TDG Methanol Classification
Big Change in Methanol Transport Classification (TDG)

TDG Update - Man Staring in to warehouse

New Transport Canada Update Means Big Changes for Many Companies

Recently, Transport Canada posted on their FAQ web page, a few questions regarding shipping mixtures of Methanol.

The first three FAQs are for the most part, not surprising, with one exception in Question 2. These FAQ’s appear as follows (these FAQ’s are directly from their website): (keep reading, the biggest surprise is coming).

Question: How do I classify a product that contains methanol as the only dangerous good?
Answer: As per Section 2.3 of the TDG Regulations, when the name of a dangerous good is shown in Schedule 1, that name and the corresponding data for that shipping name (class, subsidiary class(es), packing group (PG)) must be used. Therefore, when methanol is the only dangerous good in the product and it meets the criteria for Class 3, Flammable Liquids, it should be transported as UN1230, METHANOL, Class 3 (6.1), PG II. Note that PG II is the only packing group available for methanol as per Schedule 1 of the TDG Regulations. Note: Subparagraph 1.3(2)(d)(iv) of the TDG Regulations allows a person to indicate the word “SOLUTION” or “MIXTURE” and also the concentration of the solution or mixture after the shipping name, as applicable.
Question: Tests results for a solution containing methanol as the only dangerous good indicate that its packing group should be III. How do I choose the proper shipping name?
Answer: Even if a dilution would lead to a Continue Reading…
Regulatory Helpdesk: March 12

Combustible Liquids, Using Chemtrec’s Number, Keeping Up-To-Date, and Other Paperwork

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

DG Documentation on Overpacks

Q. If there are multiple skids of dangerous goods (overpacks) in a shipment on which one should the copies of the invoices and shipping papers be attached?
A. Neither the DOT nor IATA regulations tell you to put “paperwork” on the outer packages or overpacks. That is a carrier/driver thing. All the regulations care about is the proper marking and labeling that they require. You also have to be able to physically hand your paperwork to the carrier. Your best bet would be to talk to your carrier directly as to how they want it handled.

Combustible Liquids

Q. I have a liquid with a flashpoint of 100° F and it does not meet any other hazard classes. It is not an RQ, waste or marine pollutant. After manufacturing, it is placed in tubes and then shipped for sale in retail stores. What marks and labels are needed on the outside of the packages?
A. The flashpoint of this material is 100° F and there are no other hazards under the transport regulations. This means it technically meets the definition of a flammable liquid in Packing Group III per §173.120 Continue Reading…
Regulatory Helpdesk: March 5

Batteries, Batteries, and more Lithium Batteries

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Why do I need an SDS for a Laptop Battery?

Q. We are shipping used laptops with batteries in the units from the US to HK via air. There are multiple manufacturers and models, are (M)SDS sheets required for each model? Our forwarder is requesting them in order to provide pricing.
A. To answer your question, it would depend on why the forwarder is requesting them. They may be asking for them to meet the written emergency response requirements. However, they could be asking for them for classification purposes to prove which part of the packing instructions these meet.

The SDS could tell them the watt-hour rating which would then drive which part of the instruction to use. Forwarders and carriers have a lot of leeway. I can only speak to what the regulations say. There is nothing in 49 CFR or IATA that indicates you must use an SDS. Most people tend to default to them because they meet so many parts of the regulations in one place.

Manufacturer’s Packaging (Lithium Battery)

Q. Should I remove the manufacturer’s packaging from lithium ion batteries being shipped by air under PI 965 Continue Reading…
2016 Emergency Response Guidebook (PDF Download Available)

2016 ERG Accidents

The 2016 ERG is Valid Until 2020

The Emergency Response Guidebook published by the US Department of Transportation, developed jointly with Transport Canada and the Secretariat of Transport and Communications is used by firefighters, police, and other emergency response personnel who may be the first to arrive on the scene of a transportation incident regarding dangerous goods/hazardous materials.

The primary purpose of the Guide is to provide immediate information regarding the chemical, therefore allowing them to take appropriate action to protect themselves and the general public.

Changes and Updates You Should Know About:

Free ERG 2016 Download

  • The 2016 edition includes changes such as:
    • Expanded/Revised sections on:
    • Shipping documents
    • How to use this guidebook (flowchart)
    • Table of placards and markings
    • Rail car/road trailer identification charts
    • Pipeline transportation
    • Protective clothing
    • A glossary
    • ER telephone numbers
  • New Sections include:
    • Table of contents
    • Information on GHS (Globally Harmonized System of Classification and labeling of Chemicals)
    • Information about ERAP (Emergency Response Assistance Plans)
  • Also …
    • Updated to the 19th revised edition
    • Updated guides

Plus much more…

 

A physical copy of the ERG is required for most drivers and emergency responders.


Download the free ERG 2016 PDF

The PDF downloads of the 2016 Emergency Response Guidebook have been provided by PHMSA.

Regulatory Helpdesk: February 19 & 26

Shipments to Puerto Rico, Non-hazardous substances, the Overpack label, and Aviation Regulated Liquids or Solids

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Shipping to Puerto Rico

Q.  If 49 CFR is used to make a vessel shipment of limited quantities from the mainland US to Puerto Rico is a shipping paper required? I’m asking because limited quantities don’t require shipping papers.

A. Technically that is true. Shipping papers are not needed for US GROUND shipments. You have to read the fine print in paragraph 173.150(b) which is the section on limited quantities for flammable and combustible liquids. It that paragraph it says, ” … is not subject to the shipping paper requirements of subpart C of part 172 of this subchapter, unless the material meets the definition of a hazardous substance, hazardous waste, marine pollutant, or is offered for transportation and transported by aircraft or vessel, and is eligible for the exceptions provided in §173.156 of this part“.

Non-hazardous substances under WHMIS 2015

Q.Customer called and asked if SDS’s were required for non-hazardous substances and where to find this in the WHMIS 2015 Regulations?

A.The answer to your question can be found below in WHMIS 2015, which states that safety data sheets only pertain to a hazardous product, therefore Continue Reading…

Regulatory Helpdesk: February 12

Lithium Batteries, Placards, and SDS in the Workplace

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Lithium Batteries (Air)

Q. For PI 967 in IATA is the weight limit the weight of the equipment and battery inside of it or just the battery.
A. For all battery packing instructions in IATA it is always the weight of the battery itself.

Lithium Batteries (IMDG)

Q. Do “excepted” batteries require segregation from limited quantity packages under IMDG?
A. Under IMDG §3.4.4.2 it tells you that segregation requirements in Chapters 7.2 – 7.7 plus any information on Stowage in column 16b of the table do not apply to goods in limited quantity packages. Lithium ion batteries do not yet need segregation under IMDG either. It is only IATA that has implemented segregation this year as part of the packing instructions for shippers. IATA has also added batteries to the segregation table for operators, but it isn’t mandatory until next year and only applies to those in Section 1A and 1B not Section II.

Placards (TDG)

Q. Customer asked if his Class 8 material (UN 1830) needed to have a UN number on the placard if shipping 1 liter per package and 7 per tote for a total of 17 Liters for the shipment in Canada. Continue Reading…
Regulatory Helpdesk: February 5

Labels, Placards, Segregation, Documentation, SDSs & Emergency Response

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Here are the top 6 questions from last week.

SDS and Workplace Labels

Q. If I have a product like a concentrated cleaner which is corrosive to the eyes and skin that I water down at my facility, do I need a new SDS and workplace labeling?
A. You have 2 options. You can use the SDS as provided to create your workplace labeling. This may cause concern with your workers. However, it would be better for you to develop your own and re-evaluate the product using the hazards presented in the watered-down version. It is possible, depending on how diluted it is, to move into the irritation or non-hazardous range.

Listing Canutec or Chemtrec on Lithium Battery Marks

Q. Regarding the new battery mark, am I allowed to add “in case of emergency, contact Chemtrec”?
A. The regulations are pretty clear (DOT §173.185(c)(3) and IATA 7.1.5.5). What should be listed there is a phone number for “additional information”. There should be no extra phrasing other than phone number itself. As for listing Chemtrec, Infotrac or even Canutec, those are 3rd party Emergency Response Providers and would not be appropriate to include in that section of Continue Reading…
Regulatory Helpdesk: January 29

WHMIS Labels Format, How ICAO and IATA are Related, Shipping Residues, and IATA Documentation

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

WHMIS Labels Format

Q. Is there a specified format for WHMIS 2015 workplace labels?
A. No. The information is specified but not the format. Pictograms may assist employees in quickly identifying the hazards/precautions; and may simplify employer creation of substitute “supplier” labels.

This is especially true when employees have been trained in the GHS-based WHMIS 2015 system. Employers must ensure training has been provided if GHS pictograms are used on workplace labels during the transition period.

ICAO/IATA Relationship

Q. Is a risk of non-compliance in using IATA DGR given that government regulations specify compliance with ICAO Technical instructions?
A. IATA DGR states in §1.14 that they contain all of the ICAO TI requirements and add additional restrictions. Thus, complying with IATA DGR will ensure compliance with ICAO TI. As with all regulations, it is important to keep aware of amendments/corrigenda between publication dates.

Shipping Residues (TDG)

Q. When we are shipping residues…. Can we and how do we indicate ‘Residue last contained’ on the transport document.
A. If the quantity of dangerous goods in a means of containment is less than 10 per cent of the Continue Reading…
Regulatory Helpdesk: January 22, 2018

Shipping Alkaline Batteries, IBC Pressure Gauges, and SDS Expiry Under WHMIS 2015

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Shipping Spent Alkaline Batteries (49 CFR)

Q. Can spent alkaline batteries (Duracell) be shipped to a recycling facility by ground without being declared dangerous goods?
A. Assuming that these are dry alkaline batteries that are used or spent for recycling, they are not required to be shipped as dangerous goods by ground in the USA per 172.102 Provision 130 (d) provided they are rated under 9 volts per below.

Ground Transport (US DOT): 49 CFR 172.102 SPECIAL PROVISION 130

Used or spent battery exception. Used or spent dry batteries of both non-rechargeable and rechargeable designs, with a marked rating up to 9-volt that are combined in the same package and transported by highway or rail for recycling, reconditioning, or disposal are not subject to this special provision or any other requirement of the HMR.

Pressure Gauge Requirements for IBCs

Q. What are the pressure gauge testing requirements for 31A IBCs?
A. I referred the customer to 178.814 d (1) (2) which lists 2 consecutive tests that must be administered with a rating of 65kPa first followed by 200kPa.

Can You Use Capital Letters (TDG)?

Q. Do Continue Reading…
Regulatory Helpdesk: January 15, 2018

Here are the top 4 questions last week:

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Worded Label Requirements

Q. Are worded labels required for use in US transport?
A. Based on 172.405(a), except where prescribed, wording is optional on US hazard class labels.

Placement of UN Number, Shipping Name and Hazard Class Label

Q. Can you put the “ISH” information (shipping name, UN number and hazard label) on the top of a package (e.g. box)?
A. That depends. Different regulations express it differently, but the key message is that the information must be easily located and read; and with few exceptions in proximity to each other on the same surface of the package. All common regulations (49 CFR, Canadian TDGR, IATA DGR, IMDG Code) have a general requirement for legibility.

49 CFR requires the information to be clearly visible on a surface other than the bottom [172.304(f) and 172.304(a)(i)]- so the top could be allowed if the configuration resulted in it being clearly visible.

IATA DGR and the IMDG Code do not specify top/bottom but only require the information to be “readily visible” [IATA 7.2.6.1(a); IMDG 5.2.1.2.1, 5.2.2,1.6].

TDGR, however, is a little more prescriptive- requiring the information to be “on any side … other than the side on Continue Reading…