WHMIS Logo
WHMIS 2015 – June 2017 Deadline Extended

Warehouse with chemicals

Extra, Extra Read All About It!

Health Canada has announced that the deadline for manufacturers and importers to comply with the HPR (a.k.a. WHMIS 2015) has been EXTENDED.

The deadline of June 1, 2017 has been delayed by one (1) year to June 1, 2018. The second deadline of June 1, 2018 has been delayed by three (3) months to September 1, 2018.

The orders and a regulatory impact analysis statement (RIAS) will be published in Canada Gazette Part II shortly. We will provide details as they become available. Stay tuned.

Finally, thank you to everyone that worked with Health Canada to make this extension a reality.

Check out our resources for complying with the WHMIS 2015 regulations »

Labeling
New Hazard Class Label Requirements

Red semi truck on highway

Updated Hazard Class Label Requirements

Stemming from the UN Sub-Committee of experts on the Transportation of Dangerous Goods 40th session, December 2011, and adopted by IMDG, IATA, and PHMSA (US DOT) in 2015. This change to all Hazard Class labels, became mandatory January 1, 2017 for air and ocean shipments. HM-215N issued on March 30, 2017 amended section 172.407 to allow an additional transition period to December 31, 2018 for ground shipments in the USA.

What’s Changed?

This inner line must be 2mm width and also remain at 5mm inside the outer edge even if a reduced size label is allowed.
Note, this is not mandatory for TDG (Canada ground, but will likely become mandatory in future), but customers who ship by ground and air, or ground, air, and ocean will want the consistency now.

Class 3 Label With thick border
New Border

Class 3 Label With thin border
Old Border

The width of the inner border was never previously defined. This change allows for consistency and the wider thickness to make the label more visible.

ICC The Compliance Center is your source for Hazard Class Labels. Our regulatory staff at ICC Compliance Center will be happy to help. Just contact us at 1.888.442-.628 (USA) or 1.888.977.4834 (Canada).

PHMSA Update
Finally . . . HM-215N

Final Rule HM-215N

At long last, HM-215N is officially in place. The Department of Transportation was published in the Federal Register on Thursday, March 30, 2017. This much-anticipated final rule harmonizes the 49 CFR regulations with the United Nations Recommendations on the Transport of Dangerous Goods—Model Regulations (UN Model Regulations), International Maritime Dangerous Goods Code (IMDG Code), and the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions).

Some of the Notable Changes from HM-215N Include:

New entries in the hazardous materials table (HMT) including:

  • UN3527 Polyester Resin Kit, solid base material
  • UN3528 Engine, internal combustion, flammable liquid powdered or Machinery, internal combustion, flammable liquid powered
  • UN 3529 Engine, internal combustion, flammable gas powered or Engine, fuel cell, flammable gas powered or Machinery, internal combustion, flammable gas powered or Machinery, fuel cell, flammable gas powered
  • UN 3530 Engine, internal combustion or Machinery, internal combustion

Amended Proper Shipping names

UN 3151, Polyhalogenated biphenyls, liquid or Polyhalogenated terphenyls, liquid and

UN 3152, Polyhalogenated biphenyls, solid or Polyhalogenated terphenyls, solid by adding “Halogenated monomethyldiphenylmethanes, liquid” and “Halogenated monomethyldiphenylmethanes, solid”

New Special provisions including:

New special provision 422 is assigned to the HMT entries “UN 3480, Lithium ion batteries including lithium ion polymer batteries“; “UN 3481, Lithium ion batteries contained in equipment including lithium ion polymer batteries; “UN 3481 Lithium ion batteries packed with equipment including lithium ion polymer batteries“; “UN 3090, Lithium metal batteries including lithium alloy batteries“; “UN 3091, Lithium metal batteries contained in equipment including lithium alloy batteries“; and “UN3091, Lithium metal batteries packed with equipment including lithium alloy batteries“.

Updates to Hazard Class Labels

Section 172.407 requires that the inner border of the hazard class labels measure 2mm. A transition period was in place, and recently ended on December 31, 2016, however, HM-215N has provided further relief by extending the transition period to December 31, 2018 (for domestic transportation only)

Updates to Lithium Battery Labels

New lithium battery labelSection 172.447 was created to incorporate the new class 9 lithium battery label (the one with the lithium batteries in the center). There is a transition period in place to December 31, 2018.

Lithium Battery Section 173.185

Significant changes to both packaging and hazard communication requirements were amended.


ICC has all of the products you need to comply with HM-215N, under-one-roof. Contact us today.

Anatomy of an ERG

Emergency Response Guidebook

Emergency Response Guidebook (ERG)

The North American Emergency Response Guidebook (ERG) is a tool developed by the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA), Transport Canada, and the Secretaria de Comunicaiones Y Transportes (SCT).

Every 4 years, millions of copies are distributed, free of charge to firefighters and other emergency personnel. The purpose is to provide guidance to first responders during the initial phase of a transport incident involving dangerous goods.

There are Six Sections in the ERG

The white pages are informational. They contain the guidance and explanation on the following:

  • A flow chart provides information on how to use the Guide.
  • Basic safety information for use when responding
  • Hazard classification system
  • Rail car identification
  • Introduction to GHS pictograms
  • International Identification numbers
  • Hazard Identification numbers
  • Pipeline transportation, including pipeline markers

The Yellow Pages are chemicals listed by UN number. The responder would find the chemical by UN number, then follow orange and green pages accordingly. This section is also a handy tool to look up chemical names when you only have the UN number, without having to pull out a 49 CFR!

The Blue Pages are chemicals listed by chemical name. The responder would find the chemical by name, then go to the orange and green pages for instructions. This section is also a handy tool to look up UN numbers when you only have the chemical name, without having to pull out a 49 CFR!

The Orange Pages are the Guides. These Guides provide information to the emergency responder on Health, Fire, Public Safety, Protective Clothing and Evacuation, Spill or Leak and First Aid. In the workplace, the safety data sheet should be the first place to look up this information, but the ERG will do in a pinch.

The Green Pages provide information regarding initial isolation and protective action distances for both small and large spills. In other words, how far should we stay away or evacuate the area.

The final section contains another set of White Pages. These pages provide additional information and guidance including, spill procedures, protective clothing, and a glossary.

The North American ERG is a must have, whether you are an emergency responder, truck driver, or a shipper. Accidents happen, big and small, and the ERG can help you during response and clean up.

Placarding
Is a Placard Required?

Placards on a truck

Answers from the Helpdesk

Placarding is one of the more complicated areas of the hazardous materials regulations. There are so many variables and exceptions, no wonder it becomes confusing.

Let’s practice using a real helpdesk question.

What placards are required for each shipment (49 CFR or TDG)? Write down your answer before scrolling down to read the answer.

SHIPMENT 1: 

9000 LBS (4082 KG) CORROSIVE UN1719, (ALL NON-BULK PACKAGING)

 SHIPMENT 2: 

(ALL NON-BULK PACKAGING)

9000 LBS (4082 KG) CORROSIVE UN1719
1500 LBS (680 KG) CORROSIVE UN1791

1500 LBS (680 KG) CORROSIVE UN3264
1500 LBS (680 KG) CORROSIVE UN3265

 SHIPMENT 3: 

(ALL NON-BULK PACKAGING)

200 LBS (91 KG) CORROSIVE UN1719
200 LBS (91 KG) CORROSIVE UN1791,

200 LBS (91 KG) CORROSIVE UN3264
200 (91 KG) LBS CORROSIVE, UN3265

Click here to see the 49 CFR answers »
Click here to see the TDGR answers »

49 CFR Regulations

The placarding requirements are found in Part 172.500 of the Hazardous Materials Regulations. The general rule is going to be:

If in bulk, you always need a placard.

If non-bulk, then it depends on if the hazard class is in Table 1 or 2, and the amount that is being shipped.

Also, in most cases, 4 placards are required, one on each side and one on each end.

When shipping in bulk, a UN number is required on the placard. You will find this referenced in the marking section Part 172.331.

(a) Each person who offers a hazardous material to a motor carrier for transportation in a bulk packaging shall provide the motor carrier with the required identification numbers on placards or plain white square-on-point display configurations, as authorized, or shall affix orange panels containing the required identification numbers to the packaging prior to or at the time the material is offered for transportation, unless the packaging is already marked with the identification number as required by this subchapter.

(b) Each person who offers a bulk packaging containing a hazardous material for transportation shall affix to the packaging the required identification numbers on orange panels, square-on-point configurations or placards, as appropriate, prior to, or at the time the packaging is offered for transportation unless it is already marked with identification numbers as required by this subchapter.

For non-bulk, the following references are also important:
The reference for this is 49 CFR §172.301(a)(1)(3):

“(3) Large quantities of a single hazardous material in non-bulk packages. A transport vehicle or freight container containing only a single hazardous material in non-bulk packages must be marked, on each side and each end as specified in the §172.332 or §172.336, with the identification number specified for the hazardous material in the §172.101 Table, subject to the following provisions and limitations:

(i) Each package is marked with the same proper shipping name and identification number;

(ii) The aggregate gross weight of the hazardous material is 4,000 kg (8,820 pounds) or more;

(iii) All of the hazardous material is loaded at one loading facility;

(iv) The transport vehicle or freight container contains no other material, hazardous or otherwise; and

(v) The identification number marking requirement of this paragraph (a)(3) does not apply to Class 1, Class 7, or to non-bulk packagings for which identification numbers are not required.”

Answers:

Which placards are required according to 49 CFR?

Shipment 1: 4- Class 8 placards are required with UN1719

Why? The class 8 placard is required as it is being shipped as a single commodity in non-bulk exceeding 8,820 lbs (4000.68 kg)

Shipment 2: 4- Class 8 placards are required, UN number not required

Why? The class 8 Placard is required, the UN number is not required because there are multiple hazardous goods being shipped on the same shipment

Shipment 3: No placards are required

Why? No placards are required because Class 8 materials appear on table 2 and is under 454 kg (1001 lbs)

Transport Canada

The placarding requirements are found in Part 4 of the Transportation of Dangerous Goods Regulations (TDG).

The following are some general rules for placarding under the TDG regulations in Canada.

In most cases, four placards are required, on both sides and both ends of the transport unit.

A placard is required if the chemical is in a quantity or concentration for which an ERAP is required.

If 500 kg or more of a quantity is being transported of one hazard class a placard is required.

4.15.2 UN Numbers on a Large Means of Containment says:

UN numbers, except UN numbers for dangerous goods included in Class 1, Explosives, must be displayed on a large means of containment in accordance with subsection 4.8(2) if the dangerous goods

(a) are in a quantity or concentration for which an emergency response assistance plan is required; or

(b) are a liquid or a gas in direct contact with the large means of containment.

4.16.1 Placarding Exemption for Dangerous Goods Having a Gross Mass of 500 kg or Less says:

Subsection (1) provides an exemption from placarding requirements if the dangerous goods in or on a road vehicle or railway vehicle have a gross mass that is less than or equal to 500 kg.

Subsection (2) sets out which dangerous goods cannot be counted in the 500 kg and are, therefore, subject to the placarding requirements.

  1. Except in the case of the dangerous goods listed in subsection (2), a placard is not required to be displayed on a road vehicle or railway vehicle if the dangerous goods in or on the road vehicle or railway vehicle have a gross mass that is less than or equal to 500 kg.
  2. The exemption set out in subsection (1) does not apply to dangerous goods
    • (a) requiring an emergency response assistance plan;
    • (b) requiring the display of a subsidiary class placard in accordance with section 4.15.1;
    • (c) included in Class 1, Explosives, except for
      • (i) explosives referred to in subsection 4.17(1), and
      • (ii) explosives included in Class 1.1, 1.2, 1.3 or 1.5, if
    • (A) the explosives are not subject to special provision 85 or 86 and have a net explosives quantity that is less than or equal to 10 kg, or
    • (B) the explosives are subject to special provision 85 or 86 and the number of articles of explosives is less than or equal to 1000;
      • (d) included in Class 2.1, Flammable Gases, if the road vehicle or railway vehicle is to be transported by ship;
      • (e) included in Class 2.3, Toxic Gases;
      • (f) included in Class 4.3, Water-reactive Substances;
      • (g) included in Class 5.2, Organic Peroxides, Type B, liquid or solid, that require a control or emergency temperature;
      • (h) included in Class 6.1, Toxic Substances, that are subject to special provision 23; or
      • (i) included in Class 7, Radioactive Materials, that require a Category III – Yellow label.

Answers:

Which placards are required according to the TDGR?

Shipment 1: 4- Class 8 placards are required UN number not required

Why? Class 8 placards are required, because this shipment exceeds 500 KG, but the UN number is not required as there is no ERAP and it is not in a large means of containment

Shipment 2: 4- Class 8 placards are required, UN number not required

Why? Placards are required as the shipment is over 500 KG, but UN numbers on the placards are not required because the ERAP is either non-existent or is not met.

Shipment 3: No placards are required

Why? Because no ERAP are met, and the quantity is less than 500 kg.

No Placards are required for class 8 hazardous material for shipments under 500 KG and when no ERAP is met.


ICC Compliance Center has a variety of tools and “cheat sheets” to help you understand the placarding requirements. Visit our website for more information.

Fire Safety
Spring Ahead – Fire Safety

Smoke Detector

Springtime Fire Safety

It is that time of year again, where we all lose an hour in our day. The good news is that we also gain an hour of daylight, and it means that warmer weather is just around the corner.

Many organizations including the National Fire Protection Association (NFPA) suggest taking the time to also check smoke alarms. The NFPA states:

Roughly two-thirds of home fire deaths occur in homes with no smoke alarms or working smoke alarms. When smoke alarms should have worked but failed to operate, it is usually because batteries were missing, disconnected, or dead. NFPA provides the following guidelines around smoke alarms:

  • Test smoke alarms at least once a month using the test button.
  • Make sure everyone in the home understands the sound of the smoke alarm and knows how to respond.
  • Replace all smoke alarms when they are 10 years old.
  • Replace the smoke alarm immediately if it doesn’t respond properly when tested.
  • Smoke alarms with nonreplaceable (long-life) batteries are designed to remain effective for up to 10 years. If the alarm chirps, a warning that the battery is low, replace the entire smoke alarm right away.
  • For smoke alarms with any other type of battery, replace batteries at least once a year. If the alarm chirps, replace only the battery.

Fire Extinguishers

Also, take time to make sure your fire extinguishers are in good working order. If they are in a business, ensure that inspections are up-to-date. The NFPA provides the following guidance regarding the use of an extinguisher:

Safety tips

  • Use a portable fire extinguisher when the fire is confined to a small area, such as a wastebasket, and is not growing; everyone has exited the building; the fire department has been called or is being called; and the room is not filled with smoke.
  • To operate a fire extinguisher, remember the word PASS:
    • Pull the pin. Hold the extinguisher with the nozzle pointing away from you, and release the locking mechanism.
    • Aim low. Point the extinguisher at the base of the fire.
    • Squeeze the lever slowly and evenly.
    • Sweep the nozzle from side-to-side.
  • For the home, select a multi-purpose extinguisher (can be used on all types of home fires) that is large enough to put out a small fire, but not so heavy as to be difficult to handle.
  • Choose a fire extinguisher that carries the label of an independent testing laboratory.
  • Read the instructions that come with the fire extinguisher and become familiar with its parts and operation before a fire breaks out. Local fire departments or fire equipment distributors often offer hands-on fire extinguisher trainings.
  • Install fire extinguishers close to an exit and keep your back to a clear exit when you use the device so you can make an easy escape if the fire cannot be controlled. If the room fills with smoke, leave immediately.
  • Know when to go.

Sources:
http://www.nfpa.org/news-and-research/news-and-media/press-room/news-releases/2014/nfpa-encourages-testing-smoke-alarms-as-daylight-saving-time-begins

http://www.nfpa.org/public-education/by-topic/fire-and-life-safety-equipment/fire-extinguishers

PHMSA Update
A Small Victory for Harmonization … For Now (HM-215N)

PHMSA Withdraws Final Rule

—PHMSA Update HM-215N

The Pipelines and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) has withdrawn a Final Rule that was intended to be published in the Federal Register on January 26.

The Final Rule, HM-215N, would have updated the U.S. “Hazardous Materials Regulations” to reflect international standards. This was due to the new administration’s Regulatory Freeze executive memorandum, issued January 20, 2017.

Harmonization

HM-215N would have harmonized the 49 CFR regulations to the latest version of the UN Recommendations on the Transport of Dangerous Goods, the ICAO Technical Instruction’s on the Safe Transport of Dangerous Goods, the International Maritime Dangerous Goods Code.

New lithium battery label     New Lithium Battery Mark and Pictogram
New marks and labels introduced in the upcoming international regulations.

 

This delay has made it particularly confusing for shippers of lithium batteries, who have transitioned to the new handling mark, and hazard class 9 label, shown in these international regulations.

Usage

Last week, PHMSA issued a Notice that allows offerors and carriers to use the 2017-2018 versions of the international regulations without fear of enforcement. In addition, it is allowing users to mark and label packages in accordance with either the 2015-2016 or 2017-2018 IATA/ICAO and IMDG regulations.

This notice is limited to 49 CFR Parts 171.4(t) and (v). This notice is expected to be in place until HM-215N is release, or this notice is otherwise rescinded or otherwise modified.

For a full version of the notice, please click here.

ICC is your source for hazardous materials products, services, and training, all under one roof. Contact us today.

Safe Holiday Decorating

Holiday Safety

December means festivity and cheer for many. Many offices, including ours, enjoy bringing the festivities to work by decorating our offices, cubicles, and other office areas.

Safety is always important, festive occasions included. Safety+Health suggest the following to help prevent injuries while celebrating on the job. (Safety+Health Magazine)

Safe decorating

  • Don’t stand on a chair to hang decorations. Use a stepladder, and make sure to read and follow the instructions and warnings on the label. And never hang decorations from fire sprinklers – they can prevent the sprinklers from operating properly. OSHA regulations state that stacked materials should never be closer than 18 inches below fire sprinklers.
  • Planning to string decorative lights or other electrical items in your workspace? The Electrical Safety Foundation International, a nonprofit organization, states that workers should:
    • Be sure that all electrical items are certified by a nationally recognized independent testing lab.
    • Inspect all lights, decoration and extension cords for damage before using.
    • Avoid overloading electrical outlets with too many decorations or electrical devices – they can overheat and cause a fire.
    • Never try to make a three-prong plug fit into a two-prong outlet.
    • Turn off all indoor and outdoor electrical decorations before leaving.

ICC Compliance Center offers a variety of safety courses to train employees on the hazards in the workplace. Visit our website and view our safety courses for more information

From our ICC family to yours, have a safe and happy holiday season.

Safe Winter Driving

As the weather gets colder and inevitable snow and ice arrive, it is time to think about winter driving, and the challenges it brings.

According to the Federal Highway Administration, more than 24% of accidents are cold-weather related.

AAA (http://exchange.aaa.com/safety/roadway-safety/winter-driving-tips/#.WDMTHrIrLRY) recommends the following for driving in snow:

  • Accelerate and decelerate slowly. Applying the gas slowly to accelerate is the best method for regaining traction and avoiding skids. Don’t try to get moving in a hurry. And take time to slow down for a stoplight. Remember: It takes longer to slow down on icy roads.
  • Drive slowly. Everything takes longer on snow-covered roads. Accelerating, stopping, turning – nothing happens as quickly as on dry pavement. Give yourself time to maneuver by driving slowly.
  • The normal dry pavement following distance of three to four seconds should be increased to eight to ten seconds. This increased margin of safety will provide the longer distance needed if you have to stop.
  • Know your brakes. If you have anti-lock brakes (ABS) and need to slow down quickly, press hard on the pedal-it’s normal for the pedal to vibrate a bit when the ABS is activated. In cars without ABS, use “threshold” breaking, keeping your heel on the floorboard and using the ball of your foot to apply firm, steady pressure on the brake pedal.
  • Don’t stop if you can avoid it. There’s a big difference in the amount of inertia it takes to start moving from a full stop versus how much it takes to get moving while still rolling. If you can slow down enough to keep rolling until a traffic light changes, do it.
  • Don’t power up hills. Applying extra gas on snow-covered roads just starts your wheels spinning. Try to get a little inertia going before you reach the hill and let that inertia carry you to the top. As you reach the crest of the hill, reduce your speed and proceed down hill as slowly as possible.
  • Don’t stop going up a hill. There’s nothing worse than trying to get moving up a hill on an icy road. Get some inertia going on a flat roadway before you take on the hill.
  • Stay home. If you really don’t have to go out, don’t. Even if you can drive well in the snow, not everyone else can. Don’t tempt fate: If you don’t have somewhere you have to be, watch the snow from indoors.

ICC Compliance Center cares about our employees and customers. Stay safe this winter season.

Shipping a Gift? Ask Yourself, is it Dangerous Goods?

This weekend, my husband and I decided it was time to do some clean up and sell some things on e-Bay. We did the usual photo and description, and posted a few odd items. When we came to the last item, a PS3 controller, my husband stopped and said, “I am going to have to ship this as dangerous goods.”

It got me thinking, how many people would know that? I wonder how many lithium batteries are mailed or shipped by average people, never thinking that they are doing something wrong and potentially very dangerous. Even scarier, is the thought that my family could be on that same plane.

As the holiday season approaches, people everywhere will be sending gifts to loved ones around the world. What many people still do not realize, is that innocent gifts like game controllers, lap-top computers, cell phones, and tablets are dangerous goods.

The definition of “dangerous goods” varies slightly from regulation to regulation, but basics means  articles or materials capable of posing significant risk to people, health, property, or the environment  when transported. Examples include: perfumes, paints, aerosol cans, and anything with a lithium battery including power tools, computers, and cameras.

Dangerous goods need to be packaged and labeled in accordance with the regulations. You also need to be a trained person to ship them.

Before you wrap that gift, contact the post office or the shipping company and ask them if it is considered dangerous goods. If it is, the best solution might be to seek a local packaging and crating company to assist. ICC Compliance Center has a list of “Repackers” around the USA and Canada that can be found here: http://www.thecompliancecenter.com/partners/.

Since not everyone is privileged enough to be in the dangerous goods industry, as dangerous goods professionals, we need to do our part in to educate and protect others, so all families can have a safe holiday season. Help me educate others by sharing this on your social media pages.