IATA
IATA Expresses Concerns over Laptop Ban

Laptop on wood table

Rethinking the Laptop Ban

Back in March, The United States Government implemented a ban on carry on electronic devices on certain airlines from the Middle East and Africa to the U.S. due to security fears of a potential bomb threat. However, IATA recently called for the government to re-think this current policy as it has opened up an array of financial concerns for the affected airlines.

Financial Concerns

Since the ban on laptops in carry-on baggage was initiated in March, airlines are finding implementation of the ban has been a financial burden. In addition, governments did not consult with IATA, which gave airlines little time to implement the ban. As passengers are now forced to check their laptop computers, the affected airlines had to increase the training of the current staff as well deploy extra staff due to the increased handling of cargo hold baggage. In addition, the affected airlines fear that companies will cancel trips rather than risk losing confidential information in checked laptops, causing a potential decrease in business customers.

It is estimated that the ban affects more than 18,000 daily passengers, in particular Gulf carriers and airports have noted a drop in passenger traffic between their hubs and the United States. There is certainly a risk of affected airlines losing frustrated passengers to other carriers not affected by the ban. From a systematic point of view, the ban has caused slower moving security lines at the airports due to more thorough baggage screening measures, triggering a surge in departure delays. In the ban’s current scope, IATA has estimated that the ban could cost $180 million in lost productivity, which could increase to $1.2 billion if the ban is eventually expanded to Europe-US flights.

Airport security, laptop ban

Alternatives to Banning Devices

IATA is recommending various alternatives to potentially replace the current ban. These recommendations include the use of explosive trace detection at primary and secondary security checkpoints, visual inspection of electronic devices for signs of any alterations, questioning passengers about the purpose and origin of the device, the possibility of turning on the device to help determine its functionality, the deployment of “behavioral detection” officers and canines, recognition of trusted traveler programs and the identification of high or low-risk passengers, and increased training for screeners to detect potential threats from electronic devices and laptops.

It is unknown whether or not IATA’s recommendations will ever come to fruition. In the meantime, we will have to wait and see how long this ban will be in affect and how much it will cost the carriers in the long run.

Sources

http://www.ainonline.com/aviation-news/air-transport/2017-05-17/iata-urges-restraint-possible-new-electronics-ban

https://www.businesstraveller.com/news/2017/06/07/iata-appeals-alternatives-laptop-ban/

http://www.news.com.au/world/breaking-news/us-mulls-banning-more-electronics-in-air/news-story/58f268e2ee31224979f67853efead8dc

https://www.ainonline.com/aviation-news/air-transport/2017-06-08/unanswered-questions-over-electronics-ban-irk-iata

Air – TDG Part 12 Pre-Amendment Consultation

Ground and air transport

Time Flies

Transport Canada, in what has become a series of proposed amendments, has issued a consultation White Paper on updates to the Transportation of Dangerous Goods (TDG) Regulations (TDGR) Part 12 Air.

This part references the International Civil Aviation Organization (ICAO) Technical Instructions (TI) along with TDG-specific supplemental requirements and exemptions. Some ICAO references date back to 2002 and changes to the TI have made some TDG provisions redundant or in need of updating. Also, there are some clarifications proposed to better align with the Canadian Aviation Regulations under the Aeronautics Act.

In the interest of clarification, Transport Canada hopes to increase the “one window” approach, wherein material is incorporated into the Part 12 TDGR rather than simply referencing an external document. This self-contained approach will still have to consider that changes to external documents might make references a more practical approach in some areas. The objective is also to harmonize this proposal with the “dynamic” (aka “ambulatory”) approach taken with the TDG International Harmonization Amendment.

Related Posts

TP14850 Update Consultation – May 2017 Draft
The Clock is Ticking – 3 Recent TDG Proposals
TDG Update: Proposed Harmonization/

Geography Counts – Limited Access Exemptions

A potential improvement to Part 12 includes adding a definition of “Limited Access”. The proposed definition reads:

“a location to or from which the transport of dangerous goods by means other than by aircraft is not reasonably possible, for at least three (3) consecutive months per year.”

The journey would not be restricted to a specific time of year. However, a journey from a non-limited access location, to a second non-limited access location, ending at a third limited access location, can only apply a Limited Access exemption provision between the second and third destination. The first to second flight must comply (an example is given in the White Paper, with further clarification in Annex B “Details…” to the White Paper).

Another clarification in the proposal is to reinforce the carrier’s “consignor” responsibilities when accepting shipments under Limited Access exemption.

Changes – Additions – Deletions

No section of the current TDG Part 12 is untouched by this proposal. In addition to clarifying Limited Access criteria and other modifications, new provisions are proposed for: “animal repellants” (e.g. bear spray), UN3012 “signal cartridges” (e.g. “bear bangers”), DG required to provide emergency services or aerial fire suppression, DG for operation of an aircraft, or DG transported by peace officer in the exercise of duties.

Some provisions considered redundant, or excessively exempted, under current IATA TI that may be removed include the current sections: 12.6 (toxic and infectious substances), 12.8 (Packing Instruction Y963), 12.9(12) (sodium chlorite and hypochlorite solutions), 12.11 (geological core samples), 12.13 (measuring instruments). Some existing “Equivalency Certificates” will be withdrawn as a result of changes formalizing the exemption in the proposed amendment.

Interested parties have until August 8, 2017 to provide input to this pre-Gazette I proposal. The Gazette I notice is expected to be published by early 2018.

Annex B to the White Paper provides a fairly readable map to the changes. The link below introduces the proposal, and contains further links to the White Paper, Annexes, background documents and feedback options:

http://www.letstalktransportation.ca/part12air

TDG
Transport Canada Publishes Enforcement Action Summaries

Truck Driving on highway at sunset

A New Awareness Vehicle

Transport Canada has added a new item to the various informative offerings on the TDG home page. A link was added to an “Enforcement Action Summaries” listing to supplement existing guidance pages on topic-specific publications, orders, equivalency certificates, safety awareness material, etc.

This new page is intended to give the regulated community a better understanding of the types of offences that could subject them to penalties or orders to take corrective action. The objective is to provide an incentive to “deter wrongdoing” by demonstrating consequences to those who might choose to ignore the regulations; or, on a more positive note, provide an illustration of the advantages of understanding the regulations before an enforcement situation is encountered.

“I Fought the Law …” – or Ignorance is (Usually) No Excuse

Sections 22(3) and 40 of the TDG Act do provide for a defense of having taken “all reasonable measures” to comply with the Act. “Reasonable measures” would normally include acquiring and maintaining knowledge of the applicable regulations.

Although current enforcement activities are unlikely to result in the incarceration experienced by the misguided soul in Bobby Fuller’s 1966 classic hit, the TDG Act does provide for a range of consequences.

These consequences are represented in the published summaries under the following categories:

  1. Detention (of goods) notices
  2. Direction to remedy (non-compliances)
  3. Direction to “not import” or return DG to the point of origin
  4. Revocation of certificates
  5. Tickets (fines)
  6. Convictions (“guilty in court”)

Initial Offering

The current summary covers 24 enforcement actions from the period December 2014 to April 13, 2017, with the intent to update the list monthly. The list has basic sorting features and, when actions are directed at corporations under consequences d)-f) above, disclose names of the offender. Individuals (non-corporate offenders) are not named.

Of the 24 listings: 11 resulted in detention notices, 6 had tickets (ranging from $575 to $900), 5 were directions to remedy deficiencies and 2 were under stop import/return directions.

4 of the listings disclosed the names of corporations and only was the result of a ticket- i.e. presumably 5 of the tickets were issued to individuals.

The majority of the offences were related to TDGR Part 5 (“means of containment) violations (14), with 6 of these pertaining specifications and general requirements for highway tanks under CSA B-621. Documentation deficiencies were cited in 2 ($615 and $900) of the tickets issued.

Avoiding running afoul of regulations is avoided by obtaining knowledge of the content of the regulations with awareness of how they relate to a company’s or individual’s activities. Maintaining compliance also requires keeping abreast of changes that have a potential effect on the activities.

To consult the enforcement summary page at Transport Canada’s website, click on the link below:

http://www.tc.gc.ca/eng/tdg/enforcement-actions-summaries.html

If you have any questions regarding the Transport Canada Enforcement Action Summaries, please contact ICC Compliance Center, Inc. at 1.888.442.9628 (USA) or 1.888.977.4834 (Canada).

WHMIS 2015
WHMIS 2015 Delayed Implications

Young female Industrial Worker

The Cat Came Back – WHMIS 1988 Lives!

More Than Just a Date

As reported in Karrie Monette-Ishmael’s May 19 Blog, an order-in-council resulted in an extension to the Supplier deadlines for compliance with the GHS-based Hazardous Products Act/Regulation (WHMIS 2015). Canada Gazette II (CGII), published on May 31, provided some insight into the delay in the supplementary Regulatory Impact Analysis Statement (RIAS) associated with the extension.

RIAS

The transition extension itself (from June 1, 2017 to June 1, 2018 for manufacturers/importers; and from June 1, 2018 to September 1, 2018 for distributors) was cut and dried. However, the details in the RIAS are a reminder that despite the harmonization focus, there are still some unresolved issues in implementing the new hazard communication system.

CBI

Confidential business information (CBI) in the context of WHMIS has always focussed on masking the disclosure of ingredients on the M(SDS). Officially, Canadian suppliers were expected to rely on the somewhat costly and administratively burdensome Hazardous Materials Information Review Act (HMIRA) process to obtain exemptions from disclosing CBI. Practically the provisions in the Controlled Products Regulations (CPR or WHMIS 1988) were used by most suppliers as a simpler alternate to protect CBI.

Although this was the practise almost from the start of WHMIS 1988, it appears to be news to the current organisation- to wit, in the “Background” section of the RIAS: “Health Canada officials have learned that . . . some companies protected their CBI…by disclosing…ranges rather than using the . . . HMIRA.” I recall the discussions in the early days of WHMIS 1988 and, although unfortunately I don’t have copies, some documented acceptance of the practise as an alternate to the HMIRA as long as it wasn’t abused.

The stated main purpose of the extension is to allow Health Canada some time to prepare a palatable alternative to the WHMIS 1988 concentration ranges – which some in the regulated community have dubbed “CBI Light”. “CBI Light” presumably could allow for ranges, albeit narrower than in WHMIS 1988, and restrict their use for higher hazard “CMRs” (carcinogens, mutagens, reproductive toxins and sensitizers of the respiratory tract) as discussed in the “Consultation” section of the RIAS.

“WHMIS 2017”?

The RIAS includes the thought that some other stakeholder issues could be considered as part of the review. Chief among these is Labour’s desire to bring excluded products (e.g. consumer products and manufactured articles) under the WHMIS umbrella. Given the heavy discussions (again the writer attended some of these in the early 2000’s as an active member of regulated industry) that took place to introduce WHMIS 2015 (the original goal was for 2003!) – I suspect the issues around incorporating the Hazardous Products Act s. 12 exclusions may not come to fruition during the CBI discussions.

Suppliers Beware!

A significant number of suppliers have progressed far enough along the WHMIS 2015 trail that the transition will not have a serious impact on their transition. However, those who have not completely transitioned need to keep in mind that the CGII notice did not change the transition philosophy that prevents “mixing and matching” between WHMIS 1988 and WHMIS 2015 requirements. i.e. Labels and SDS must correspond- as must labels and MSDS. Classification differences could also be problematic if warnings on “GHS” labels were not reflected in WHMIS 1988 MSDS. Similarly, the “expiry” dates on MSDS would still apply to supplies under the older system. Prolonging the transition potentially prolongs the opportunity for non-compliance.

The transition extension does presumably provide for some relief on direct shipments where the Canadian supplier could still take advantage of the exemption, in the CPR s.23, to have (with written agreement) the customer label the material on receipt.

Employers Ditto (Sigh …)

The RIAS “Consultation” section indicates that some employer stakeholders were concerned that extending the transition for suppliers would, in effect, decrease the implementation window for workplaces. This interpretation indicates a false sense of complacency in the “employer” community’s need to establish training and procedures for WHMIS 2015.

As the Health Canada naming conveys, the GHS-based system has been “legal” for use since the CGII adoption in February 2015. Proactive companies, particularly those with significant US customers (US HazCom 2012 was, after all, mandatory in 2015), may already supply to WHMIS 2015 requirements.

The majority of Federal/Provincial/Territorial (FPT) jurisdictions have updated their workplace regulations. Despite the FPT transition provisions, the expectation is that employers will, at minimum, train employees in WHMIS 2015 sooner if products received are supplied under the new system.

Why Wait?

It would seem only prudent to undertake WHMIS 2015 training well before the “official” workplace implementation date. Items outlined as under review in the RIAS are unlikely to require significant changes to employee awareness requirements in understanding the new GHS-based classification, labelling and SDS aspects.

The May 31 CGII contains 2 separate notices: SOR/2017-92 for the new June 1, 2018 manufacturer/importer deadline; and SOR/2017-93 for the September 1, 2018 distributor deadline. The former contains the RIAS for both notices, found under the above SOR (referencing ‘Order Fixing . . . Economic Action Plan 2014″) at:

http://www.gazette.gc.ca/rp-pr/p2/2017/2017-05-31/html/index-eng.php

If you have any questions regarding WHMIS 2015 implementation, please contact ICC Compliance Center, Inc. at 1.888.442.9628 (USA) or 1.888.977.4834 (Canada).


WHMIS 2015 – June 2017 Deadline Extended

Safety
National Forklift Safety Day – June 13

Forklift

Forklift Safety

There’s an old joke out there about what happens when you play a country song backwards. According to the joke you get your girl, dog, and truck back. Rascal Flatts even did a song about it. It is a pretty good tune. Take a listen here.

So, how does a song about getting a truck back relate to forklifts and forklift safety? Well, by definition a forklift is a powered industrial truck. Since the joke and song talks about trucks you can see the connection. Forklifts are used to lift, move, and place various materials weighing anywhere from a few thousand pounds up to 90 tons. These powered industrial trucks must comply with OSHA standard 29CFR 1910.178. You can access a copy of the standard at this link.

National Forklift Safety Day

In 2016, accidents and incidents involving powered industrial trucks were listed in the top ten OSHA violations. To stress the safe use of the vehicles, need for operator training, education of non-users the Industrial Truck Association (ITA) has set aside Tuesday, June 13 as National Forklift Safety Day. This is the fourth year for such an event. Having a written standard, good safety policies and regulations surrounding the safe use of these machines isn’t enough. It requires every day awareness and commitment from drivers, managers, and other personnel in the areas with these trucks to stay safe.

If you are in the Washington, DC area check out the free activities ITA has planned.

  • Monday, June 12 from 3 to 5 p.m.: Education session for ITA members and invited quests
  • Tuesday, June 13 morning: Speakers from industry and government, including elected officials
  • Tuesday, June 13 afternoon: ITA members will visit their congressional representatives to convey our message about the critical importance of workplace safety and discuss how elected officials can help to support that

For information regarding your area, contact your local forklift dealer. 

A few ideas from other locations include the following:

  • Safety pledge signings
  • Open houses and plant tours
  • Safety demonstrations / Safety Awareness classes
  • “Train the Trainer” classes
  • Operator training sessions

If there is any way ICC Compliance Center can help make your National Forklift Safety Day a success, contact us. We are here to help.

Safety
OSHA Safe + Sound Week

Safe + Sound Week 2017

Safe + Sound Week is June 12 – 18

Back in the 14th century, sailing ships were a primary means of trading goods. To protect goods on these vessels they were insured against loss or damage.  The best news for the insurance companies was to receive word that the ship had returned “safe and sound”. The word “safe” was an indication of all crew members were accounted for without injury. The word “sound” told the company the ship had not suffered any serious damage. Since then we continue to use the phrase in our daily life.

The week of June 12-18 has been designated as the inaugural Nationwide Safe + Sound Week. The week is presented by Occupational Safety and Health Administration (OSHA), National Safety Council, American Industrial Hygiene Association (AIHA), American Society of Safety Engineers, the National Institute for Occupational Safety and Health just to name a few. The goal is to “raise awareness and understanding of the value of safety and health programs”. All businesses and companies are encouraged to participate.

The focus of the week is on three core elements. It covers management leadership, worker participation and find and fix hazards. Here is a brief overview of each taken from the OSHA website.

Core Elements:

  • Management leadership is a demonstrated commitment at the highest levels of an organization to safety and health. It means that business owners, executives, managers, and supervisors make safety and health a core organizational value, establish goals, provide resources, and set a good example. Because managers and workers take their cues from leadership, it’s important that all leaders throughout an organization show a visible commitment to safety and health.
  • Worker participation is meaningfully engaging workers at all levels in establishing, implementing, evaluating, and improving safety and health in the workplace. This means workers understand they are a valuable partner in making their workplace safer and are encouraged and able to communicate with management about hazards on the job. Workers are the experts when it comes to the tasks they do and the tools and equipment they use, which makes them a key resource for knowledge and innovative ideas that can improve safety and health.
  • Finding and fixing hazards is a proactive, ongoing process to identify and control sources of potential injuries or illnesses. This means establishing {systemic} procedures to collect and review information about known or potential hazards in the workplace, investigating the root cause of those hazards, and prioritizing hazard controls. Identifying and correcting these hazards before someone gets hurt ensures that workers go home to their families safe and sound after every shift.

Participate in Safe + Sound Week

To prepare your location to participate in the week it is a simple process.

  1. Step 1:  Select or plan activities under each of the elements shown above.
  2. Step 2:  Plan and promote your events
  3. Step 3:  Recognize participation. The website (here) under each element lists a few activities. You just have to click on each topic and decide.

Make the effort to make this week a success for your company. Good business involves keeping workers safe. Use this week to bring new life to your existing safety and health programs or get yours started. If there is anything ICC Compliance Center can do for you to help keep your workers safe, give us a call today.

Airplane Icon
FAA Short Audit Answers

Cargo loading on aircraft

Common Errors When Shipping by Air

At a recent training, the group hosting invited someone from the Federal Aviation Administration (FAA) to come and speak. Throughout the brief discussion, the speaker mentioned things she sees most often while doing site audits. Listed below are a few of the main items. See if you can guess what the officer sees during audits that is not accurate.

  1. Retention of Shipping Papers: In IATA, the retention of documentation is found in Section 8.0.2.2. According to this section the declaration of dangerous goods “must” be maintained for a minimum of 3 months. There are no state or operator variations attached to this section which may be why people get caught. In United States’ variation USG-01 it clearly tells shippers the document must be maintained by not less than 2 years.
    • Error Found: Only 3 months’ worth of documentation can be produced during an audit.
  2. Use of Technical Names: Entries in the blue pages listed with a star (*) symbol tells the shipper a technical name is needed.  Section 4.1.2.1(d) outlines how to determine the name, the number or names, and the type of names allowed. “The technical name must be a recognized chemical or biological name or other name currently used in scientific and technical handbooks, texts and journals. Trade names must not be used.
    • Error Found: The trade name or retail name is listed on the packages and shipping papers.
  3. Classification: The same 9 hazard classes are used in all transport regulations. The classification of materials into those hazard classes is also the same. However, there are some items that are country specific.
    • Error Found: The shipper tried to put an ORM-D package on an air shipment.
    • Error Found: A shipper packaged, marked and labeled a bulk package as Combustible under the DOT regulations and then attempted to send it via air where it is not regulated.
  4. Training Records: There is a very clear listing of what records of training should include. This information is in Section 1.5.5. It includes the employee’s name, the completion month, the name and address of the organization providing the training and some evidence that a test was completed satisfactorily.
    • Error Found: The certificate shown to the auditor had no indication of being tested.
    • Error Found: There was no address for the training organization.
  5. Emergency Response Phone Number: Another country specific requirement found in the state variations for the US is specifics for the emergency response telephone number. In USG-12 is the statement, “… the number must be monitored at all times… .”
    • Error Found: The emergency response number was disconnected and no longer in service.

These are just a few of the incidents noticed by the FAA inspector. The speaker mentioned her team does checks at all times of the day and night. This is not to “catch” you but to ensure hazardous materials/dangerous goods are being properly handled for transport. Interestingly enough, if your site completes a DOT Form 5800.1, a visit from the FAA is likely.

The point is, review your location and process. Just because you haven’t had a visit in a while or had a package refused doesn’t mean you are in the clear. ICC Compliance Centers offers a variety of auditing services. Contact us today to see how we can help you prepare for your next “visit” from the FAA.

Lithium
IATA Issues Guidance for “Smart Luggage”

luggage at an airport

The Problem with Smart Luggage

Some of you may remember the old credit card commercial that featured the epic journey of a self-propelled suitcase seeking its lost owner. Well, it turns out this wasn’t so entirely fantastic. There’s a new generation of “smart luggage” hitting the market that can tell airlines electronically who it belongs to and where it’s going, trail after you down airport hallways without a handle, and charge your cellphone if you can’t make it to one of those electrical outlets airports seem to hide on purpose. Some will even double as transport devices themselves, allowing travelers to zip around terminals on their own electric suitcase-scooters.

But these modern technologies come with a problem that’s often overlooked. The energy sources for all these seemingly-magical functions are usually lithium batteries. Lithium batteries are one of the main causes of fires related to dangerous goods on aircraft. So travelling with the newest piece of high tech luggage can bring headaches both for the traveller and the airline he or she flies on.

The International Air Transport Association (IATA) has for many years established rules for equipment containing lithium batteries carried by passengers or crew, but dangerous luggage is a new area. To help, they’ve published a guidance document that covers the dangers associated with such luggage, and instructions on how it can be carried safely.

The document lists various types of “smart luggage” that may include lithium batteries, including:

  • Lithium ion battery and motor allowing it to be used as a personal transportation device, either as a stand-up scooter, or sit on vehicle. These devices do not meet the criteria of a mobility device.
  • Lithium ion battery power bank that allows charging of other electronic devices such as mobile phones, tablets and laptops.
  • GPS tracking devices with or without GSM capability.
  • Bluetooth, RFID and Wi-Fi capability.
  • Electronic baggage tags.
  • Electronic locks.
  • Lithium ion battery, motor and tracking device (GPS) allowing the bag to self-propel and “follow” the owner.

Such items are classified by IATA as “portable electronic devices” (PEDs). While PEDs have been covered by the IATA Dangerous Goods Regulations section 2.3 when carried by passengers or crew, the new devices present some extra problems.

The Guidance Document covers topics such as:

  • When do PEDs require pre-approval by airlines?
  • What special requirements apply for devices such as luggage trackers, which must be kept active during transport?
  • Can powered luggage be carried as “lithium batteries contained in equipment”
  • How should airline staff handle lithium battery-powered luggage at the gate and during loading?
  • How should flight crew handle on-board fires involving PEDs?

Owners of PED luggage should be aware that travelling with them may be more difficult than, say, carrying a cellphone on an airplane. IATA has declared that, “no lithium battery contained in a bag may be considered as ‘installed in equipment.'” This means that the battery would not be permitted as checked baggage. Instead, you would have to remove the battery and take it a carry-on item. (Spare batteries and power banks are only permitted as carry-on luggage.)

IATA says:

Any PED equipped with a power bank offered as checked baggage must have the power bank removed prior to being checked-in. The power bank must then be carried in the passenger’s carry-on baggage where permitted by security regulations… Where a bag intended to be carried in the cabin is surrendered at the boarding gate or on the aircraft to be loaded in the cargo compartment the passenger should be asked if the bag contains any spare lithium batteries, including power banks. Where it is identified that there are spare lithium batteries or power banks, the passenger must remove them from the bag before it can be loaded into the cargo compartment. The spare battery / power bank must then be carried in the cabin, where permitted by security regulations.

Expect to see airlines start to promote awareness of the hazards of battery-powered luggage, and to inquire at check-in if your luggage contains lithium batteries.

Despite their inherent dangers, we can’t help but think self-powered luggage is has an undeniable “cool factor”. IATA has included links to several manufacturers in the guidance document as examples of equipment the airlines may expect to see over the next few years, and you might want to check them out. Is it time to reinvent the suitcase?

If you have questions about shipping lithium batteries or battery-powered equipment, call us here at ICC Compliance Center 1.888.977.4834 (Canada) or 1.888.442.9628 (USA).

WHMIS Logo
WHMIS 2015 – June 2017 Deadline Extended

Warehouse with chemicals

Extra, Extra Read All About It!

Health Canada has announced that the deadline for manufacturers and importers to comply with the HPR (a.k.a. WHMIS 2015) has been EXTENDED.

The deadline of June 1, 2017 has been delayed by one (1) year to June 1, 2018. The second deadline of June 1, 2018 has been delayed by three (3) months to September 1, 2018.

The orders and a regulatory impact analysis statement (RIAS) will be published in Canada Gazette Part II shortly. We will provide details as they become available. Stay tuned.

Finally, thank you to everyone that worked with Health Canada to make this extension a reality.

Check out our resources for complying with the WHMIS 2015 regulations »

railroad crossing
AAR Publishes New Edition of “Field Guide to Tank Cars”

Field guide to tank cars

AAR’s Field Guide to Tank Cars Download

Are you a birdwatcher who’s spotted every owl and thrush, and wants to move on to a new field of study? Are you a model train hobbyist who wants to make sure your HO scale equipment accurately reflects modern regulations? Or are you a safety professional who deals with bulk dangerous goods in tank cars? If your answer to any of those questions is “yes,” the American Association of Railways (AAR) has published something that will make identifying a TC-111A100W5 or DOT-117R100W as easy as telling a Mourning Warbler from a Laughing Gull.

AAR’s Field Guide to Tank Cars, by Andy Elkins, is a resource for rail workers and particularly for emergency responders. Tank cars come in many varieties, and handling them safely or responding to spills means that you must know what type of car is involved. The Field Guide has been updated for its third edition to reflect current regulations and standards, which have changed over the past decade due to incidents such as the Lac-Mégantic explosion in Quebec.

Types of Tank Cars

The Field Guide starts with a discussion of the basic types of tank cars – non-pressurized tank cars (also known as “general service” or “low-pressure” cars), pressure tank cars for products such as liquid propane and cryogenic liquid tank cars, used for gases that are liquefied at low temperature, such as liquid oxygen. After explaining the DOT (U.S. Department of Transportation), TC (Transport Canada), and AAR tank car classes and specifications, author Andy Elkins goes on to discuss how to interpret specification markings, assisted with a helpful diagram of a typical mark.

Safety Systems

Next, the guide covers the safety systems found in tank cars, such as Pressure Relief Devices (PRDs), and the markings that must be displayed on tank cars to identify qualification specifics, such as the Thickness Test. Further sections deal with additional details about the various car types, illustrated with clear technical diagrams and photographs. This arrangement makes it an excellent resource for non-experts who want a quick summary of tank car marking and safety, as well as a good in-depth guide for those who need to know details of the fittings and safety devices for specific commodities such as chlorine or crude oil.

The guide includes an Annex covering recent changes relating to tank cars in North America, such as Transport Canada’s Protective Directions #34 and 38, and the “FAST Act” amendments to 49 CFR.

Use of This Guide

This guide would be a useful introduction for anyone who ships dangerous goods (or even non-dangerous commodities) in tank cars. While the “Hazardous Materials Regulations” of 49 CFR (in the U.S.) and the “Transportation of Dangerous Goods Regulations” (in Canada) are the controlling regulations, their tendency to cross-reference standards often makes it hard to pull together a full picture of requirements for selection and marking. The guide arranges information in a clear, logical flow, and the illustrations prove that pictures are really worth a thousand words.

The best part? The Field Guide to Tank Cars is available as a free PDF download from the AAR site.

Have questions about shipping hazardous materials by rail, or by any other mode? Contact our regulatory staff here at ICC Compliance Center 1.888.977.4834 (Canada) or 1.888.442.9628 (USA).