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 Continue Reading…

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 Continue Reading…

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 Continue Reading…

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 Continue Reading…

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 Continue Reading…

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 Continue Reading…

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 Continue Reading…
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 Continue Reading…