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 it is the regulation to have the 6.1 on the bottom of the placard … and not just the 6 in order to ship overseas. Is Continue Reading…

ICC Top 10 List
OSHA’s Top 10 Most-Cited Standards for 2017

Young female Industrial Worker

Top 10 OSHA Violations 2017

At the end of September every year several things happen. It is the official start of autumn. All of the children are back in school. Pumpkin spice everything is available. OSHA publishes their list of top ten most-cited standards. These are 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 2017

  1. Fall Protection – Standard 1926.501 with 6,072 violations
  2. Hazard Communications – Standard 1910.1200 with 6,072 violations
  3. Scaffolding- Standard 2936.451 with 3,288 violations
  4. Respiratory Protection – Standard 1910.134 with 3,097 violations
  5. Lockout/Tagout – Standard 1910.147 with 2,877 violations
  6. Ladders – Standard 1926.1053 with 2,241 violations
  7. Powered Industrial Trucks – Standard 1910.178 with 2,162 violations
  8. Machine Guarding – Standard 1910.212 with 1,933 violations
  9. Fall Protection: Training requirements – Standard 1926.503 with 1,523 violations
  10. Electrical Wiring Methods – Standard 1910.305 with 1,405 violations

Here are some things I notice about this year’s list. First of all, four of top ten are related. By this I mean, items 1, 3, 6 and 9 are related to falling.  Next, take note that the top five violations are the exact same and in the same order as the past four fiscal years. Almost every other standard listed for 2017 is also on the 2016, 2015, 2014 and 2013 lists. The only Continue Reading…

Emergency Preparedness
Safety & Emergency Preparedness

Firemen Extinguishing a Fire

Dangerous Times, Dangerous Goods

This year has seen environmental disasters that have put millions of people at risk. From the incredible one-two-three punch of Hurricanes Harvey, Irma and Maria, to the Bangladesh floods, to the recent earthquake in Mexico, we see people facing lack of food, clean water and shelter. All of us need to protect ourselves and our loved ones during these periods when outside help hasn’t arrived. But while we’re watching out for what Mother Nature can throw at us, we must also remember hazardous chemicals and articles, even those that can help us survive, can put us in danger as well.

How to Prepare for Natural Emergencies

What does a typical household need to prepare for natural emergencies (or even man-made ones such as chemical spills that can isolate and endanger communities)? A number of websites list “must haves” and “should haves” for these situations, including:

What are some of the hazards that our own preparations can create?

One of the biggest dangers during emergencies is generators. These internal-combustion power sources can be lifesaving, especially for those with special health needs, and can make life during power outages more bearable. But they function by burning fuel, which can 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 except the dealer’s name and address which can appear in either language.

Any label information in addition to the mandatory requirements discussed above (i.e., directions for Continue Reading…

Repacking Dangerous Goods
A Dead Bat: Repacking Biological Substances

Repacking Biological Substances UN3373

We Repack All Types of Dangerous Goods … Including Dead Bats!

I received a call from a local veterinarian who was looking to buy 2 labels, yes only 2 individual labels. We sell them in rolls of 500 so it is surprising when someone asks for 1 or 2 labels. She was advised by a carrier that all she needs is to put two “UN3373” labels and a label with the words “Biological Substance, Category B” on a package and send it out. The veterinarian called us to get two “UN3373” labels and a label with the words “Biological Substance, Category B” as told to her by the carrier. I advised her that she can simply write the words on the package as long as it’s legible and indelible but she said she was told it must be a label.

TDG Training to Ship a Dead Bat?

Of course this is when my brain starts thinking outside of the box (more than the conversation that is currently taking place). Then I asked if she was trained to ship dangerous goods and she said no. She was only doing what the carrier advised her to do. That’s when the regulatory specialist in me stepped up. I advised her she must have TDG training to be able to ship dangerous goods. I gave her a 5 minute crash course Continue Reading…

Fire Safety
NFPA’s Fire Prevention Week 2017

Every Second Counts: Plan 2 Ways Out!

The National Fire Protection Association (NFPA) has designated the week of October 8th 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 “Every Second Counts: Plan 2 Ways Out!” An explanation of the theme is best explained by a video from Sparky, The Fire Dog.

Here are some statistics from a recent survey conducted by the NFPA. About one in every 338 homes had a fire each year from 2010 to 2014.  For most of those years the second leading cause of fires in homes and fire deaths/injuries is heating equipment. In terms of escape planning, only about a third of the US has developed and practiced a home escape plan. Also, many people believe they would have 6 minutes before a home fire could become life threatening when in reality the time is much shorter. The most shocking statistic of all was that only 8% of those surveyed indicated that when hearing a fire alarm their first thought was to leave the home or building. These are numbers we cannot deny and should all consider.

So, what can you do?  Here are some ideas from NFPA to use during Continue Reading…

Prop 65
Proposition 65 List – Updated

Foggy California bay at sunset

What a Difference A Day Makes

Recently at a ballroom dance lesson, I heard the song “What a Difference a Day Makes”. A young couple is using it as their wedding song. They were learning a dance using it for the reception. Listen here to the 1959 version by Dinah Washington. Not only did the melody and words stay with me, but so did the title. Keeping in mind how things can change in a day I wanted to follow up on my blog “Extra! Extra! Read all About it: California Proposition 65 List Updated” from April 2016. A bit more than a day later but you get the point.

It turns out the Safe Drinking Water and Toxic Enforcement Act of 1986 or as it is more commonly known Prop 65 was updated seven times since my blog in April. 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 substances ability to cause cancer, birth defects or other reproductive harm. Shown below are all of the new substances that were added by month. They are listed by name, type of toxicity and Chemical Abstracts Service Registry Number (CAS).

Proposition 65 – New Substances

May 2016

Single Packaging
What About Cobb … Testing?

Splash drops of water on cardboard

What is Cobb Testing?

If you previously read my blog Anatomy of A box, you learned about the various components that make up a corrugated box. The construction of a box can become even more complicated for dangerous goods. Not only do you need to provide strong, durable corrugated boxes that can withstand drops and movement during transportation, but they must also be able to withstand various weather conditions including snow and rain.

How can box manufacturers and test labs ensure that dangerous goods packaging is safe to use when it gets wet? This is where the Cobb test comes in handy. This test helps determine the quantity of water that can be absorbed by the surface of paper or board in a given time. In this case, the less water that absorbs into the corrugated, the better. In fact as per § 178.516 of CFR 49 as well as TP 14850 7.8 this test is a requirement.

Cobb Testing

Why Cobb Testing?

Cobb tests are performed, because paper and fiberboard tend to attract and hold water molecules from the surrounding environment. The Cobb test is essential as it tests the ability of the paper to resist the penetration of water and quantity of water absorbed by the surface of fiberboard. If fiberboard absorbs too much water, the box may have difficulty maintaining strength and integrity. In fact, the inner fluting can Continue Reading…

Safety
Flood Water Safety

Wearing yellow flood boots walking through flood water

How to Stay Safe During Extreme Weather

Hurricanes bring about many emotions for me. You see, I have lived through a large number of them with varying impacts on my life. Here are just a few that trigger some strong emotions in me even after more than 15 years. In 1989, Hurricane Hugo hit. I was in college at North Carolina State University in Raleigh, NC. What made it so scary was the fire alarm in the middle of it, which caused an evacuation from my dormitory. The wind and rain were so strong you almost couldn’t stand.

The next one that comes to mind is Bertha in in 1996. Bertha was memorable because we purchased our first home the day she hit. If we had stayed in our new home, we would have lost both of our cars due to a tree falling. The worst though came in 1999. That year brought us Dennis in August and Floyd in September. We survived Dennis with a few heavy rains and some minor damage to the neighborhood. However, Floyd hit just 2 weeks later! Again, there was little damage in our area but lots of rain. We cleaned up and prepared for work the next day. What we weren’t prepared for was the National Guard at our door at 4:00 am that next morning telling us to evacuate due Continue Reading…

Alberta Reviews OHS System

Warehouse with chemicals

News From the Provinces

Alberta Labour Announces Comprehensive OHS Review – Invites Comments by October 16

Taking Alberta workplaces a little closer to heaven:

The province of Alberta is inviting stakeholders to get involved in a comprehensive review of its occupational health and safety (OHS) system. Although there have been some amendments (e.g. to the OHS Act in 2012, with an update to the OHS Regulation in 2013), the system was established in 1976. The operating OHS Code, containing details (such as WHMIS requirements) has not been updated since 2009.

[Note: Alberta Labour has also posted an update to their WHMIS 2015 transition policy following the extension of Health Canada’s deadline to 2018 for suppliers:

http://work.alberta.ca/documents/OHS-Bulletin-CH010.pdf ]

In addition to general regulatory updates, the review will also look at improving the fundamental aspects of the system under the key themes of responsibility, worker engagement and prevention.

Responsibility

This topic will examine potential enhancements to the internal responsibility system that may include tools such as prescribed joint health and safety committees or other programs, and enforcement options.

Worker Engagement

Worker engagement is dependant on protected rights- i.e. the right to: know about hazards; freely participate in OHS decisions or to refuse unsafe work, without fear of reprisal. Education and training of workers can assist in promoting worker engagement.

Prevention

The main focus of this theme in the review seems to be examining current programs to determine their effectiveness, as well Continue Reading…