Regulatory Helpdesk: October 9, 2017

Top 4 Questions From the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

#4. Why is My Product X when it should be Y? (USA)

Q. Why is my product listed as a Flammable Liquid Category 4, when the product is combustible?

A. Under OSHA Hazcom 2012, a product that has a flashpoint >140°F and <199.4°F is considered a Flammable Liquid Category 4.

This is illustrated in the table below:

Table B.6.1: Criteria for flammable liquids

Table B.6.1: Criteria for flammable liquids
Category Criteria
1 Flash point < 23°C (73.4°F) and initial boiling point ≤ 35°C (95°F)
2 Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F)
3 Flash point ≥ 23°C (73.4°F) and ≤ 60°C (140°F)
4 Flash point > 60°C (140°F) and ≤ 93°C (199.4°F)

Once you have the classification, then you can apply the label phrases. The Flammable Liquid Category 4 hazard statement is Combustible Liquid. This is outlined in the table below.

C.4.19 Flammable Liquids (Continued)
(Classified in Accordance with Appendix B.6)
Hazard Category Signal Word Hazard Statement
4 Warning Combustible Liquid

 


#3. Does my Class 6 placard need to show Class 6.1? (International)

Q. I have a customer who is saying that Continue Reading…

Regulatory Helpdesk: October 2, 2017

Top 4 Questions From the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

#4. Shipping Sodium (UN1428) by Air (USA)

Q. The Customer asked if Sodium (UN1428) can be shipped by air using a plastic bag as an inner container inside of a 4GV box.

A. Per the 49 CFR 172.102 Special Provision A20, Plastic Bags are not allowed to be used as inner receptacles in combination packaging by aircraft.


#3. When to Use Bilingual Packaging (Canada)

Q. Does every word on [my] packaging need to be in French and English to sell in retail stores in Canada?

A. Canada has the federal Consumer Packaging and Labelling Act and the Consumer Packaging and Labelling Regulations. That Act and Regulation requires 2 mandatory items to be bilingual. Those items are the product identity, and the net quantity. The dealers name and place of business can be in either English or French according to those laws.

However, the guide specifically states: Subsection 6(2) of the Consumer Packaging and Labelling Regulations requires that “all” mandatory label information be shown in English and French Continue Reading…

Regulatory Helpdesk: September 30, 2017

Answers from the Helpdesk

ICC supports our valued customers with access to our complimentary Regulatory Helpdesk. To further assist clients, we will be sharing some of the highlights of those calls each week. If you have a question, contact one of our regulatory specialists today.

#2. Certifier’s Signature (Canada)

Q: Can the 49 CFR certification statement be used on Canadian TDG shipping documents for shipments between two points in Canada, having only a signature for the certifier’s name?

A: TDGR 3.6.1(1)(a) does not restrict the use of the 49 CFR statement to US bound/origin shipments. TDGR 3.6.1(2), in conjunction with Transport Canada (TC) Safety Awareness Guidance Bulletin RDIMS#11829346 (August 2017), does not require that the individual’s name be a signature; but if a signature is used it must be clearly legible, identifying the individual, to be compliant.


#1. Refrigeration Regulation (USA)

Q: We need to ship a refrigeration unit (UN2857) that contains a small amount of non-flammable, non-toxic gas. How is this regulated?

A: In general, REFRIGERATING MACHINES, UN2857 are regulated as Division 2.2 dangerous goods, with no packing group. However, small units can usually be shipped as exempted dangerous goods, with no significant requirements, if they contain no more than 12 kg of non-flammable, non-toxic gas as a coolant, Continue Reading…

Lithium
Lithium Battery Labels as of August 1, 2017

Lithium Batteries, Laptop battery

The A-Team and Lithium Battery Marks / Labels

An iconic show from the 1980’s was “The A-Team”. It was about a group of former military men who worked to help those in need by using their former skill set. A famous line from it was often said by John “Hannibal” Smith, played by George Peppard. At the end of many episodes he would say, “I love it when a plan comes together”. With the publication of Transport Canada’s Amendment TDGR SOR2017 – 137, we finally have a plan coming together for the transportation of Lithium Batteries.

Finally, all transport regulations – 49 CFR, TDG, IATA .and IMDG – are on the same page regarding the necessary marks and labels needed for transporting Lithium Batteries. All of the regulations even have the same transition times for when the new Class 9 Lithium Battery Hazard Class Label and new Lithium Battery Mark will be mandatory.

New lithium battery label     New Lithium Battery Mark and Pictogram

Download Our Lithium Battery Labels Guide

 

Let ICC Compliance Center be your “A-Team” for shipping Lithium Batteries. Call us today for packaging, training, labels and marks.  We have it all.

Shipping by Road
FMCSA Electronic Logging Device (ELD) Requirements

Red semi truck on highway

FMCSA Goes on Tour

The Eagles, a popular band for several decades, broke up back in the 1980s. A famous quote from one of the band’s members is that they would play as a band again “when Hell freezes over.” Interestingly enough in 1994 the band got back together and went on tour. Of course, the name of the tour was “Hell Freezes Over”. I mention this because the Federal Motor Carrier Safety Administration (FMCSA) is also about to go on tour.

The tour known as the “ELD Implementation National Tour” is a way for FMCSA staff members and experts to present, discuss, and help with the new Electronic Logging Devices or ELDs. An ELD is a device designed to sync with an engine to record driving times. This recording will make for easier and better tracking of a driver’s hours of service (HOS). These ELDs will replace the paper logbooks that certain drivers are required to maintain. To access the Federal Register for the full Final Rule, click here.

The ELD Final Rule was published in December of 2016 and has a 3-phase implementation. Each phase has its own time frame, objective(s), and device requirements.

ELD Rule implementation phases:

Frequently Asked Questions
FAQ: What is a Special Permit?

Truck Driving on highway at sunset

If you ever navigate our packaging section on our website, you will notice a section for U.S. Special Permit Kits.

You may ask yourself, what is a special permit and how does it apply to packaging? Well, basically special permits allow a shipper to perform a function that is not currently authorized by the regulations, or not perform a function currently required under the PHMSA regulations. Below are answers to questions regarding special permits.

Q. Why would someone need a special permit?

A. Special permits can provide relief from specific regulations when shipping dangerous goods. For example, it can allow a shipper to transport their dangerous goods in a specific UN-rated package without having to use hazard labels, as long as they adhere to the required provisions stated within the Special Permit.

Q. How do you apply for a special permit?

A. An application has to be completed and submitted to the US DOT along with specific documentation including written descriptions, drawings, flow charts, plans and other supporting documents.

Q. Do special permits expire?

A. Yes. Special permits expire after a period of time and the manufacturer must re-apply with the Department of Transportation.

Q. Does the Department of Transportation reject applications for a special permit?

A. The application must Continue Reading…

Hydrostatic Pressure and Shipping Liquids by Air

Pressure at High Altitudes

As the video above shows, you never know how the pressure change on an airplane will affect our sealed containers. From exploding shaving cream cans in checked luggage, to scattered potato chips at our feet on the floor of an airplane, the unpredictability of a high altitude can certainly cause its share of messes. Aside from having to do laundry while on your vacation, these examples are relatively mild. In the world of shipping dangerous goods, the consequences can be far more severe. For this reason when shipping hazardous liquids by air, our single and inner packaging must pass a hydrostatic pressure test that essentially ensures the pressure differential at high altitudes will not cause a disaster mid-air. You may ask, what is hydrostatic pressure and how is it measured?

What is Hydrostatic Pressure?

Hydrostatic pressure is the pressure exerted by a fluid at equilibrium at a given point within the fluid, due to the force of gravity. For the purpose of shipping dangerous goods, this is measured in kPa or Kilopascal.  When you see a UN Marking on a single package it usually looks something like this 1H1/Y1.8/100. The “100” is referencing the maximum hydrostatic pressure this Continue Reading…

PHMSA
49 CFR – There’s an App for that?

oCFR Regulation Smartphone app

We’ve Come a Long Way

Technology is everywhere we look now. Think about some of the advertisements on television you see for what is available today in the realm of technology. There is the refrigerator that sends you pictures of its insides and keeps your grocery list. A device that can regulate your thermostat, turn on your lights, and send you reminders about events. Cell phones can now stream videos, search the internet, pay your bills, and still make calls. All of these are just in the past year.

Think back about ten years ago. It doesn’t seem that long ago, now does it? It is around this time that the iPhone craze was starting. In 2008 the iPhone 3G was released. As the second generation of iPhone, it came preloaded with such features as a GPS, special email capabilities, and the App Store. App stands for Application. It is from the App Store that people could download various tools, games, and software. Around this time, Apple began to advertise with the slogan, “There’s an App for that”.  You can watch one of the original commercials here.

So, why all the history? Because there is a new app available from the U.S. Department of Transportation’s (DOT) Continue Reading…

Single Packaging
Latin, Vince Lombardi, & Packaging Selection

Man preparing shipment

Practice Makes Perfect

Most of us have heard the phrase, “Practice makes perfect”. I did when learning my multiplication tables. Others hear it in reference to playing sports. What is interesting is the phrase originates from the 1500’s. In Latin, it is ‘Uses promptos facit‘ which translates to ‘use makes mastery’. Vince Lombardi, American football player and coach, said it differently. For him, “Practice does not make perfect. Only perfect practice makes perfect” was the correct way to say it. The intent is the same. The only way to get batter at something is to practice it.

So how does that relate to making the correct packaging selection for shipments of hazardous materials? A shipper should practice using the regulation and the UN Specification Markings together before making any decisions on packaging. When working with clients in transportation training sessions I always remind participants that packaging is two-fold. You have to use what the regulations say and what the marking on your packaging allows. Let’s do a practice problem to show what I mean.

Steel Drum MT0M502

Practice Problems:

Problem #1:

Can a shipper put 16 Liters of UN1114 Benzene into a steel drum with a non-removable head for a US Ground shipment using 49 CFR? Benzene has a specific gravity of 0.876 Continue Reading…

World Hepatitis Day Logo
World Hepatitis Day

Eliminate Hepatitis Banner

Are your Signs Accurate?

Since 2010, World Hepatitis Day is observed on July 28th. The goal is to raise awareness of hepatitis as well as the prevention and treatment of the disease. According to the World Health Organization (WHO), an estimated 1.34 million people died globally from this disease in 2015. In comparison, numbers that high match those caused by tuberculosis, malaria, and HIV/AIDS. According to the World Hepatitis Day website, “Currently, 90% of people living with hepatitis B and 80% living with hepatitis C are not aware of their status.” We all need to be educated. This is not a disease found in just one country or in one particular ethnicity. Here is the chance to educate ourselves. Check out the website dedicated to the even this year at http://www.worldhepatitisday.org/en/about-us

Hepatitis is the inflammation of liver tissue. It is most commonly caused by a virus and there are five main ones commonly referred to as Types A, B, C, D and E. Types A and E are usually short-term (acute) diseases. Types B, C, and D are likely to become chronic. Note that Type E is very dangerous for pregnant women.

Listed below are some key facts about each type of Hepatitis taken from the Continue Reading…