Concentrations and Concentration Ranges Rules

If you’ve begun switching your MSDSs to SDSs under the new WHMIS 2015 regulations, you likely know this headache all too well.

With the publication and implementation of the Hazardous Products Regulations (HPR or WHMIS 2015), Health Canada removed the old Controlled Products Regulations’ (CPR or WHMIS 1988) list of prescribed concentration ranges that could be used in MSDSs. These concentrations were in place, in part, to allow some Confidential Business Information (CBI) protection when concentrations varied in a product. WHMIS 2015 now requires disclosure of exact concentrations of ingredients, or the actual concentration range of the ingredient. Actual concentration ranges can only be used if the concentration varies in the product due to issues such as batch to batch variability. You cannot list a range if you have an exact concentration, and simply wanted to “protect your formula”.

Suppliers would be required to file a CBI claim under WHMIS 2015 requirements, if even just to protect the exact concentration of one ingredient on a SDS. A whole host of difficulties may face the supplier in obtaining information that would be needed to complete this type of CBI submission, such as obtaining exact concentration information from suppliers outside the country, where CBI or trade secret requirements are different from those in Canada. In the United States, for example, there is no federal requirement to submit any type of claim to protect an ingredient’s exact concentration on a SDS. The SDS simply has to state that the concentration is being withheld as a “trade secret.” You can imagine the reluctance of a US supplier in providing information that they consider to be a trade secret.

This new requirement to submit a CBI claim for exact concentrations can result in significant additional costs. Fees for an original claim begin at $1800 CAD per claim, with review fees every three years of $1440 CAD per claim. Sometimes the supplier can group several products into one claim; however, costs for submission could skyrocket depending on just how many products are being submitted. The non-profit trade association Responsible Distribution Canada (RDC) estimates that the impact of those submission fees to members of the Canadian Consumer Specialty Products Association (CCSPA) will be over $12 million.

Alternatives

There may be some light at the end of the tunnel, however. As a result of this substantial cost burden, the RDC, as an industry representative, has requested that Health Canada amend the HPR to include some kind of alternative to disclosing exact concentrations that avoids having to file a costly CBI claim. The RDC believes that the use of ranges does not diminish protection of workers, and that the new requirements in WHMIS 2015 creates disharmony rather than harmony between Canada and its major trading partners.

In the RDC Newsletter Volume 6 Issue 43, issued November 7, 2016, the RDC presented a proposal that would allow the use of the WHMIS 1988 prescribed ranges again, with the added ability to combine up to three of the low end ranges into a single range (e.g. 0.1 – 1%, 0.5 – 1.5% and 1 – 5%, into one range of 0.1 – 5%). The additional stipulation of allowing those combined low end ranges, would, the RDC believes, allow for better alignment with US requirements.

Open for Suggestions

In previous meetings with Health Canada, the RDC and other industry groups did not come to a resolution on this issue of concentration disclosure, but Health Canada is willing to listen to solutions to this issue such as the current RDC proposal. The RDC has requested help from interested parties on approaching Health Canada, and is asking that suggestions from interested parties be sent to Cathy Campbell at: ccampbell@rdcanada.ca. Please submit your suggestions prior to November 30, 2016.

If you would like to learn more about the RDC, please consult the following website: http://www.rdcanada.ca/. For further information on CBI exemptions and claims in Canada, please consult the following website: http://www.hc-sc.gc.ca/ewh-semt/occup-travail/whmis-simdut/hmira-lcrmd/index-eng.php.


As always, should you have any questions regarding SDSs, please contact ICC Compliance Center Inc at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).

winter-driving-1000x1000
Safe Winter Driving

As the weather gets colder and inevitable snow and ice arrive, it is time to think about winter driving, and the challenges it brings.

According to the Federal Highway Administration, more than 24% of accidents are cold-weather related.

AAA (http://exchange.aaa.com/safety/roadway-safety/winter-driving-tips/#.WDMTHrIrLRY) recommends the following for driving in snow:

  • Accelerate and decelerate slowly. Applying the gas slowly to accelerate is the best method for regaining traction and avoiding skids. Don’t try to get moving in a hurry. And take time to slow down for a stoplight. Remember: It takes longer to slow down on icy roads.
  • Drive slowly. Everything takes longer on snow-covered roads. Accelerating, stopping, turning – nothing happens as quickly as on dry pavement. Give yourself time to maneuver by driving slowly.
  • The normal dry pavement following distance of three to four seconds should be increased to eight to ten seconds. This increased margin of safety will provide the longer distance needed if you have to stop.
  • Know your brakes. If you have anti-lock brakes (ABS) and need to slow down quickly, press hard on the pedal-it’s normal for the pedal to vibrate a bit when the ABS is activated. In cars without ABS, use “threshold” breaking, keeping your heel on the floorboard and using the ball of your foot to apply firm, steady pressure on the brake pedal.
  • Don’t stop if you can avoid it. There’s a big difference in the amount of inertia it takes to start moving from a full stop versus how much it takes to get moving while still rolling. If you can slow down enough to keep rolling until a traffic light changes, do it.
  • Don’t power up hills. Applying extra gas on snow-covered roads just starts your wheels spinning. Try to get a little inertia going before you reach the hill and let that inertia carry you to the top. As you reach the crest of the hill, reduce your speed and proceed down hill as slowly as possible.
  • Don’t stop going up a hill. There’s nothing worse than trying to get moving up a hill on an icy road. Get some inertia going on a flat roadway before you take on the hill.
  • Stay home. If you really don’t have to go out, don’t. Even if you can drive well in the snow, not everyone else can. Don’t tempt fate: If you don’t have somewhere you have to be, watch the snow from indoors.

ICC Compliance Center cares about our employees and customers. Stay safe this winter season.

shipping-a-gift-1000x1000
Shipping a Gift? Ask Yourself, is it Dangerous Goods?

This weekend, my husband and I decided it was time to do some clean up and sell some things on e-Bay. We did the usual photo and description, and posted a few odd items. When we came to the last item, a PS3 controller, my husband stopped and said, “I am going to have to ship this as dangerous goods.”

It got me thinking, how many people would know that? I wonder how many lithium batteries are mailed or shipped by average people, never thinking that they are doing something wrong and potentially very dangerous. Even scarier, is the thought that my family could be on that same plane.

As the holiday season approaches, people everywhere will be sending gifts to loved ones around the world. What many people still do not realize, is that innocent gifts like game controllers, lap-top computers, cell phones, and tablets are dangerous goods.

The definition of “dangerous goods” varies slightly from regulation to regulation, but basics means  articles or materials capable of posing significant risk to people, health, property, or the environment  when transported. Examples include: perfumes, paints, aerosol cans, and anything with a lithium battery including power tools, computers, and cameras.

Dangerous goods need to be packaged and labeled in accordance with the regulations. You also need to be a trained person to ship them.

Before you wrap that gift, contact the post office or the shipping company and ask them if it is considered dangerous goods. If it is, the best solution might be to seek a local packaging and crating company to assist. ICC Compliance Center has a list of “Repackers” around the USA and Canada that can be found here: http://www.thecompliancecenter.com/partners/.

Since not everyone is privileged enough to be in the dangerous goods industry, as dangerous goods professionals, we need to do our part in to educate and protect others, so all families can have a safe holiday season. Help me educate others by sharing this on your social media pages.

Well cook delicious looking turkey
Gobble, Gobble, Gobble – Thanksgiving Day Fire Safety

Thanksgiving – that time of year when everyone prepares to burst their waistbands. It is a time for family and friends to get together and enjoy some wonderful food and fellowship. It is also the “leading day for home fires involving cooking equipment,” according to the National Fire Protection Association (NFPA). This day is followed by Christmas Day and Christmas Eve for number of fires in the home due to cooking. While I could find no statistics to show the number of injuries actually increase on this holiday, the fact is the day is full of instances where personal safety is at risk.

No one wants to take a trip to the emergency room over the holiday so make preparations now. Have a plan in mind to deal with everything that goes into the day.

To stay safe, the NFPA recommends the following safety tips:

  • Stay in the kitchen when you are cooking on the stovetop so you can keep an eye on the food.
  • Stay in the home when cooking your turkey and check on it frequently.
  • Keep children away from the stove. The stove will be hot and kids should stay 3 feet away.
  • Make sure kids stay away from hot food and liquids. The steam or splash from vegetables, gravy or coffee could cause serious burns.
  • Keep the floor clear so you don’t trip over kids, toys, pocketbooks or bags.
  • Keep knives out of the reach of children.
  • Be sure electric cords from an electric knife, coffee maker, plate warmer or mixer are not dangling off the counter within easy reach of a child.
  • Keep matches and utility lighters out of the reach of children — up high in a locked cabinet.
  • Never leave children alone in room with a lit candle.
  • Make sure your smoke alarms are working. Test them by pushing the test button.

NFPA Thanksgiving Fire Safety Tips

You can also download these tips from here »

The Red Cross also has a list of cooking safety tips. Many of them are listed above, but here are some additional ones.

Additional Safety Tips

  • Use a timer as a reminder that the stove or oven is on.
  • Keep anything that can catch fire – pot holders, oven mitts, wooden utensils, paper or plastic bags, food packaging, and towels or curtains – away from the stove, oven or any other appliance in the kitchen that generates heat.
  • Clean cooking surfaces on a regular basis to prevent grease buildup.
  • Always check the kitchen before going to bed or leaving the home to make sure all stoves, ovens, and small appliances are turned off.

Everyone deserves to be happy and safe over the holiday. Do your part to make that happen. From ICC Compliance Center’s family to yours, I wish you a “Happy Thanksgiving”.

Danger Placard
Does My Personal Vehicle Need Placards? – Answering Regulatory Helpline Questions

One of the great services offered by ICC Compliance Center to our customers is our Regulatory Helpline. Current customers can call in and have basic questions answered for free. Our Specialists are trained in all of the transport regulations for the US and Canada. We also answer questions surrounding HazCom2012 and WHMIS 2015. A great benefit of our service is getting the customer a “right” answer. Occasionally it may require some information gathering, but we still give you an answer. Being relatively new to our Helpline, I tend to take a bit longer to get an answer.

I mention this because of an interesting question that came in last week. A customer called and posed the following question:

If I want to move a container of oxygen in my personal vehicle, does [my vehicle] have to be placarded?

On the surface this seems easy enough to answer, but in reality that is not the case. As I discovered a good bit more information was needed to formulate a “right” answer.

Answer Step 1:

What is meant by “a container of oxygen”? This information is needed for several reasons. We have to determine if what the caller has is truly a hazardous material/dangerous good. For example, is it pure oxygen or is it a blend of oxygen and nitrogen similar to a SCUBA tank? One is much more dangerous in the event of a fire than the other. In this case, the container is of pure oxygen.

Answer Step 2:

What is the description of the container? The assumption is the container is a cylinder. If so, what size? There could be exemptions in place depending on how large or small the container is. The caller said it is a steel cylinder that weighs 15 kilograms and it has TC on the outside.

Answer Step 3:

Where is this person located? We need to have this information so that the proper regulations can be checked. If the caller was in the United States, but I used Canada’s transport regulation to answer that may not have worked. In this case the caller is from Canada. This is helpful because there was a mention of using a “personal vehicle”. In the U.S. this could have led to a discussion of Materials of Trade exemptions. Since Canada does not have that type of exemption it would make no sense to go over them with the caller.

Answer Step 4:

Now we almost have the whole picture. We have a steel cylinder full of pure oxygen that weighs 15 kilograms. It is being transported in a personal vehicle in Canada. With all of that information, the caller MAY meet the 150 kilogram Gross Mass Exemption in the Canadian Transportation of Dangerous Goods regulations per Section 1.15. This prompted one more question. Was this cylinder purchased by the caller at a location open to the general public? The answer was “yes.”

Final Answer:

The final answer is “no”, the caller is not required to placard his personal vehicle to transport a cylinder of oxygen. Per the 150 kilogram Gross Mass Exemption, he does not need a shipper’s declaration, training or … any sort of “dangerous goods safety marks”. This section also includes placards. He may voluntarily display it per Section 4.1.1 of the regulation but there are multiple provisions.

So while this looks like a complicated process, it is in fact not. As long as we have all of the information, answering your questions can be quite easy. Give us a call today to see just how easy it is – ICC Regulatory Helpline 855.734.5469. We are here to help. As always, ICC Compliance Center is here to help you with all of your regulatory needs.

hazmat-violations
Amazon: Hazmat Violations Lead to Hefty Fines

Pulled over by police officer

Violations & Fines

We have all had this experience: We are driving in our car on a long stretch of highway or a small suburban road and it happens.

We notice a flashing light in our rear view mirrors and we are pulled over by a friendly neighborhood member of law enforcement.

As you go into a brief moment of anger and confusion, you realize most likely this is going to result in a hit to your pocketbook. As the old saying goes, “You do the crime, you do the time.” In this case it is in the form of a check or money order. Following the regulations for the transportation of dangerous goods is certainly no exception. The world’s largest internet-based retailer is finding this out. Recently, Amazon has been hit with a $78,000 fine by the FAA for violating its Hazardous Materials Regulations.

When a package containing a highly flammable liquid began leaking en route to its destination, it was found to have no markings or labels and was also missing required paperwork. This incident is just one of numerous shipping violations Amazon has had within the last several years, totaling approximately $872,000 in fines.

UN Packaging New Labels

Penalties Have Become More Severe

Since the ValueJet Disaster in 1996, The FAA has taken a far more aggressive approach in the regulations of dangerous goods resulting in substantial fines for offenders. The FAA can impose up to $75,000 in civil penalties for each violation of hazardous-materials regulations and up to $175,000 for severe injury, illness, death or property damage. Clearly violations of hazardous material regulations can leave your company, whether it’s large or small, at a risk to substantial fines. The best way to reduce this risk is to get your company thoroughly trained in shipping hazardous materials by a reputable company.


For training and other information on how ICC can help you remain in compliance with dangerous goods regulations call us at 888.442.9628 (USA) or 888.977.4834 (Canada).

Single Packaging
Changes Notice: BX-100CA

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-100CA.

  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.

ICC Kits Effected:

  • PK-MTRC141
  • PK-MTRC151
  • PK-PCP4/PK-PCP8
  • PK-PCP1600/PK-PCP3200


Click here to view our packing instruction downloads »

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

Thank you,
Michael S. Zendano
Packaging Specialist

OSHA
New OSHA Concentration Range FAQ

Validation

Oprah Winfrey once said, “I’ve talked to nearly 30,000 people on this show, and all 30,000 had one thing in common. They all wanted validation.” Validation is receiving feedback from others that what you do and say matters. It is an acknowledgment of your actions, deeds and accomplishments. To be a healthy person we need to receive positive validation and be able to give it to ourselves. So is it possible for a company to receive validation? I believe so and here’s why.

In one of OSHA’s recent Frequently Asked Questions (FAQ’s) postings a question regarding the use of ranges on Safety Data Sheets was added. To see the full FAQ and the answer, please click here. The specific question asked is: When may chemical manufactures/importers use concentration ranges rather than an exact percentage composition in Section 3 of the SDS, and how does this apply to trade secrets? Let’s take a closer look at OSHA’s answer. There are several parts to it and each deserves some attention.

Part 1 – Exact Percentage versus Concentration Range Clarification

The answer starts by clarifying the language used in Appendix D under Section 3. In the actual Appendix it states, “The chemical name and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards” must be disclosed in Section 3. However, in the FAQ answer the statement reads as “the chemical name and concentration (exact percentage) of all ingredients present in a mixture which are classified as health hazards” must be disclosed. This new phrasing has no mention of concentration ranges. In fact the answer goes on to say that concentration ranges may be used for cases where trade secret claims are made, there is variability between batches of product, or there is a group of substantially similar mixtures with similar compositions. It is now clear that exact concentrations and/or percentages of ingredients causing health hazards must be in Section 3 of an SDS. It is only in certain circumstances that a range can be used.

Part 2 – Exceptions to Exact Concentrations

As listed above, there are only 3 instances where a concentration range may be used. The first is when trade secret claims are made. The FAQ answer provides more guidance on how to use those claims correctly. As we know, these claims can be used to protect the specific chemical identity and/or the exact percentage of an ingredient. If it is the percentage that is being protected, then a concentration range can be used. The next instance where a range can be used is if there is variability between batches. Again the answer provides better details for when and how this fits. Batch-to-batch variability comes from differences in concentrations of ingredients that occur during production. To appropriately use a range here, those slight variations in concentrations cannot have any impact on health hazards of the mixture. The last allowed use of ranges is a bit tougher. Again, the FAQ does a good job of further explaining the concept of similar mixtures with similar compositions. If a manufacturer/importer has a “line of products” that are very similar, but their compositions vary slightly, then a concentration range can be used. However, here again the differences must not change the overall hazards of the mixture. The answer goes on to say that the ranges used must be “sufficiently narrow” and provide an “accurate representation” of the concentrations.

Part 3 – Validation

ICC’s answer for ranges has been clear from the beginning and matches what is in this new FAQ. We follow what is in Appendix D of HazCom 2012 in regards to how Section 3 should be written. In all of our U.S. GHS webinars, Classification courses and Regulatory Helpline responses, we say “ranges are NOT allowed unless certain criteria are met.” We then take the time with the clients or customers to explain the specific criteria to see if they in fact qualify. If they do, we work with them to review their safety data sheets or author a new one for them.


So here it is. ICC Compliance Center, a company, has its validation. We are doing it right! OSHA’s answer in this FAQ matches our standard procedure for answering questions regarding the use of ranges on safety data sheets here in the US. We knew we were doing it the right way, but here is OSHA validating our process. As always, ICC Compliance Center is here for all of your hazard communication needs.