Welcome to the ever-changing world of transporting lithium batteries. It feels like just yesterday we were discussing the introduction of the new Class 9 hazard label dedicated to just batteries and the new handling “mark”. Would you believe that started at the end of 2016? In an attempt to clarify things, here is the first of several blogs dedicated to one of the new versions of a transport regulation. The focus will be what changed in regards to lithium batteries for that mode. My first choice, only because it is my favorite regulation, is the 60th edition of the International Air Transport Association or IATA as many of us know it. By the way, ICC will be hosting a training on lithium batteries on January 24th and 25th. Call us today to get registered today.
Listed below are the specific sections, paragraphs, packing instructions and the like that had changes for lithium cells and batteries. If you aren’t overly familiar with shipping batteries, what is below can be a bit overwhelming. You can access our “cheat sheet” for required labels by ground, ocean, and air.
60th Edition Changes for Batteries:
New classification criteria – As part of 220.127.116.11.1 there are 2 new paragraphs around the classification of lithium batteries. One paragraph talks about “hybrid” batteries, which are those that contain both ion and metal while the other is about Continue Reading…
The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a final rule on October 18th. As you know, the only way to amend or change Title 49 for Transportation in the Code of Federal Regulations is through a rule making process. This particular docket number is HM–259. Its goal is to “align the U.S. Hazardous Materials Regulations with current international standards for the air transportation of hazardous materials”. It has an effective date of October 18, 2018. While the published rule is 23 pages long, I have attempted to hit the highlights here. If you wish to read the entire final rule with the discussion on comments received, you can go to https://www.phmsa.dot.gov/regulations-fr/rulemaking/2018-22114.
Highlights of HM-259
172.101 – Removal of A3 and A6 from Column 7 for multiple entries in the HMT. Provision A3 will be removed from all Packing Group I entries. Provision A6 will be removed from all liquid entries to which it is assigned.
172.102 – A3 revised and now reads as follows: “For combination packagings, if glass inner packagings (including ampoules) are used, they must be packed with absorbent material in tightly closed rigid and leakproof receptacles before packing in outer packagings.” There is no longer a mention of using “tightly closed metal receptacles”.
175.10(a)(18)(i) – Revised portable electronic devices by passengers and crew. This section has been expanded to include portable medical electronic devices with lithium metal Continue Reading…
It is the end of October. This is the signal for many exciting things. First, autumn is well under way; no more temperatures in the high 90’s. Second, pumpkin spice everything is available. My personal favorite though is plain old pumpkin pie. Finally, OSHA publishes their list of top ten most-cited standards for the previous fiscal year. This is always announced at the National Safety Council’s Congress and Expo. The timing fits with OSHA’s fiscal year that runs from October 1 through September 30. So, without further delay….
Most-Cited OSHA Standards for Fiscal Year 2018
Fall Protection – General Requirements: Standard 1926.501 with 7,720 violations
Hazard Communications: Standard 1910.1200 with 4,552 violations
Scaffolds/Scaffolding: Standard 1926.451 with 3,336 violations
Respiratory Protection: Standard 1910.134 with 3,118 violations
Lockout/Tagout: Standard 1910.147 with 2,944 violations
Ladders: Standard 1926.1053 with 2,812 violations
Powered Industrial Trucks: Standard 1910.178 with 2,294 violations
Fall Protection: Training requirements: Standard 1926.503 with 1,982 violations
Machine Guarding: Standard 1910.212 with 1,972 violations
Personal Protective Equipment and Lifesaving Equipment – Eye and Face Protection: Standard 1926.102 with 1,536 violations
Here are some things I notice about this year’s list. First of all, the top five are the exact same ones and in the exact same order as last year, and all the way back to fiscal year 2014. The next four on the list are the same as well. The only difference is the order of them going back through Continue Reading…
Chemical data and information are an integral part of my work. Data is needed for a shipper of hazardous materials or dangerous goods. It is needed for an author of Safety Data Sheets (SDS). It may also be needed for OSHA workplace labeling. Sometimes you need several websites or resources open all at once to gather the needed data.
As such, OSHA has created a tool that you may find helpful. It is called the “OSHA Occupational Chemical Database”. The link for it is https://www.osha.gov/chemicaldata/. It is a compilation of data from several agencies and organizations put into one online resource. The first paragraph on the site calls this “OSHA’s premier one-stop shop for occupational chemical information”. For chemicals found on the website, there is information on some or all of the following topics:
Exposure limits – OSHA, NIOSH, ACGIH
Additional Resources and Literature References
The site is searchable mainly by chemical name, CAS number or alphabetically. There is even a feature that will allow you to search for chemicals under certain topics. The site allows you to group chemicals by Permissible Exposure Limits (PEL), Carcinogenic classification and Immediately Dangerous to Life and Health hazards (IDLH). That aside, once you have found your chemical, this site provides a variety of information. Simply click on the link listed Continue Reading…
The National Fire Protection Association (NFPA) has designated the week of October 7th-13th as Fire Prevention Week. This date was chosen as the Great Chicago fire started on October 8, 1871. Each year a theme for the week is chosen in an effort to keep fire safety present in people’s minds. This year’s theme is “Look. Listen. Learn. Be aware – fire can happen anywhere.”
Those 3 words are simplistic but necessary when it comes to fire prevention, preparedness and risk. It carries over from the home, to the workplace and more. Look is for people to look around their home, office and workplace. Listen is mainly focused on the sound of smoke or fire alarms. Learn is about knowing multiple ways out of a room. Here are some further thoughts on each word for you to consider.
Look for places fire could start:
Electrical and lighting equipment
Listen for the sound of the smoke alarm:
Take them seriously
Know where are they located in the home, office and workplace
Test them monthly
Replace any over 10 years old
Learn two ways out of every room:
Have an escape plan in the home, office and workplace
Set a meeting place
Know the path from each exit to the outside
Keep the areas near the exit points easily accessible
At this time of year all the regulatory updates start. Every time a notation comes across my desk or email I can’t help but think about a famous line in the movie “Sixteen Candles”. That particular line is “What’s happening hot stuff?” Click here to see the actual movie clip. One of these days, I want a presentation to start with this. It would sure break the ice on some rather detailed subject matter.
Having prepared you for thinking about what’s happening or changing, we have to start at the UN level specifically. Much of this information comes from a presentation by Duane Pfund at the Pipeline and Hazardous Materials Safety Administration. We need to focus on is what changed from the 2015 – 2016 biennium. That biennium gave us Revision 20 of the UN Model Recommendations for the Transport of Dangerous Goods. Revision 20 is what will drive the changes starting in January 2019.
What’s Happening or Changing for 2019?
Class 8 Corrosive Materials:
A new alternative method for classifying these mixtures is being introduced. It revolves around using the GHS Purple Book bridging principles and calculation methods. Note that flammable gases and explosives are on the list for this same concept in the current biennium.
Sometimes I feel behind in the regulatory world. It is just a fact that regulations often change faster than one has time to process. A good case for this is California’s Proposition 65. Not only are there multiple changes for how to represent substances that are on the list, but the list itself changed in May 2018. For more information on “how to represent” and the August 30, 2018 changeover date, take a look at ICC’s blog found here
To refresh your memory, the Safe Drinking Water and Toxic Enforcement Act of 1986 is the official name for California’s Prop 65. The list has to be revised and republished at least once per year. California’s Office of Environmental Health Hazard Assessment (OEHHA) is the agency responsible for Prop 65 implementation. They consider adding chemicals to the list when some other “authoritative body” makes a determination regarding a substance’s ability to cause cancer, birth defects or other reproductive harm. Shown below are all of the new substances that were added and or removed by month. They are listed by name, type of toxicity and Chemical Abstracts Service Registry Number (CAS).
Now would be a good time to see not only if you are up to date on the new required “warnings” but if any of your products or substances were added to the new list.
ICC Compliance Center constantly evaluates our courses to be sure they are the most up-to-date with current versions of the regulations. Our Regulatory Team works hard to make sure the information we get you is complete and correct. In that regard, I am in the process of revising and updating our course on shipping reduced amounts of materials. It will focus on the options outlined in the US 49 CFR and the IATA regulation. We are talking about a focused course on the topics of small quantities, excepted quantities, limited quantities and consumer commodities.
During the course of the update, I came across an odd word in regards to drums under the Excepted Quantities exception. It was one not familiar to me at all even after 10 years of being in the “business.” Of course, my first thought was to look in the definitions or glossary section of the regulations. It wasn’t there. Then I tried to Google it. No luck. At this point, it was time to reach out to the Team. Sure enough, within minutes there was the answer and even where I could find it for future reference.
What was the word? It was the word “chime.” In both 49 CFR and IATA for Excepted Quantities is the package test requirement that must be met for drums. It says that when the package is in the shape of Continue Reading…
It is always a great time when a bunch of safety professionals get together to chat. This happened this past weekend when several of us in the field ended up on someone’s back patio. There were five of us discussing what we see at various facilities. A topic that was recurrent throughout was Personal Protective Equipment (PPE) particularly eye protection. This got me to thinking about how ICC can help get the word out about this. Oddly enough, August is National Eye Exam Month. Let’s put these two together and see what happens.
Back in 1989, Sears Optical created National Eye Exam Month. Many ophthalmologists and optometrists take this time to focus on eye safety. Just for general knowledge, an ophthalmologist is someone who specializes in medical and surgical eye disease, whereas an optometrist is a medical doctor who specialist in eye and vision care. Most of us spend at least 40 hours at work a week with many doing more. A large number of us work at computers, outside or even near chemicals. This puts stress on our eyes. Depending on your age, an eye exam could be useful even if you have no symptoms. The American Optometric Association provides some basic guidelines around when to get an exam.
Airplanes are a great way to reach far away locations. This wouldn’t be possible without Wilbur and Orville Wright’s first powered flight in Kitty Hawk, North Carolina in 1903. To honor this great accomplishment President Franklin Roosevelt declared August 19th as National Aviation Day in the United States. Many use this day to honor other pioneers in aviation and space exploration. It also happens to be Orville Wright’s birthday.
National Aviation Day can be celebrated in any number of ways. Schools dedicate lessons to air travel. Discussions focused on the Wright brothers, Amelia Earhart or Charles Lindbergh and their accomplishments is another. People interested can explore the history of the National Aeronautics and Space Administration (NASA) which started as the National Advisory Committee for Aeronautics (NACA). Visits to museums that have dedicated exhibits to aviation and aeronautics are another possibility. Build a model airplane. If you are stuck in an office, make a paper airplane and fly it around the office during your next break or lunch.