ICC Top 10 List
2019 Top Ten OSHA Violations

Top Ten lists are often the topic of very enjoyable discussions. Whether its movies, music, sports teams, or restaurants. However some top ten lists aren’t based on entertainment value and taste, some are based on more serious topics. As the year comes to a close, the National Safety Council and the Occupational Safety and Health Administration announced the preliminary Top 10 most frequently cited workplace safety violations for the 2019 fiscal year.

Once again, Fall Protection – General Requirements is OSHA’s most frequently cited standard in the most cited violations of 2019. This makes nine years in a row that Fall Protections has topped this list. Although there is some good news with that as the number of citations for fall protection was 7,720 last year and dropped down to 6,010 for the 2019 fiscal year. The rest of the preliminary list of OSHA’s Top 10 violations for the fiscal year 2019 also remained mostly the same from last year, with only one minor change. Lockout/Tagout, which was ranked No. 5 in 2018, is now No. 4, switching places with Respiratory Protection. Below is the 2019 most cited violations per OSHA.

  1. Fall Protection – General Requirements (1926.501): 6,010 violations
  2. Hazard Communication (1910.1200): 3,671
  3. Scaffolding (1926.451): 2,813
  4. Lockout/Tagout (1910.147): 2,606
  5. Respiratory Protection (1910.134): 2,450
  6. Ladders (1926.1053): 2,345
  7. Powered Industrial Trucks (1910.178): 2,093
  8. Fall Protection – Training Requirements (1926.503): 1,773
  9. Machine Guarding (1910.212): 1,743
  10. Personal Protective and Lifesaving Equipment – Eye Continue Reading…
PHMSA Notice of Proposed Rulemaking

In the vast world called the dangerous goods community, it can sometimes feel like we are specks in the universe, simply just faces in the crowd.  The regulations exist, and we follow them. However in certain cases like in the latest NPRM, we do have a voice.   What is a NPRM you may ask? It stands for a notice of proposed rulemaking, which derives directly from requests from within the dangerous goods regulatory community to address a variety of provisions within the regulations.  That’s right, we can make a difference!   The purpose of this is to help clarify, improve, and provide relief from the various regulatory requirements when shipping dangerous goods. As a result of the requests, PHMSA addressed a wide variety of provisions including those addressing packaging, hazardous communication, and incorporation by reference documents. Some of the proposed amendments include revising the basis weight tolerance provided in § 178.521 from ±5% to ±10% from the nominal basis weight reported in the initial design qualification test report for paper shipping sacks, incorporating by reference updated versions of multiple Compressed Gas Association (CGA) publications, and removing the words “manufactured before September 1, 1995” from § 180.417(a) (3) to allow for an alternative report for cargo tanks manufactured after September 1, 1985. 

Per PHMSA, these revisions proposed therein are intended to reduce regulatory burdens while maintaining, or enhancing, the existing level of safety. In this NPRM, Continue Reading…

USPS Allowing Reduced Size for Excepted Quantity & Limited Quantity Marking

From time to time the Universe aligns and changes in the dangerous goods shipping regulations actually make our lives a bit easier.  That is the case now that The United States Postal Service (USPS) has published new options for hazardous materials markings in their June 20th Postal Bulletin. USPS is now piloting the use of smaller Excepted Quantity and Limited Quantity marks incorporated into or applied adjacent to the address label which allows a minimum size of no less than 50 millimeters (1.97 inches) in height and width.   For use of the smaller marks, you must first request authorization through the USPS Product Classification Group. Additionally The DOT has recently issued a special permit to allow a Limited Quantity mark of a minimum of 50 millimeters on each side when placed adjacent to the package tracking label. The Postal Service temporary authorizations are expected to align with DOT’s special permit process.

                Limited Quantity Mark                                Excepted Quantity Mark

If you are interested you should request authorization through the USPS Product Classification group at the address below:

Manager, Product Classification
475 L’Enfant Plaza SW Rm 4446
Washington DC 20260

The request for authorization should include:

  • A description of the general products you are shipping;
  • Your company name and address;
  • The requestor contact information (name, email, phone, etc.); and
  • A picture of the proposed marking (size) on the postage label/address side of the package

This change can Continue Reading…

PHMSA Announces Public Meeting to Solicit Input for 2020 Emergency Response Guidebook

On May 7, 2019, the Pipeline and Hazardous Materials Safety Administration announced there will be a public meeting scheduled for June 17, 2019 to solicit input on the development of the 2020 edition of the Emergency Response Guidebook (ERG). During the June 17 meeting, PHMSA will discuss different ways to determine the appropriate response protective distances for poisonous vapors resulting from spills involving dangerous goods considered toxic by inhalation in the “green pages” of the 2016 ERG. PHMSA will also discuss new methodologies and considerations for future editions of the ERG and outcomes of field experiments including ongoing research to better understand environmental effects on airborne toxic gas concentrations and other updates that will be published in the 2020 ERG. The 2020 ERG will be published in English, French, and Spanish and will increase public safety by improving emergency response procedures for hazardous material incidents across North America. For more information on how to be a part of the public meeting visit the link below:

https://www.federalregister.gov/documents/2019/05/07/2019-09299/hazardous-materials-public-meeting-notice-for-the-2020-emergency-response-guidebook-erg2020

PHMSA first published the ERG Guidebook in 1973 for use by emergency services personnel to provide guidance for first responders during the critical first 30 minutes of hazardous materials transportation incidents. Since 1980, PHMSA’s goal has been to provide free access of the ERG to all public emergency response personnel including fire-fighters, police, and rescue squads. PHMSA has distributed more than 14.5 Continue Reading…

Transport Canada Launches Video: Responding to Rail-Car Incidents Involving Flammable Liquids

When a train carrying flammable liquids is involved in an incident, first responders are often the first on scene. These types of incidents are not typical for first responders. They require a unique approach. And for that reason, Transport Canada has put out a video on how to respond to rail-car incidents that involve flammable liquids. Below are the factors and steps from the video when dealing with these types of incidents.

Situation:

A Rail Car is involved in an accident and a fire starts on impact.  The rail car is properly placarded with the appropriate class 3 flammable Placard. Below are the factors that can influence the fire as well as steps and tools to utilize during the incident. 

Factors:

Whether it’s Gasoline, Diesel, Ethanol, Crude oil, or bitumen, knowing the properties of each is important to first responders because all can behave differently under spill and fire conditions.  This is where the importance of proper placarding will come into play as first responders can detect exactly what type of flammable substances are on the train based on the UN number.   Below are important factors of flammable substances that would help first responders determine the proper course of action:

Viscosity- Gives an indication on how fast the fire can spread.

Density- Will determine if substance will sink or float if it is near a body of water.

Flashpoint- Tells how easily the Continue Reading…

USPS Regulations and Updates
New USPS Mailing Standards for Mailpieces Containing Liquids and How ICC Can Help

The US Postal Service is taking a positive step to improve the safety of liquid packaging shipments. This step is significant, as the industry will begin to incorporate some components of UN 4GV combination packaging requirements among a wide variety of changes soon to be implemented. Here at ICC, we help you understand what these changes are and provide the solutions that ensure you meet these new stringent requirements.

Why Change?

The Postal Service has observed that a significant percentage of liquid spills results from mailers misinterpreting the existing packaging requirements for liquids, thinking their non-metal containers are not breakable. However, non-metal containers (i.e., plastic, glass, earthenware, etc.) are often the source of liquid spills in Postal Service networks. As a result, on July 9th of 2018, the US Postal Service proposed a new rulemaking on standards for mail pieces containing liquids. There was a comment period requesting public feedback on the proposed rules until September 18, 2018.

The proposed rule addressed two components:

  1. Clarification of existing language that specified packaging and markings for mail pieces that contain liquids in containers greater than 4 fluid ounces; and
  2. Extending the triple-packaging requirement for breakable primary containers with 4 ounces or less.

What are the Changes and the Compliance Solutions?

Effective on March 28, 2019, the adopted changes published in the final rule include:

railroad crossing
PHMSA UPDATE: New Safety Rule to Strengthen Oil Train Spill Response Preparedness

Much like Sheryl Crow sang, “A change, could do you good”, at least one would hope. When it comes to PHMSA, change is aimed at improving an already existing process, or adding a new process we can all benefit from. So in this case, I believe Sheryl Crow is right.

With that being said, The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA), recently issued a final rule that requires railroads to create and submit Comprehensive Oil Spill Response Plans for route segments traveled by High Hazard Flammable Trains also called HHFTs. The rule applies to these trains that are transporting petroleum oil in a block of 20 or more loaded tank cars and trains that have a total of 35 loaded petroleum oil tank cars.

Why the Change?

Incidents involving crude oil can have devastating consequences to local communities and the environment. Countering these effects on the environment can take between a few weeks to many years, depending on the damage caused. For this reason, fast and effective response is essential to rail accidents containing oil. The 174-page final rule is designed to improve the response readiness and decrease the effects of rail accidents and incidents involving petroleum oil and a flammable train. The agency said the rule also is needed due to expansion in U.S. energy production having led to “significant challenges for the Continue Reading…

Don’t Turn Your Vacation into an Embarrassing Headline

Sometimes no matter how many precautions you take, there is no way to stop the inevitable. Football players with helmets designed to protect their brains still get concussions. You cross every “t” and dot every “i” on your federal income tax return and you still get audited. And sometimes even if you follow all of the safety tips for lithium ion batteries in my previous blog, they still can explode. http://blog.thecompliancecenter.com/safety-tips-for-lithium-ion-batteries/

However, by not taking the proper preventative measures in all of the cases listed above, the chances of a negative outcome can be greatly increased. With the travel season looking to pick-up in the coming months and many of us looking to hop on a plane and head out to our idea of paradise, I think it is safe to say that none of us want to end up in a situation like the story below.

What Happened?

Just like any other domestic flight, passengers on a Delta flight in New York City were stowing their carry on items in the overhead storage bins and preparing for take-off for a scheduled departure to Houston, Texas. Suddenly, passengers started to smell something burning, similar to the smell of a camp-fire. It was at that point that passengers started to see smoke in the cabin and begin panicking. The panic was caused by a vape pen that started smoldering Continue Reading…

Single Packaging
BX-24DU Change Notice

Dear Valued Customer,

In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to BX-24DU (PK-MT-124).

  1. The clear tape required for closure of this packaging has changed from 2 strips of 3M #305 48mm wide clear tape to 1 strip of 3M #375 48mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.

If you have any questions or concerns, please contact our customer relations center in the US at 888-442-9628 or in Canada at 888-977-4834.

Thank you,

Michael S. Zendano

Packaging Specialist

Government Shutdown- How Does This Affect PHMSA??

With another government shutdown possibly looming again in the United States in mid-February, many are wondering how this affects the hazardous materials world, specifically those looking to ship domestically or shipments that are entering the U.S.  Whether or not you agree or disagree with the shutdown, I think it is safe to say we can all agree on the importance of the continuing enforcement of the hazardous materials regulations. So the million dollar question here is, will the government shutdown have an effect on PHMSA? The short answer here, for the time being, is yes, but not in all cases. While activities like program developments, research, and HMR permits have generally been suspended, enforcement of the regulations and investigations have continued. Below is a list of continuing operations and suspended activities while this government shutdown continues to take place.

Summary of Continuing Operations

• Investigations of pipeline accidents to determine the causes and circumstances of failure, the need for corrective action, and any non-compliance that might have contributed to the accident.

• Inspections of pipeline operators and systems to detect and remediate safety concerns and determine compliance with the pipeline safety regulations.

• Enforcement of the pipeline safety regulations through corrective action orders, notices of probable violations, letters of warning and other authorized enforcement activities.

• Investigations of hazardous materials accidents to determine the causes and circumstances of failure, the need Continue Reading…