IMDG
Ship by Ocean? Update the IMDG to Latest Corrigendum

Updating the International Maritime Dangerous Goods Code (IMDG Code) may be one of the worst jobs in the dangerous goods industry. At least, if their pattern of corrigenda (lists of corrections after the initial printing) is any indication. One or two of these are to be expected during the lifespan of an edition, as typos and mistakes are noted by users and require correcting.

Why is this a common situation? Well, more than most dangerous goods regulations, the International Maritime Organization (IMO) writes the IMDG Code in a style that depends heavily on cross-referencing. This can be frustrating for someone trying to figure out how to prepare a specific shipment. For example, in Chapter 3.4, “Dangerous goods packed in limited quantities,” the Code starts off by saying that limited quantities are exempted from all requirements not in section 3.4 – except for a list of over two dozen cross-references. Each one of these must then be read through to see how they’d apply to your limited quantity shipment. This usually leads to much jaw-clenching and a desire to fling the Code against the nearest wall.

Other problems can arise from trivial mistakes or typos when transcribing from the UN Recommendations for the Transport of Dangerous Goods or other documents. Simply mistaking the word “and” for “or” in a list of requirements can completely change the intent. Not to mention the multitude of Continue Reading…

Airplane Icon
Shipping by Air? Don’t Overlook the Latest IATA Addendum

As we start our new year, one of our resolutions should be to make sure our dangerous goods shipments get where they’re going. Which means, of course, that we need to update to the 2020 edition of the Dangerous Goods Regulations (DGR) from the International Air Transport Association (IATA). But don’t rely on that completely, because as always, there will be a few corrections and additions that IATA needed to make after the book has gone to print.

In December, IATA published an addendum to the DGR which is available as a free download. These will take effect as of January 1, 2020, so they’re in effect now. The majority of the corrections and additions have to do with State and Operator variations (country variations and airline policies that apply in addition to the DGR), although some affect more general areas. To find the addendum, go to the bottom of their webpage at https://www.iata.org/en/publications/dgr/#tab-2, from where you can download the file as a .pdf in various languages.

First, let’s look at some of the significant changes that are not specific to countries or airlines.

  • In section 2.3.2.3, on shipping wheelchairs and mobility aids with spillable batteries, paragraph (c)(2) includes a corrected cross-reference.
  • A significant change has been made to several packing instructions for Class 3 liquids when shipped Cargo aircraft only. In the original versions of Packing Instructions 360 to Continue Reading…
Airplane Icon
2020 Vision or Still Blurry for Lithium Battery Shippers?

The title says it all, can you see clearly when you ship lithium batteries, or are the waters still a little murky? If it is the former rather than the latter for you, that may change as Amazon has announced new global FBA requirements for all lithium batteries and products which contain lithium batteries. A Lithium Battery Test Summary will now need to be uploaded to Amazon, starting this past 1st of January 2020. This new rule will affect those who sell a variety of products, from watches to smartphones to toys. This type of change is not only exclusive to Amazon, as IATA and IMDG Code will now also be enforcing a new regulation that requires the test summary for the lithium battery/cells to be made available throughout the entire distribution network. 

What is the Test?

Lithium cells and batteries that are manufactured after June 30, 2003, and equipment powered by those cells and batteries have to be tested in accordance with the UN Manual of Test and Criteria Part III, Section 38.3. If the testing passes, the test facility provides a summary certificate to the manufacturer that confirms that the cells or batteries meet an international standard and can be shipped around the world in accordance with the appropriate regulations. The test standard includes eight tests total: Altitude Simulation; Thermal Test; Vibration; Shock; External Short Circuit; Continue Reading…

Complacency of Own Safety During Air Travel

As a former member of the Canadian Armed forces, I have always tried my best to keep keenly aware of any possible hazards/dangers that could affect me, my family, or others. I have never been one to stand by idly and say nothing or do nothing. I have noticed a trend developing lately in air travelers where it seems the majority are seemly unaware or oblivious of safety regulations and the reasons why some rules even exist.

I remember as a teenager embarking on my first flight in the mid-1980s being very attentive to all demonstrations; looking at every exit; observing every rule. It was easily noted that every traveler was watching the hand gestures of the flight attendant, knowing where our life jackets were, and again knowing the location of the nearest exit. But, as air travel safety has improved it seems complacency has increased. I have noticed hardly anyone listens to the flight safety briefing anymore as they are more preoccupied with taking their shoes off and looking at their phones.

Here are a couple of rules that exist and why:

NO lithium batteries in checked baggage
It is imperative to not check any lithium batteries in your luggage. If a lithium battery in your electronic device fails, thermal runaway occurs. The heat at which it will burn will melt aluminum which is what aircrafts are made of. Continue Reading…

ICC’s 2020 Regulatory Resolutions

Here it is – January 2020.  The time when all holiday decorations are put away and people make resolutions for the coming year.  Things we would like to change about ourselves, our workplace or our home.  We’ve all heard them.  I’m going to work out more.  There will be more family time.  We will eat healthier.  I’ll be kinder to my co-workers.  That one is mine in case you were wondering. 

Now at this point you are asking how does resolution making have anything to do with transportation of dangerous goods?  Well, I asked our Regulatory Team what their “regulatory resolutions” would be.  In other words, if they had the power, what changes or resolutions would they make to a regulation.  Oddly enough, with their responses, not a single regulation escaped a “resolution”!  Some of the items listed below were mentioned on more than one person’s list.

49 CFR:

  • Resolve to get rid of the combustible liquids.No one else in the world regulates these.
  • All lithium batteries should be transported as fully regulated with UN Specification Packaging and paperwork.No more exceptions. 
  • Resolve to adjust the packaging recertification requirements.Align them more with Canada’s.  As long as the components and specifications do not change there should be no need to re-test UN packaging every 2 years.  49 CFR should allow packaging manufacturer’s to simply send in an application for certification every 5 Continue Reading…
There’s a Handbook for That!!

Did you ever say to yourself; I wish there was a handbook for that? Handbooks are designed to provide a convenient reference or instruction about a particular subject. Handbooks come in many forms which can make life easier for employees, students, and new vehicle owners. But in some cases, handbooks provide guidance to more serious subjects other than just learning how to set the channel lineup on your car stereo for example. With that being said, if your business generates hazardous waste, I have the perfect handbook for you that has been prepared by the U.S. Environmental Protection Agency (EPA). It was designed to help small-business owners and operators understand how best to comply with federal hazardous waste management regulations.

What is it? 

This handbook provides a general overview of the federal hazardous waste management regulations and will give you a basic understanding of your responsibilities when generating and managing hazardous waste for small businesses. On a side-note, this handbook should not be used as a substitute for the actual requirements, but it does provide an outline and can act as a guide to assist you in understanding the regulations. The setup of the handbook is relatively easy to follow, as words or phrases that appear in bold red text throughout the guide are defined in an “Abbreviations and Definitions” section located on the last page. In addition, Continue Reading…

OSHA HazCom 2012
HazCom2012 Revision is Coming

It just doesn’t seem possible that the new OSHA standard, known as HazCom2012, has been in full swing for over 4 years now.  Of course, the time taken to get everything in place regarding it is still fresh in many people’s memories. I can still remember choosing to work on Memorial Day weekend to help some customers meet the June 1, 2015 deadline.  Just as a reminder, that transition was to Revision 3 of the Globally Harmonized System of Classification and Labeling of Chemicals (UNSCEGHS) or Purple Book and the direct section of the Code of Federal Regulations (CFR) that was updated is Title 29 1910.1200.  Given that the UN just released Revision 8, the US is a bit behind some other parts of the world.

Don’t worry though, OSHA is already in the process of preparing another update to the standard.  However, this will take time given the process involved with updating the CFR.  The process was supposed to start in the Fall of 2014 with a Notice of Proposed Rulemaking (NPRM) for an update to Revision 7 of the Purple Book.  That didn’t happen and the date moved to Spring of 2018.  Again, the process stalled.  OSHA is now looking to publish the NPRM this month – December 2019. 

This notice of proposed rulemaking, whenever it is published, is supposed to update the OSHA standard to Continue Reading…

OSHA
OSHA Workplace Safety During the Holidays

There are numerous holidays in the months of November and December.  Just a quick look at Wikipedia confirmed at least 47 holidays for Christian, Secular, Hindi and Buddhist celebrations.  Each has its own traditions, decorations and food.  Given that large number, OSHA has some advice to keep workplaces safe during this time of year.  Don’t think this doesn’t apply to you and quit reading.  Think about the increase risks for personnel in warehouses and offices, on transportation teams, retail workers, etc.  E-Commerce is at an all time high which adds another layer to this busy season.

In the most recent Quick Takes Newsletter, there is a link to multiple resources which can be used for worker safety.  The link to reach those resources is https://www.osha.gov/holidaysafety.html.  I browsed through a few of the topics and here are just a few of the highlights.

  • Warehouse Safety Pocket Guide.  There are 10 OSHA standards that could apply to workers in a warehouse.  The standards include hazard communication, electrical safety, personal protective equipment (PPE) and forklifts.  There are also the hazards associated with loading docks, conveyors and charging stations to consider.  This guide provides a nice overview of the possible hazards and solutions for workers in the warehouse.
  • Safety Practices Once Tractor Trailer Drivers Arrive at a Destination.  While just a short 1-page resource, the information is a nice reminder not only for Continue Reading…
Air Canada Cargo – Section II Lithium Batteries Transport Document

It’s really no surprise that something new has come up with shipping lithium batteries again. Frankly speaking, these days it’s easier to ship a radioactive shipment on a passenger aircraft then a cell phone. Of course, I am referring to the process of shipping when I make this statement. Crazy isn’t it?

Effective Jan 2, 2020, anyone shipping any of the following:

  • Lithium-Ion batteries packed with equipment – UN3481 Section II PI966
  • Lithium-ion batteries contained in equipment – UN3481 Section II PI 967
  • Lithium metal batteries packed with equipment – UN3091 Section II PI 969
  • Lithium metal batteries contained in equipment – UN3091 Section II PI 970

With Air Canada cargo must complete and sign Lithium Batteries – Section II – Shipper’s Transport Document. The contents of the document include:

  • certifying shipment doesn’t include forbidden lithium battery shipments such as defective/damage batteries;
  • verifying the watt-hour for lithium-ion batteries meet Section II requirements;
  • verifying lithium metal content for lithium metal batteries meet Section II requirements;
  • airway bill includes the statement, if applicable;
  • lithium battery mark is on the package(s), if applicable; and 
  • shipper’s declaration statement. 

This document reinforces the fact that any person preparing or offering Section II lithium batteries must receive adequate instruction (IATA section 1.6). Basically, have some sort of dangerous goods training before you can ship lithium batteries. 

Up here in Canada we are limited to dangerous goods Continue Reading…

What is an Overpack?

Every few days one of our customers will call our Regulatory Helpline with questions about overpacks. Given the complexity of them, it is time to set the record straight. The focus for this blog will be the IATA Dangerous Goods Regulations as they seem to give a clearer picture, in my opinion, than those of 49CFR for US ground, IMDG for international vessel, and TDG Canadian ground regulations.

To start, let’s look at a few definitions. These are found in IATA’s Appendix A. Some of these may seem silly on the surface, but they are needed to drive the point home about overpacks. These definitions will all pertain to non-radioactive shipments.

  • Packaging: One or more receptacles and any other components or materials necessary for the receptacles to perform their containment and other safety functions and to ensure compliance with the minimum packing requirements of these Regulations. 
  • Package: The complete product of the packing operation consisting of the packaging and contents prepared for transport
  • Overpack: An enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage. Dangerous goods packages contained in the overpack must be properly packed, marked, labelled and in proper condition as required by these Regulations. Note: Shrink-wrap or banding may be considered an overpack. 

What is all of that in reality? Packagings are the pieces and parts that Continue Reading…