Compressed Gas
CSA Cylinder Standards – June 2018 Update

compressed gas cylinders

CSA issues new Editions of TDG Class 2 Cylinder Standards

Transport Canada has issued an update “Notice” to inform the regulated community of recent updates to the Canadian Standards Association (CSA) standards addressing the requirements for the manufacture/qualification, selection and use of cylinders used in the transportation of dangerous goods (TDG).

Although these standards are primarily for compressed gases, their use may also be required or permitted for DG substances, other than Class 2, that may produce toxic or flammable vapours. Typically, this information is cited in standard TP14850 by reference in the packing instructions.

The four standards involved are:

CSA B339, CSA B340
(design/manufacture/qualification and selection/use, respectively) regarding cylinders, spheres and tubes, and other similar containers.
CSA B341, CSA B342
(manufacture/qualification and selection/use, respectively) regarding UN pressure receptacles and multi-element gas containers (MEGC).

Why Two Sets? Origins

The B339/B340 set are the seventh revision to the standards based on the older CTC (Canadian Transport Commission, pre-Transport Canada) national standards for these types of containers. These versions are the seventh revision of the original editions commencing in 1983 and 1986 respectively.

This contrasts with the B341/B342 set derived from the standards in UN Recommendation model regulations. The Canadian versions referenced here are the 3rd editions following 2009 and 2015 editions. Issuing these as CSA standards, rather than just adopting the UN Recommendations, facilitates incorporating the country-specific aspects such as special permits, reciprocity, etc.

Details

Although the 2 Continue Reading…

TDG Standards on the Move – Explosives Plus TP14850 & TP14877

TDG Update - Red and white semi truck on the highway

CGSB.43-151 Class 1 Explosives Draft Update

There have been some recent developments in 2 of the packaging standards of potential interest to the DG community involved with Canadian transportation.

  • TP14850- Class 3-6.1, 8 and 9 Small Packaging pre-publication 3rd Edition-Transition to CGSB
  • TP14877- Rail Transition to CGSB

CGSB-43.151 Explosives Packaging Standard

Transport Canada has provided notice of a consultation on a proposed update of the Canadian General Standards Board (CGSB) standard “Packaging, Handling, Offering for Transport and Transport of Explosives (Class 1),” CAN/CGSB.43-151.

The new edition, to replace the current 2012 edition, will update the list of UN numbers and packing instructions to align with the UN Recommendations 20th edition; and update references to other dangerous goods container standards.

Also proposed in the draft are packing instructions for UN large packaging (ELP) to supplement the existing standards for IBC and portable tanks.

New Canadian domestic packing instructions (CEP 01) for jet perforating guns, used in oil well completion, are also included in the draft. Previously packaging of these (UN0124 and UN0494) had to be authorized on a case-by-case basis as referenced in EP 01.

CEP 02 replaces the previous EP 17 for highway and portable tank transport.

In common with the recent approach in other Canadian standards, changes to the organization of information, as well as regulatory requirement updates and additional definitions are part of the draft.

New or clarified definitions are provided for “IM” and “IMO-type” Continue Reading…

Radioactive
Class 7 IAEA Regulatory Update – SSR-6 Rev. 1, June 2018

Radioactive material warning sign at the package

Regulations for the Safe Transport of Radioactive Material

– Specific Safety Requirements No. SSR-6 (Rev. 1)

As expected, the IAEA has published the 2018 amendment to SSR-6 as Revision 1 (SSR-6).

This Revision removes the term “radiation level” from Section 2 “Definitions,” replacing it by “dose rate” to designate the dose equivalent per unit time (e.g. mSv/h). The associated changes to sections referencing the term throughout the document account for many of the other paragraph (para.) changes.

Also deleted from this edition are the requirements for testing LSA-III material for residual water activity below 0.1 A2 in the 7-day leachate test.

Table 2 “Basic Radionuclide Values” has been updated to include entries for:
Ba-135m, Ge-69, Ir-193m, Ni-57, Sr-83, Tb-149 and Tb-161.

Enter SCO-III

Perhaps the most significant change is the expansion of surface contaminated objects (SCO – “a solid object that is not itself radioactive but which has radioactive material distributed on its surface”) to add SCO-III provisions in the regulation. The Table 1 list of UN numbers, proper shipping names and descriptions now includes SCO-III to SCO-I and SCO-II for UN2913.

In addition to meeting the general requirements for the SCO designation, SCO-III objects are defined in para. 413(c) as a large solid object that is too large to be transported in the type of package described in SSR-6. There are other criteria to be met regarding sealing of openings, insides being as dry Continue Reading…

DOT 49 CFR USA
No Placards, No CDL Endorsement – USA Only

Truck Driving on highway at sunset

Hazmat Certification Under Placarding Exemption

The US DOT recently issued a “Letter of Interpretation” (LoI) regarding the lack of a need for a driver to have a hazmat (hazardous materials) endorsement on the CDL (Commercial Driver’s License) when transporting Class 9 hazmat within the US, despite the presence of Class 9 placards.

Changing Modes without Removing Placards

This situation is likely to occur when foreign shipments arrive which did not have the equivalent to the US 49 CFR §172.504(f)(9) conditional exception for Class 9 placarding, and are to be transported to their US destination.

An example would be if a Class 9 consignment arrives by vessel, which has placarding in conformance with the IMDG Code, and is picked up for road transport without removing the placards.

Even if the placards are not removed, there is not a requirement for the hazmat-endorsed CDL (equivalent to a TDG training certificate- for readers North of the 49th, metonymically speaking).

Note that, despite the exception for an actual Class 9 placard, §172.504(f)(9) does require bulk packages to be marked with at least the UN number.

Key to the Endorsement Exemption

49 CFR §383.93(b)(4) invokes the need for a hazmat CDL when the definition of hazmat in 383.5 is met. For substances defined as hazardous in 49 U.S. Code §5103(a) and (other than infectious substances/ biotoxins in 42 CFR §73) requiring placards, the CDL endorsement is required.

Thus, for most Continue Reading…

Lithium
How to Ship Damaged or Defective Lithium Batteries

Swollen lithium polymer batteries. Dangerous and harmful electronic waste

Regular Damaged or Defective or Dangerous Damaged or Defective?

There is a fair amount of interest in the topic of preparing Damaged or Defective (DoD) lithium batteries for transport and how to make a determination of the degree of hazard they present.

The current (20th) 2017 Edition of the Recommendations on the Transport of Dangerous Goods (UN Model) Regulations have addressed the former (packaging for transport) aspect, but the documents currently posted have not yet established firm protocols for the latter.

The situations involving recalls of defective, unsafe batteries and incidents during transportation has sustained the efforts to find better ways of dealing with them. The topic has been under discussion at the United Nations Sub-Committee of Experts on the Transportation of Dangerous Goods (TDG) in most sessions over the last several years.

For this discussion we’ll refer to cells/batteries that do not meet the UN Manual of Test criteria due to damage or defect, without specific safety hazards, as “regular” DoD; and those that “are liable to disassemble rapidly, react dangerously, produce a flame or a dangerous evolution of heat, or produce a dangerous emission of toxic, corrosive or flammable gases or vapours” as “dangerous” DoD.

This distinction is proposed for clarification in the next version (21st Edition) of the UN Model. See, for example, working document ST/SG/AC.10C.3/2018/51:
http://www.unece.org/fileadmin/DAM/trans/doc/2018/dgac10c3/ST-SG-AC.10-C.3-2018-51e.pdf

Batteries or Reactive Substances?

As a technicality, we should pause to consider the basic Continue Reading…

TDG
New Draft: CGSB Standard 43.145

Man preparing shipment

TDG Large Packaging

Still Time to Review the draft “Design, Manufacture and Use of Large Packaging for Transportation of Dangerous Goods in Classes 3, 4, 5, 6.1, 8 and 9

Transport Canada provided notice last month of the availability of a draft Canadian General Standards Board (CGSB) standard for large packagings for specified classes of dangerous goods (DG). The contents of the draft are largely based on the UN “Recommendations on the Transport of Dangerous Goods Model Regulations” (UN TDG Model) 20th Edition.

The draft is open for comment by interested parties until June 8, 2018.

Similar, but Not Identical

Although the current draft is based on the 20th edition of the UN Model, there are some differences – for example: the Canadian TDG regulations (TDGR) have not yet updated Schedule 1 to the current UN numbers above UN3534; TDGR cite Class-specific standards for certain DG (Classes 1, 2, 6); and not all of the lithium battery packaging has been incorporated.

The CGSB-43.145 proposal does, however, contain a supplementary instruction for UN2794 and UN2795 permitting these batteries to be shipped unpackaged on shelving that is permanently fixed within a vehicle. This LP801 standard presumably replaces equivalency certificates providing the option to battery distributers and members of automotive industry associations.

The UN Model and CGSB 43.145 are similar in restricting the use of large packaging to the lesser hazardous Classes/Divisions, typically at the packing Continue Reading…

TDG
March 2018 TDG TP 14877 Update

Railway Tanker Transporting Dangerous Goods

Rail TDG Standard TP 14877 Update

On March 15 Transport Canada released a notice on the intent to issue a new January 2018 edition of standard TP 14877 “Containers for Transport of Dangerous Goods by Rail” to replace the current 2013 (with Corrigendum) edition.

This is the penultimate culmination of the public process, in part arising out of the Lac Mégantic 2013 disaster, undertaken by a stakeholder Consultative Committee that began in February of 2016.

The main features of the proposed 2018 edition include:

  • Improved usability by incorporating external technical requirements, such as those in Protective Direction 34, 37 and 38.
  • Updated dangerous goods list to align with the 19th edition of the UN Model Regulations. Adjusted special provisions to reflect updated transportation requirements for Sulphuric Acid (UN1831) and Hydrogen Peroxide (UN2014 / UN2015).
  • Updated technical requirements for Class 3, Flammable Liquids and the new tank car specification known as TC 117.
  • Improved harmonization between tank car requirements in Canada and the US, including tank car approvals, tank car design requirements and a new mechanism to secure One Time Movement Approvals (OTMA) – Category 2.
  • Updated material of construction requirements for tank cars, including the addition of stainless steel, normalized steel for dangerous goods classified as a toxic inhalation hazard (TIH) and improved thickness requirements for new tank car construction.

Comparing the 2013 and 2018 Standard TP 14877

A brief comparison of the TABLE OF CONTENTS Continue Reading…

TDG
2018 TDG Registration and Fines FAQ

Red semi truck on highway

REGISTRATION and FINES and FAQs, OH MY!

February and March contain some interesting items potentially impacting the Canadian TDG landscape…

Registration-CID Consultation

Transport Canada, through a consultation notice published in late February, has solicited input from stakeholders on a plan to require those who handle/offer for transport, transport or import dangerous goods to register with Transport Canada.

The premise is that, “… public safety depends” on Transport Canada knowing who is transporting DG, including where, when, and how much. The main thrust of this proposal seems to be for targeting enforcement and consultation activities.

The proposal as currently presented does not appear to distinguish among the size, frequency, or nature of DG involved; and will require period re-registration with submission of data to the “Client Information Database” (CID).

There’s nothing in the posted information to indicate whether there will be a cost to “clients” for registration, in addition to the record-keeping burden they will bear.

(For those familiar with the 49 CFR §107 (Subpart G) requirement, intended to subsidize government response activities, this TDG version does not serve the same purpose.)

The only exemptions currently contemplated, extend to those falling under a TDGR Part 1 “special case” exemption. This contrasts with 49 CFR’s registration which has exemptions based on load sizes and hazard types.

The TC proposal and comment provisions are found at:
https://letstalktransportation.ca/cid

Contraventions Regulations

While not directly cited in the Transport Canada TDG Act or regulations, Continue Reading…

TDG
Standard TP14850 Pre-Canada Gazette (CG) I Consultation

Truck Driving on highway at sunset

Updated TDG Packaging Standard – Small Containers for Classes 3, 4, 5, 6.1, 8, & 9

In addition to expanding the title to reflect the various types of containers contemplated in the Transportation of Dangerous Goods regulation (TDGR) §5.6, 5.12 (and cited within other referenced standards), this “final draft” reflects the penultimate result of a review that’s been active since the adoption of the current edition in 2015.

Anatomy of Development

The 2nd Edition of TP14850, published October 2010 was adopted into the Canadian TDGR in July 2014, replacing CGSB-43.150-1997 and becoming the mandatory standard for packaging the “common” classes of dangerous goods in Canada in January 2015.

The 16th Edition (2009) UN Model was the primary basis for the 2010 TP14850 standard, so it was time to move forward in the spirit of harmonization.

Transport Canada began the process of forming a consultative committee in mid-2015. A public notice regarding the consultation was published in early 2016 with provision for general public input. The committee, formed in April 2016, consists of about 3 dozen participants.

The committee includes a core group of 6–8 from Transport Canada with the remainder representing a variety of industry associations, individual manufacturers, users, provincial/US regulatory interests, and labour organizations.

The draft presently open for general comment was developed by consensus following discussions, including face-to-face meetings and a series of web/teleconference sessions, between April 2016 and June 2017. Continue Reading…

United Nations Logo
20th UN Model Recommendations for Dangerous Goods Transport (Orange Book)

UN Model Regulations (Orange Book)

2017 (20th Edition) – Highlights Changes

Those who follow the IATA DGR will have an idea of many of the changes resulting from the UN Recommendations expected to result from the changes in the 20th Edition of the commonly titled “Orange Book”.

Those who work with other modal/government regulations may not be familiar with changes that will likely follow in those regulations as all or part of the amended Model become incorporated.

Changes in Terminology

As often happens, terminology changes were introduced to this edition to clarify or technically improve concepts covered by the regulations. Throughout the document the term “risk” has been replaced by “hazard” to reflect the intent of referring to a danger.

Similarly, most references to “devices” now refer to “articles” which is defined in 2.0.5.1 as including “machinery, apparatus or other devices”.

New UN Numbers

UN3535 to UN3548 have been added to the collection:

  • UN3535 refers to “TOXIC SOLID, FLAMMABLE, INORGANIC, N.O.S.”
  • UN3536 is a new “LITHIUM BATTERIES INSTALLED IN A CARGO TRANSPORT UNIT” applicable to either ion or metal-based batteries.
  • UN3537 through UN3548 cover a sequence of listings for “ARTICLES CONTAINING…, N.O.S.” applicable to a variety of Class 2-5, 6.1, 8 and 9 dangerous goods.

The additional entries result in related changes to classification sections and special provisions.

Lithium Everywhere

As we’ve seen over the last few years regulation of lithium battery regulations continues to evolve.

The concept of “equipment” in the sense of lithium Continue Reading…