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 220.127.116.11, 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…
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.
ERAPs are unique to Canada, and are intended to ensure support for local responders in catastrophic spills, such as the 2013 Lac-Mégantic derailment. 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.)
The amendment has three main goals:
clarify ERAP implementation and reporting;
enhance emergency preparedness and response; and
make housekeeping changes that address smaller issues.
The amendment replaces all the text of Part 7, although unamended requirements will remain the same. Changes also occur in Parts 1, 3 and 8.
Clarifying Implementation of ERAPs
The original requirements of Part 7 didn’t go into any detail as to how 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 established precisely. The amendment addresses initial notification of an accident requiring ERAP response, and clarifies that the person with the ERAP Continue Reading…
If your business is like most, you don’t usually deal with shipping explosives in Class 1. However, this class sometimes shows up in places you’d least expect it. While it’s expected to deal with explosives in construction, mining, and the military, you can also find explosives in unexpected products such as toys (caps for cap guns), pyrotechnics for stage and movie productions, and animal tracking collars (some use explosive bolts to free the animal so it doesn’t have to make a permanent fashion statement).
Shipping explosives can be more complex than many other classes of dangerous goods. They are subject to other regulations, such as the Explosives Act, and may require special licensing depending on what type they are. In addition, they are often excluded from some of the common exemptions found in Canada’s Transportation of Dangerous Goods Regulations (TDGR). For example, explosives can’t use the Limited Quantity exemption of section 1.17, or the Excepted Quantity exception found in section 1.17.1. Some low-level explosives may qualify for the 150 Kilogram Gross Mass Exemption in section 1.15 and the 500 Kilogram Gross Mass Exemption in section 1.16, but only if they fall into certain divisions, compatibility groups or UN numbers. You’ll need to read each exemption closely to ensure that your particular explosive will qualify.
To balance things out, TDGR does contain some provisions for shipping small amounts of low-level Continue Reading…
If you’ve ever applied for an interpretation from the U.S. Department of Transportation, or even looked one up online, chances are you’ve found a solution to your problem in a letter signed by Edward Mazzullo, longtime Director of the Office of Hazardous Materials Standards of the U.S. Department of Transportation (DOT). Mr. Mazzullo’s commitment to clarifying the complexities of the Hazardous Materials Regulations, as well as his career devoted to developing and improving regulatory standards, has resulted in him being awarded the George L. Wilson Award by the Dangerous Goods Advisory Council (DGAC) at its 40th Annual Summit and Exposition in Arlington, VA.
Each year, DGAC, a major organization for the education of the private and public sectors on transport of dangerous goods issues, presents the George L. Wilson Award to an individual, organization or company that has demonstrated outstanding achievement in the field of hazardous materials transportation safety. Previous winners include former members of the DOT, but also representatives of industry, and international representatives such as Linda Hume-Sastre, who labored for many years on the Transportation of Dangerous Goods Regulations for Transport Canada. Even CHEMTREC, the well-known emergency information service, has received the award.
DGAC presented the award to Mr. Mazzullo at a lunch attended by many hazardous materials professionals who have benefitted from his guidance through the years. We applaud his long service, and dedication to Continue Reading…
A long time ago, when I was first living on my own, I made, or tried to make, a cheesecake. All the ingredients had been mixed and poured carefully into the pan. All I had to do was put it in the oven and leave it for the appropriate baking time. Unfortunately, as I was transferring it from the counter, the oven door shifted and jarred my hand. My delicious cheesecake batter ended up sloshing into the preheated oven, solidifying and creating a long and tedious cleanup instead of a tasty treat. All I could tell myself as I scrubbed away was, “It’s a learning experience.”
The same is true of hazardous materials (HAZMAT) incidents. While they produce short-term pain, the long-term gain is that we learn more about how to handle them safely. Therefore, the U.S. Department of Transportation (DOT) has required for many years that incidents such as fires, spills or the discovery by the carrier of unidentified hazardous materials should be reported to them. Under the DOT, the Pipelines and Hazardous Materials Safety Administration (PHMSA), which is responsible for the Hazardous Materials Regulations, established a specific form for this, called DOT 5800.1, the Hazardous Materials Incident Report.
What Needs to Be Reported?
The requirements for reporting are given in 49 CFR section 171.15, “Immediate notice of certain hazardous materials incidents.” A reportable incident is defined as Continue Reading…
Safety Data Sheets (SDSs) have been an important tool for worker safety for decades. In Canada, they became mandatory for hazardous materials in 1988, and although their basic format has been modified by WHMIS 2015 (the Workplace Hazardous Materials Information System 2015), one constant has always been a heading for “emergency telephone number.”
This brings up the question of what number should be on the SDS. Yes, it’s possible to run the emergency number internally, but most companies don’t use this solution. First, if you’re using it for transportation purposes, the law requires that the number be staffed 24 hours a day. Even if you have staff to do that, they must be trained to give effective advice over the telephone. That can be a difficult job, and requires professionals with both technical knowledge and the ability to remain calm in emergencies. Therefore, most companies these days outsource this function to specialist services.
Having a direct line to a live, knowledgeable person can be a true lifesaver in an emergency. Early in my training days, a customer told how he’d been given the job, late at night, of cleaning out a tank of chemicals by siphoning them into a waste container. In those days, safety standards were sometimes lax, and he was taught to start the siphon by mouth. Unfortunately, he was distracted during the procedure and ended Continue Reading…
After an Unfortunate Incident USPS New Rules are Being Created
It was a normal day at the Westgate Post Office, on the outskirts of Rochester, NY. Then a strange odor filled the air, irritating people’s eyes and respiratory passages. By the time the emergency crew had finished its investigation, six people had been sent to hospital for observation, and ten more had been evacuated. At last the culprit was discovered, lurking in an innocuous-seeming package. It turned out that a bottle of nail polish remover inside had broken and the liquid was dripping from the box.
Luckily, no one was seriously hurt. “This was unfortunate, but it could have been worse,” said Karen Mazurkiewicz, spokesperson for the U.S. Postal Service (USPS). It isn’t actually illegal for people to ship small amounts of hazardous materials through the mail in the U.S., as long as shippers comply with the “Hazardous Materials Regulations” of Title 49, Code of Federal Regulations (49 CFR), as well as the “Postal Service Regulations” in Title 39 of the Code (39 CFR). Guidelines for mailing hazardous materials can be found in USPS Publication 52 – Hazardous, Restricted and Perishable Mail.
Unfortunately, many shippers in private life (and even some in industry) aren’t even aware that these regulations exist. And what was created by the U.S. Department of Transportation (DOT) for commercial shippers may not provide workers and Continue Reading…
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…
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…