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Shipping by Air? Don’t Overlook the Latest IATA Addendum

As we start our new year, one of our resolutions should be to make sure our dangerous goods shipments get where they’re going. Which means, of course, that we need to update to the 2020 edition of the Dangerous Goods Regulations (DGR) from the International Air Transport Association (IATA). But don’t rely on that completely, because as always, there will be a few corrections and additions that IATA needed to make after the book has gone to print.

In December, IATA published an addendum to the DGR which is available as a free download. These will take effect as of January 1, 2020, so they’re in effect now. The majority of the corrections and additions have to do with State and Operator variations (country variations and airline policies that apply in addition to the DGR), although some affect more general areas. To find the addendum, go to the bottom of their webpage at https://www.iata.org/en/publications/dgr/#tab-2, from where you can download the file as a .pdf in various languages.

First, let’s look at some of the significant changes that are not specific to countries or airlines.

  • In section 2.3.2.3, on shipping wheelchairs and mobility aids with spillable batteries, paragraph (c)(2) includes a corrected cross-reference.
  • A significant change has been made to several packing instructions for Class 3 liquids when shipped Cargo aircraft only. In the original versions of Packing Instructions 360 to Continue Reading…
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2020 Vision or Still Blurry for Lithium Battery Shippers?

The title says it all, can you see clearly when you ship lithium batteries, or are the waters still a little murky? If it is the former rather than the latter for you, that may change as Amazon has announced new global FBA requirements for all lithium batteries and products which contain lithium batteries. A Lithium Battery Test Summary will now need to be uploaded to Amazon, starting this past 1st of January 2020. This new rule will affect those who sell a variety of products, from watches to smartphones to toys. This type of change is not only exclusive to Amazon, as IATA and IMDG Code will now also be enforcing a new regulation that requires the test summary for the lithium battery/cells to be made available throughout the entire distribution network. 

What is the Test?

Lithium cells and batteries that are manufactured after June 30, 2003, and equipment powered by those cells and batteries have to be tested in accordance with the UN Manual of Test and Criteria Part III, Section 38.3. If the testing passes, the test facility provides a summary certificate to the manufacturer that confirms that the cells or batteries meet an international standard and can be shipped around the world in accordance with the appropriate regulations. The test standard includes eight tests total: Altitude Simulation; Thermal Test; Vibration; Shock; External Short Circuit; Continue Reading…

Complacency of Own Safety During Air Travel

As a former member of the Canadian Armed forces, I have always tried my best to keep keenly aware of any possible hazards/dangers that could affect me, my family, or others. I have never been one to stand by idly and say nothing or do nothing. I have noticed a trend developing lately in air travelers where it seems the majority are seemly unaware or oblivious of safety regulations and the reasons why some rules even exist.

I remember as a teenager embarking on my first flight in the mid-1980s being very attentive to all demonstrations; looking at every exit; observing every rule. It was easily noted that every traveler was watching the hand gestures of the flight attendant, knowing where our life jackets were, and again knowing the location of the nearest exit. But, as air travel safety has improved it seems complacency has increased. I have noticed hardly anyone listens to the flight safety briefing anymore as they are more preoccupied with taking their shoes off and looking at their phones.

Here are a couple of rules that exist and why:

NO lithium batteries in checked baggage
It is imperative to not check any lithium batteries in your luggage. If a lithium battery in your electronic device fails, thermal runaway occurs. The heat at which it will burn will melt aluminum which is what aircrafts are made of. Continue Reading…

ICC’s 2020 Regulatory Resolutions

Here it is – January 2020.  The time when all holiday decorations are put away and people make resolutions for the coming year.  Things we would like to change about ourselves, our workplace or our home.  We’ve all heard them.  I’m going to work out more.  There will be more family time.  We will eat healthier.  I’ll be kinder to my co-workers.  That one is mine in case you were wondering. 

Now at this point you are asking how does resolution making have anything to do with transportation of dangerous goods?  Well, I asked our Regulatory Team what their “regulatory resolutions” would be.  In other words, if they had the power, what changes or resolutions would they make to a regulation.  Oddly enough, with their responses, not a single regulation escaped a “resolution”!  Some of the items listed below were mentioned on more than one person’s list.

49 CFR:

  • Resolve to get rid of the combustible liquids.No one else in the world regulates these.
  • All lithium batteries should be transported as fully regulated with UN Specification Packaging and paperwork.No more exceptions. 
  • Resolve to adjust the packaging recertification requirements.Align them more with Canada’s.  As long as the components and specifications do not change there should be no need to re-test UN packaging every 2 years.  49 CFR should allow packaging manufacturer’s to simply send in an application for certification every 5 Continue Reading…
There’s a Handbook for That!!

Did you ever say to yourself; I wish there was a handbook for that? Handbooks are designed to provide a convenient reference or instruction about a particular subject. Handbooks come in many forms which can make life easier for employees, students, and new vehicle owners. But in some cases, handbooks provide guidance to more serious subjects other than just learning how to set the channel lineup on your car stereo for example. With that being said, if your business generates hazardous waste, I have the perfect handbook for you that has been prepared by the U.S. Environmental Protection Agency (EPA). It was designed to help small-business owners and operators understand how best to comply with federal hazardous waste management regulations.

What is it? 

This handbook provides a general overview of the federal hazardous waste management regulations and will give you a basic understanding of your responsibilities when generating and managing hazardous waste for small businesses. On a side-note, this handbook should not be used as a substitute for the actual requirements, but it does provide an outline and can act as a guide to assist you in understanding the regulations. The setup of the handbook is relatively easy to follow, as words or phrases that appear in bold red text throughout the guide are defined in an “Abbreviations and Definitions” section located on the last page. In addition, Continue Reading…

OSHA HazCom 2012
HazCom2012 Revision is Coming

It just doesn’t seem possible that the new OSHA standard, known as HazCom2012, has been in full swing for over 4 years now.  Of course, the time taken to get everything in place regarding it is still fresh in many people’s memories. I can still remember choosing to work on Memorial Day weekend to help some customers meet the June 1, 2015 deadline.  Just as a reminder, that transition was to Revision 3 of the Globally Harmonized System of Classification and Labeling of Chemicals (UNSCEGHS) or Purple Book and the direct section of the Code of Federal Regulations (CFR) that was updated is Title 29 1910.1200.  Given that the UN just released Revision 8, the US is a bit behind some other parts of the world.

Don’t worry though, OSHA is already in the process of preparing another update to the standard.  However, this will take time given the process involved with updating the CFR.  The process was supposed to start in the Fall of 2014 with a Notice of Proposed Rulemaking (NPRM) for an update to Revision 7 of the Purple Book.  That didn’t happen and the date moved to Spring of 2018.  Again, the process stalled.  OSHA is now looking to publish the NPRM this month – December 2019. 

This notice of proposed rulemaking, whenever it is published, is supposed to update the OSHA standard to Continue Reading…

OSHA
OSHA Workplace Safety During the Holidays

There are numerous holidays in the months of November and December.  Just a quick look at Wikipedia confirmed at least 47 holidays for Christian, Secular, Hindi and Buddhist celebrations.  Each has its own traditions, decorations and food.  Given that large number, OSHA has some advice to keep workplaces safe during this time of year.  Don’t think this doesn’t apply to you and quit reading.  Think about the increase risks for personnel in warehouses and offices, on transportation teams, retail workers, etc.  E-Commerce is at an all time high which adds another layer to this busy season.

In the most recent Quick Takes Newsletter, there is a link to multiple resources which can be used for worker safety.  The link to reach those resources is https://www.osha.gov/holidaysafety.html.  I browsed through a few of the topics and here are just a few of the highlights.

  • Warehouse Safety Pocket Guide.  There are 10 OSHA standards that could apply to workers in a warehouse.  The standards include hazard communication, electrical safety, personal protective equipment (PPE) and forklifts.  There are also the hazards associated with loading docks, conveyors and charging stations to consider.  This guide provides a nice overview of the possible hazards and solutions for workers in the warehouse.
  • Safety Practices Once Tractor Trailer Drivers Arrive at a Destination.  While just a short 1-page resource, the information is a nice reminder not only for Continue Reading…
What is an Overpack?

Every few days one of our customers will call our Regulatory Helpline with questions about overpacks. Given the complexity of them, it is time to set the record straight. The focus for this blog will be the IATA Dangerous Goods Regulations as they seem to give a clearer picture, in my opinion, than those of 49CFR for US ground, IMDG for international vessel, and TDG Canadian ground regulations.

To start, let’s look at a few definitions. These are found in IATA’s Appendix A. Some of these may seem silly on the surface, but they are needed to drive the point home about overpacks. These definitions will all pertain to non-radioactive shipments.

  • Packaging: One or more receptacles and any other components or materials necessary for the receptacles to perform their containment and other safety functions and to ensure compliance with the minimum packing requirements of these Regulations. 
  • Package: The complete product of the packing operation consisting of the packaging and contents prepared for transport
  • Overpack: An enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage. Dangerous goods packages contained in the overpack must be properly packed, marked, labelled and in proper condition as required by these Regulations. Note: Shrink-wrap or banding may be considered an overpack. 

What is all of that in reality? Packagings are the pieces and parts that Continue Reading…

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…
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Training … the necessary evil of TDG – Part 3

Hello everyone. I’m back with the subject of TDG training. In my last blog, we made it clear who has responsibility for a list of the most important elements. We used the sections of the Canadian TDG Regulations for each part stating the implications of the various stakeholders.

Now, in order to fully understand what TDG requires as training, we will discuss what is the normal duration for a TDG training that would provide you with adequate skills and especially training applicable to your responsibilities.

It should be noted that the primary purpose of Part 6 of the TDG (article 6.2) is to ensure that the person has a solid knowledge of all of the topics listed in paragraphs (a) to (m) that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport.

It is important to clarify here that Transport Canada does not define clearly or exactly what training should contain. TDG leaves much room for the interpretation of what constitutes appropriate training, and it remains the responsibility of the company to establish this.

For this reason, we will be discussing a training standard in the industry and it is equally important to believe that if a training facility declares that it is certified by the government or any other departmental entity that this is completely false. Continue Reading…