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.
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…
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.
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…
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.
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…
On April 28, 2017, IDC Technologies held their second Dangerous Goods Conference in Mississauga, Ontario. Two of our regulatory staff from ICC were among the presenters during a day of informative sessions that covered transportation, environmental, and safety aspects of the Transportation of Dangerous Goods Regulations (TDG).
ICC Regulatory Consultant Clifton Brown presented his study of the effect the current lithium battery regulations are having on air safety, with a look over the history of accidents involving these batteries since they were first introduced in the early 1990s. Clifton did a lot of sifting through reports from government and industry sources to conclude that the regulations on lithium batteries have a way to go to make them a negligible hazard. Perhaps by the time they are, we’ll have invented safer methods of energy storage.
I presented an overview of the Globally Harmonized System (GHS) changes to health and safety regulations, and whether the GHS Purple Book has achieved worthwhile harmonization in the same way as the UN Recommendations on the Transport of Dangerous Goods (the Orange Book). Unfortunately, we’ll have to deal with a lot of disharmonization remaining in the short term (such as the differences on dealing with environmental hazards between North America and Europe). However, the Orange Book has, slowly but surely, led regulators Continue Reading…
On March 25, 2017, the United States government implemented a ban on passengers bringing carry-on electronic devices such as laptops on board certain airlines. This ban will affect electronics that exceed the size of a cellphone—typical products that will be banned include laptop computers, tablets such as the iPad and Android versions, gaming devices larger than a cellphone, DVD players, and portable printers and scanners. These devices may still be carried by travelers, but must be stowed in checked luggage during the flight. Medical devices will be exempted from the restrictions.
The ban affects flights leaving from ten airports in eight Middle Eastern countries.
Airports Involved in the Ban:
Abu Dhabi International Airport, Abu Dhabi, United Arab Emirates
Ataturk International Airport, Istanbul, Turkey
Cairo International Airport, Cairo, Egypt
Dubai International Airport, Dubai, United Arab Emirates
Hamad International Airport, Doha, Qatar
King Abdulaziz International Airport, Jeddah, Saudi Arabia
King Khalid International Airport, Riyadh, Saudi Arabia
Kuwait International Airport, Kuwait City, Kuwait
Mohammed V Airport, Casablanca, Morocco
Queen Alia International Airport, Amman, Jordan
The ban affects flights of the following airlines leaving from any airports listed above:
Royal Air Maroc
Royal Jordanian Airlines
The ban is intended to only apply to direct flights from these locations to the U.S., which would total just about 50 flights a day. Continue Reading…
A few years ago, someone wrote an irate letter to his local newspaper about the deer warning signs put up on a local highway. He couldn’t understand why they were always on busy highways. Wouldn’t it reduce accidents if the deer were told to cross smaller roads instead?
We may laugh, but the story does bring up an interesting point. Just how effective are traffic warning signs? They can be found wherever we travel, from the common “sharp curve ahead” to the more esoteric, such as the “moose warning” signs in Newfoundland. Highway safety departments consider them an important part of improving driving safety. But how well do they work?
Apparently, the answer is somewhere between “not great” and “we’re not sure.” There’s little research on the effectiveness of highway traffic signs and what there is shows that a surprising lack of effectiveness. For example, the Minnesota Department of Transportation has admitted:
“Signs that alert drivers to infrequent encounters or possible situations–such as deer crossing or children playing—do not have a consistent impact on driver behavior. Widespread use or misuse of warning signs reduces their overall effectiveness.”