IHU 2019 Proposed Amendment: Pre-Gazette I Consultation
In late March, Transport Canada posted a notice on their public website regarding a pre-Gazette I consultation on proposed amendments to the TDGR. The consultation was distributed to selected stakeholders by email on March 4.
This proposal is the latest in a series of international harmonization updates (“IHU”) to incorporate changes to reflect the current editions of the UN Model Regulations (UN Recommendations), ICAO Technical Instructions for air, and the IMDG Code for ocean shipment. In addition, the Canada-US Regulatory Cooperation Council work planning effort has suggested several items that would facilitate reciprocity in shipping dangerous goods between the two countries.
Updating to 20th edition and preparation for 21st edition.
Incorporate packaging updates by adopting 3rd edition TP14850 (pending repatriation to CGSB as standard CGSB-43.150-xx), normalize EC-allowed practices on batteries; allow UN3175 in FIBC 13H3 & 13H4.
Marking/Labeling: text on labels, banana labels on cylinders, require orientation arrows for liquids, marine pollutant, and Lithium Battery Mark on overpacks.
Language issues under review, include determining the options on the use of either or both English/French and circumstances when a different second language might appear (i.e. foreign sourced material).
Consider adding provisions for optional hazard class text on placards – see also marking/labeling.
Allow US placards for re-shipping road/rail within Canada. In addition to text issues, this would allow re-shipping with US Continue Reading…
The main part of my job is to train companies, workers, handlers, and the like on how to manage hazardous materials or hazardous chemicals safely. This can be done under the umbrella of the transport regulations of 49CFR, IATA, and IMDG, or under the OSHA HazCom standard. However, not everyone is going to take one of my courses. Sad, but true.
Granted all of those folks do their jobs well and use marks, labels, placards, and safety data sheets to convey information about their products to other users. But it begs the question, how is the general public made aware of the “other” dangers or poisons out there? Think about the laundry pod scare recently to make my point.
Back in 1962, the first-ever National Poison Prevention Week was announced. In 2019, the week will be from March 17-23. Supported directly by the American Association of Poison Control Centers (AAPCC), the goal is to promote safety tips and the emergency services provided by the Poison Control Centers in the US.
To emphasize just how important Poison Control Centers are, take a look at some numbers from 2016 taken directly from the AAPCC website at www.aapcc.org.
There were 2,700,000 cases managed by the centers.
Someone called the centers every 14 minutes.
Over $1,800,000,000 saved in medicals costs.
For this year’s event, people are encouraged to use the hashtags #NPPW19, #PreventPoison, and #PoisonHelp. Continue Reading…
One of the most frustrating issues with shipping dangerous goods is finding a carrier that will transport the goods. When a client contacts us for repackaging services, besides the DG information, I always ask if they have arranged a carrier to transport their goods. Most of the time it’s a “no”. Then I get started with what their options are; ground or air.
For shipments going from Canada to the US, believe it or not, it is easier to ship by air than ground. Of course, it does depend on the quantity being shipped and whether the DG is allowed for air transport. It is definitely more cost-effective to send anything via ground than air; however, that is not always true especially for small DG shipments. I have been told that sending a small, e.g., 20 lbs, DG package by air will cost about the same as sending it via ground.
Carriers such as FedEx and Purolator do not haul DG packages from Canada to the US via ground service. They do offer air but not ground. UPS which offers both air and ground does transport certain dangerous goods (just check for limitations on the UN# being shipped on UPS’s website under “UPS Dangerous Goods Acceptance Tool” prior to shipping) from Canada to the US but you must have a DG account set up with them.
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.
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…
At the start of each new year lots of things are said about changes to make in order for the next year to be better. Many make resolutions about losing weight or getting healthy. Others decide to be nicer to people, spend more time with family or volunteer. It doesn’t mean the previous year was bad, but things can always get better. Let’s look at this from a regulatory compliance point of view, and see if things will be better in 2019.
Changes to Regulations:
Starting January 1, 2019 there is a new version of the IATA Dangerous Goods Regulations. You must now be using the 60th edition. Luckily, IATA does a great job of giving advanced notice about what is changing late in 2018 so people can start to prepare before the new version takes effect. You can see the list of “significant” changes here. The IMDG Code was also updated for 2019. The new version is the 39-18 Amendment. You are allowed to use the 39-18 starting in January 2019, but the older 38-16 version is still viable for the rest of this year. Again, a summary of the changes for that regulation was published as well. You can find them here. The US ground regulations of 49 CFR had a few amendments throughout 2018, and there is a large one looming for 2019. To stay up-to-date Continue Reading…
Have you ever been in a situation where you understand “it” clearly, but the person you are explaining “it” to just does not get it? Frustrating, eh! Well I recently had this fun experience.
We did a repackaging job for one of our clients a couple of weeks ago. He was shipping a switch, which had a very small amount of mercury inside it. He told us maybe 0.5 kg of mercury – if that – and this shipment needs to go via air transport. Since he isn’t certified for air transport, he needed our services.
We classified the switch as UN3506, Mercury contained in manufactured articles. We packaged the shipment according to packing instruction 869, and as per special provision A191 since the article contained less than 5 kg of mercury. We did not add the subsidiary hazard label (class 6.1), and included “A191” in the authorization column of the shipper’s declaration.
We sent out the package. This was on Friday.
On Monday we got the package back. If there is something to note about me it is that I don’t take rejected packages lightly. It hits close to heart that I made a mistake. Took a look at the checklist, and it was rejected because the carrier’s DG Agent took the weight on the shipper’s declaration as the net weight of the mercury inside the package, and claimed Continue Reading…
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 18.104.22.168.1 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…
In keeping with the standard practice of alerting users to modifications in the new edition of the Dangerous Goods Regulations (DGR) for air transport, the list of Significant Changes and Amendments to the 60th Edition (2019) were released several months ago, and are incorporated into the recently published copies of the DGR.
Typically changes in the State and Operator Variations, in s. 2.8, are not outlined in specific detail in the Significant Changes document, but are referenced as a general reminder. This contrasts with amendments issued between publications which illustrate the actual details of changes.
Which leads us to FX-02…
FX-02 DROPS “V” RATED PACKAGING
A rather significant operator variation in s. 2.8.4 of the IATA DGR was the common application of FX-02 (f) to liquids in specified classes. This limitation, which existed as FX-17 prior to the 57th Ed., required shippers to use the heavy duty UN-standard “V-Pack” (“variation” commonly noted by UN code 4GV) package even though it wasn’t mandated by the Packing Instruction (PI) or other provisions of the DGR.
The limitation was invoked when FedEx customers were choosing to ship under the “International Economy” or “International Freight Economy” designations. Not only was it required in place of PI-required UN standardized Continue Reading…
Almost always the authorization column in the shipper’s declaration is left blank, but when you need to add something in there, you must add it in there. Section 22.214.171.124.4 of the IATA Regulations provides when and what to add when required. Now sometimes we forget to read the “notes” in the Regulations.
Here’s my story
A customer called in first thing Monday morning to get help on shipping an engine. It was an urgent shipment, and he had to get it out ASAP. I said, “No problem. We can help.” It’s what we do. It was going via air, and since it was a domestic shipment he can drop the shipment off to the airline directly for it to leave later that day.
Packaging for an engine
Engines vary in size, clearly. I asked our customer if his engine was packaged, and he said no, but it was strapped on a wooden pallet with 2×4 lumber on corners of the pallet for support. So, I asked him to email me a picture to understand what he meant by that. The picture showed the engine was visible, and the corners with the lumber in upright position did not affect the identification of the engine. I told our customer that all he needed was the shipper’s declaration. We created the declaration, he picked up the colored copies from our office and dropped Continue Reading…