TDG Emergency Response Assistance Plans (ERAP) Update
On June 30, 2018, Transport Canada issued a proposed amendment to Part 7 of the Transportation of Dangerous Goods Regulations (TDG). This part covers the requirements for Emergency Response Assistance Plans, or ERAPs. Details can be found on Government of Canada’s website.
Canada’s ERAP requirements are unique, not being adopted from the UN Recommendations on the Transport of Dangerous Goods. Essentially, they require consignor of significant amounts of high risk dangerous goods to establish a specific protocol, often involving an on-call response team, that can assist local responders in case of a release. Transport Canada must review and approve the plan before the consignor can offer or import affected shipments (although the approval only has to be issued once.) Since the Lac-Mégantic disaster in 2013, improving ERAP requirements has been a particular concern of Transport Canada’s.
The June amendment has four main goals:
- To clarify how an ERAP should be implemented;
- To enhance emergency preparedness and response;
- To reduce the regulatory burden for those affected by the requirement; and
- To make some general “housekeeping” changes to keep all parts of the regulations harmonized.
Clarifying Implementation of ERAPs
Currently, the regulations are unclear as to how exactly an ERAP would be implemented – presumably it would be by emergency responders or by the person with control of the released material, but it’s never been Continue Reading…
Are You Ready for e-Manifests?
Paperwork – it’s one of the worst parts of dealing with hazardous waste shipments. In both Canada and the United States, hazardous wastes require a special document, the Waste Manifest that will not only serve as the transportation document for the dangerous goods/hazardous materials transportation regulations, but also allow environmental authorities to track the waste from the generator, who sends it for disposal, through the hands of the carrier, to the end receiver (in the US referred to as a TSDF, for Hazardous Waste Treatment, Storage and Disposal Facility).
In Canada, some jurisdictions have eased the burden by allowing the waste manifest to be created electronically. For example, in Ontario, the HWIN system has been used for years. However, until now, the United States has not had a system for electronic documentation, called e-Manifests. On June 30, 2018, that has changed.
The change has been a long time coming. Although the initial proposal by the Environmental Protection Agency (EPA) was made in 2001, it was not until 2012 that Congress passed the “Hazardous Waste Electronic Manifest Establishment Act.” Under the Act, a final rule was published in 2014 that approved the use of such manifests. Since then, the EPA has been working to create an online system that will allow the e-manifest to eliminate substantial chunks of the burden of manifests, as well as Continue Reading…
National Day of Mourning is April 28th
On a winter’s day in February, 1891, my great-grandfather was working in a coal mine in Springhill, Nova Scotia, when in an instant his world changed. An explosion deep in the mine erupted, sending fire sweeping through the tunnels. About 125 of his friends and coworkers died that day. With the rest of the community, he helped carry out the dead from the shattered pits. The story passed down in my family how he found the worst was carrying out the bodies of the children, some as young as ten, who worked beside him in the mine.
How Did This Happen?
How did this disaster happen? The inquiry never reached a firm conclusion, but such incidents were common in those days, when mines filled with coal dust were time bombs waiting for a spark. One might think the mine operators would have learned, but two more high-fatality accidents happened in Springhill (1956 and 1958), before the mine was closed for good.
In some ways, we live in a lucky era. Most of us who go to work each day expect to return home alive and well. Historically, though, the workplace could be a deathtrap. Although even the earliest farming and gathering communities faced hazards, the Industrial Revolution brought more people into contact with dangerous working conditions than ever. Workers in factories could be Continue Reading…
DGAC Summit 2017
One of the highlights of the year, at least for those of us involved in dangerous goods regulations, is the annual summit meeting of the Dangerous Goods Advisory Council (DGAC). This year, it was held in Crystal City, just outside of Washington, DC, and as always had many speakers from both government and industry. Of course ICC attended, and I was graciously invited to give a couple of talks on the Canadian Transportation of Dangerous Goods (TDG) Regulations, and to take part in a fun closing activity known as “speed-dating the regulators”.
The introductory talk was given by Brigham McCown, former deputy administrator of the Pipeline and Hazardous Materials Safety Administration (PHMSA). As a longtime political insider, he discussed the state of the department under the new administration, and how the once “sleepy little agency” was moving forward. He identified top trends in transportation such as infrastructure investment, autonomous (self-driving) vehicles, drones, and of course reducing unnecessary regulatory burden while still ensuring public safety. He mentioned that the new Secretary of Transportation, Elaine Chao, was experienced and would help the department adapt.
Other speakers representing PHMSA included Shane Kelly, who provided an overview of upcoming changes to hazardous materials regulations, and a report on the United Nations Transport of Dangerous Goods Sub‐Committee by Steven Webb, Aaron Wiener, and Lindsey Constantino. Amy Parker of the U.S. Coast Continue Reading…
Going to Switzerland!
This September, ICC was offered an interesting opportunity – presenting a class on North American hazardous materials regulations in Switzerland! So, I gathered my passport and computer, and set off for Europe.
The course was organized by SAFETY Training Plus GmbH, a well-known provider of dangerous goods training in Germany and Switzerland. However, SAFETY Training Plus found that many of its customers were looking for help with shipments to North America. Although European and North American regulations are usually based on the UN Recommendations for the Transport of Dangerous Goods (better known as the Orange Book based on its cover), a number of variations still exist between the various countries and regions.
For example, a European shipper to the United States might be puzzled about why a product not classified as an environmental hazard under the EU regulations (ADR/RID) or the International Maritime Dangerous Goods Code (IMDG) for ocean would have to be treated as such for entry into the U.S. Surprise! It’s the Hazardous Substance rule, involving a list of over a thousand chemicals that are classified as environmentally hazardous in Title 49, U.S. Code of Regulations (49 CFR). Another shipment may hit a snag entering Canada due to Canada’s requirement for an Emergency Response Assistance Plan. This requirement usually applies to high-risk goods in large means of containment, but may sometimes affect smaller materials Continue Reading…
Dangerous Times, Dangerous Goods
This year has seen environmental disasters that have put millions of people at risk. From the incredible one-two-three punch of Hurricanes Harvey, Irma and Maria, to the Bangladesh floods, to the recent earthquake in Mexico, we see people facing lack of food, clean water and shelter. All of us need to protect ourselves and our loved ones during these periods when outside help hasn’t arrived. But while we’re watching out for what Mother Nature can throw at us, we must also remember hazardous chemicals and articles, even those that can help us survive, can put us in danger as well.
How to Prepare for Natural Emergencies
What does a typical household need to prepare for natural emergencies (or even man-made ones such as chemical spills that can isolate and endanger communities)? A number of websites list “must haves” and “should haves” for these situations, including:
What are some of the hazards that our own preparations can create?
One of the biggest dangers during emergencies is generators. These internal-combustion power sources can be lifesaving, especially for those with special health needs, and can make life during power outages more bearable. But they function by burning fuel, which can Continue Reading…
It seemed such a simple task at the time. A company decided to expand their consumer product line to include perfumes. They expected to send orders to customers, as they did their other products, by airmail. Yet, when setting up the shipment, an unexpected roadblock appeared. The U.S. Postal Service (USPS) told them that the perfume was a hazardous material.
How can a common consumer product like perfume be hazardous for transportation? Most perfumes have an alcohol base, designed to evaporate quickly leaving the scent behind. Unfortunately, this means that such perfumes are flammable liquids for transportation and are subject to Department of Transportation (DOT) as well as USPS restrictions for both ground and air transport.
So, the decision to go into perfumes created some major headaches for the company. But they recently got some good news. If the perfume is based on ethanol, one of the most common alcohols, the company will get a break – USPS has reduced the requirements for this one solvent. Ethanol, or ethyl alcohol, can be found in many consumer products, ranging from perfumes to hairspray to bath oil. By reducing the requirements for shipment of these products, shippers will enjoy reduced costs and complexity.
Airmailing Hazardous Materials
If you wish to airmail hazardous materials in the United States, your first step should be to consult USPS Publication 52 – Hazardous, Restricted, and Perishable Mail. Continue Reading…
Updated State Variations
International shippers of dangerous goods by air have one advantage over shippers by other modes. The International Civil Aviation Organization (ICAO) includes in its Technical Instructions for the Safe Transport of Dangerous Goods by Air a list of “state variations”. These indicate which countries have additional restrictions and requirements placed upon dangerous goods traveling to, from, or through those countries. Being aware of such variations can save shippers significant time and money – if your goods must travel through, say, Norway, your shipment might be stopped or even seized if Norwegian regulations don’t allow it.
Of course, as regulations and related information develop over time, these variations will change, sometimes faster than the actual Technical Instructions themselves. On May 19th, ICAO published an addendum to the state variations that were published in the 2017-2018 edition of the Technical Instructions. While there have not been a lot of changes, some of these are significant for shippers who must obtain permits or exemptions from state authorities, and one eases the requirements for shipping engines by aircraft in the United States.
The changed variations in the Addendum include the following:
Belgium – Variations BE1 specifies the regulation in which to find the Belgian definition of “explosive.” BE2 gives new contact numbers for the government department responsible for prior authorization for shipments of explosives, while BE4 gives new contact numbers for authorization Continue Reading…
The Problem with Smart Luggage
Some of you may remember the old credit card commercial that featured the epic journey of a self-propelled suitcase seeking its lost owner. Well, it turns out this wasn’t so entirely fantastic. There’s a new generation of “smart luggage” hitting the market that can tell airlines electronically who it belongs to and where it’s going, trail after you down airport hallways without a handle, and charge your cellphone if you can’t make it to one of those electrical outlets airports seem to hide on purpose. Some will even double as transport devices themselves, allowing travelers to zip around terminals on their own electric suitcase-scooters.
But these modern technologies come with a problem that’s often overlooked. The energy sources for all these seemingly-magical functions are usually lithium batteries. Lithium batteries are one of the main causes of fires related to dangerous goods on aircraft. So travelling with the newest piece of high tech luggage can bring headaches both for the traveller and the airline he or she flies on.
The International Air Transport Association (IATA) has for many years established rules for equipment containing lithium batteries carried by passengers or crew, but dangerous luggage is a new area. To help, they’ve published a guidance document that covers the dangers associated with such luggage, and instructions on how it can be carried safely.
The document lists various Continue Reading…
AAR’s Field Guide to Tank Cars Download
Are you a birdwatcher who’s spotted every owl and thrush, and wants to move on to a new field of study? Are you a model train hobbyist who wants to make sure your HO scale equipment accurately reflects modern regulations? Or are you a safety professional who deals with bulk dangerous goods in tank cars? If your answer to any of those questions is “yes,” the American Association of Railways (AAR) has published something that will make identifying a TC-111A100W5 or DOT-117R100W as easy as telling a Mourning Warbler from a Laughing Gull.
AAR’s Field Guide to Tank Cars, by Andy Elkins, is a resource for rail workers and particularly for emergency responders. Tank cars come in many varieties, and handling them safely or responding to spills means that you must know what type of car is involved. The Field Guide has been updated for its third edition to reflect current regulations and standards, which have changed over the past decade due to incidents such as the Lac-Mégantic explosion in Quebec.
Types of Tank Cars
The Field Guide starts with a discussion of the basic types of tank cars – non-pressurized tank cars (also known as “general service” or “low-pressure” cars), pressure tank cars for products such as liquid propane and cryogenic liquid tank cars, used for gases that are liquefied at low Continue Reading…