TDG
The Clock is Ticking – 3 Recent TDG Proposals

Red semi truck on highway

An Easter Parade!

(Marine Amendment-Part 11, Rail Car Standard TP14877 Revision, ERAP- Part 7 Consultation)

Transport Canada is heading into what seems to be an ambitious spring/summer period with a variety of projects related to the Transportation of Dangerous Goods (TDG) regulations. The latest notices are open for comment until the end of April and cover aspects of Parts 5, 7 and 11 (with implications for other parts) of the TDG regulations (TDGR).

SHIP- NO!- “VESSEL” AHOY! – MARINE PROVISIONS

Significant changes are proposed to TDGR Part 11 and Part 1 Special Cases to reflect the current Canada Shipping Act (CSA) and associated regulations, as well as commercial considerations. These affect definitions, terminology and the ability to efficiently transport fuels or medical/diving gases on passenger vessels.

In addition to the changes highlighted in the notice, there are several other noteworthy changes in the proposal.

“Near coastal” versus “Home-Trade” Voyages

The current Part 11 has been the subject of confusion regarding what constitutes the use of the IMDG Code versus the TDGR, particularly with voyages between Nova Scotia and Newfoundland. Retailers in particular have had difficulty in determining when consumer commodities can continue on to NL under TDGR Special Case 1.17. The wording in the current TDGR implies that the voyage would fall under a Home-Trade Voyage Class 1 from the Home-Trade Voyage Regulations. At certain times, the Marine Safety branch of Transport Canada has indicated that, this voyage could be considered a Home-Trade Voyage (HTV) Class II (not referenced directly in the TDGR/old Canada Shipping Act wording) – i.e. within 120 nautical miles from shore and within 200 nautical miles of a port of refuge- and be considered a “domestic voyage” as described in §.11.2.

Thus, the voyage could fall under TDGR Special Case 1.17, Limited Quantity (LQ) exemption, which references a “domestic voyage” as eligible for the exemption, use TDGR placarding, etc.

However, the proposal- instead of maintaining this distinction- adopts the Vessel Certificates Regulations (VCR) terminology without providing an “equivalent” to a HTV Class II. The proposed version of 11.2 defines, in effect, a domestic voyage subject to TDGR (without any proposed amendment to 1.17).

The VCR terminology reference in the proposed 11.2 is for a “near coastal voyage, Class 2” to be the longest voyage to be considered “domestic”. This reduces the allowable voyage to one where the vessel is not more than 20 nautical miles from shore and within 100 nautical miles from a place of refuge.

Perhaps retailers might want to consider commenting to Transport Canada on this aspect- or start preparing to submit equivalency certificate requests (under TDGR Part 14).

Ferries

In addition to expanding some exemptions and increasing the distance from 3 to 5 km, exemptions in the current TDGR 1.6, 3.9 and 8.4(4)(d) are proposed to be dropped. These affect adherence to Schedule 1 Column 6 limits for passenger vessels, on-board access to shipping documents and reporting releases.

Flash Point Marking

The TDGR 4.13 to mark the flash point on packages is to be repealed, presumably since it’s not required in the IMDG Code.

Ammonium Nitrate-Explosives Notification

Notification of loading/unloading these commodities will no longer be required under the TDGR. Presumably this is considered a duplication of requirements under the CSA Cargo, Fumigation and Tackle Regulations.

A six-month transition period is proposed to follow publication date of the final amendment in Canada Gazette II.
The Canada Gazette I notice provides for comments until May 1, 2017 and may be obtained at:
http://www.gazette.gc.ca/rp-pr/p1/2017/2017-04-01/html/reg3-eng.php

Rail Car Standard TP14877

The first revision to this 2013 standard has reached a final (at 2016 12) draft stage and is available, on request, for review and comment by April 30, 2017:
http://www.tc.gc.ca/eng/tdg/clear-modifications-menu-261.htm#public

The major changes, as highlighted in the above reference, will incorporate the improvements in tank car design; and various other safety aspects covered in Protective Directions following the Lac Mégantic disaster in 2013. The draft also includes changes to further harmonize with the 19th Ed. of the UN model regulations and 49CFR.

Before Offering versus After Loading

One significant item in section 10 (Selection and Use of Containers…) is a change in the obligation for ensuring loaded containers are in safe condition for transport.

Section 10.8 has been changed from “Before Offering for Transport” to “After Loading”. This may be to reflect the desirability of discovering errors when they’re most likely to occur; but perhaps the former aspect should be maintained for situations where there is a delay between loading and offering. In section 10.9 (“Before Transporting”), the carrier is no longer specifically responsible for remediating deficiencies that could impact public safety.

ERAP Review

The TDGR Part 7 ERAP (registered “Emergency Response Assistance Plan”) requirements have been under a Task Force review for several years. Proposals for amending Part 7 include clarification on circumstances and parties’ rights/obligations with respect to accessing (for information) or activating an ERAP.

Also, the proposal would allow an ERAP holder to extend the right to third party to return “residue last contain” shipments under the holder’s ERAP without notifying Transport Canada, update the infectious substance ERAP list, and outline ERAP termination protocols when a holder no longer consigns the substances covered by the plan.

Transport Canada has established a comprehensive website to review and provide feedback on these and other aspects of ERAP requirements, by May 1, 2017, at:
http://www.letstalktransportation.ca/part7eraps

Considering that we’ve already seen consultations on an Harmonization amendment (expected to be finalized in Canada Gazette II in June/July); a review on possible changes to Part 6 “Training” requirements; and a pre-gazette “Canadian Update” amendment proposal- not to mention ongoing committee work to update standard TP14850 for small packaging and possible development of a large packaging standard- the balance of this year will be busy for both regulators and the regulated community.

Lithium
Lithium Batteries Section 1B & IATA Shipper’s Declaration

Lithium Batteries, Laptop battery

Lithium Batteries on IATA Shipper’s Declaration

One of my favorite cartoons growing up was “Scooby Doo”. Nothing made me laugh more than when Scooby would say, “Ruh roh, Raggy” when he was trying to say, “Uh oh, Shaggy”. This was usually in situations where things had gone terribly wrong. I had one of those moments recently and it was in regards to lithium batteries.

In one of my recent training classes, we were digging into the IATA Shipper’s Declaration and how to complete it. Anyone that handles these knows there are lots of things to include. As the discussion moved to the “Nature and Quantity of Goods” section, we were cruising. Everyone understood the process and how great IATA is about explaining what goes where. The examples in Chapter 8 are awesome!

The “Ruh roh” moment came as we were discussing the inclusion of the Packing Instruction number. Most of us are familiar with the first part of that step. It tells us that for all of our shipments, we add the number of the Packing Instruction we followed for said shipment. In Section 8.1.6.9.3 of IATA, it says the following:

Step 8. Number of Packing Instruction or Limited Quantity Packing Instruction (with its “Y” prefix) (Columns G, I or K). For lithium batteries prepared in accordance with Section IB of Packing Instruction 965 or Packing Instruction 968 the letters “IB” must be added following the packing instruction number.

And I would have gotten away with it too, if it weren’t for you meddling kids… (Not Really)

What I failed to read was the rest of the paragraph. It clearly states that for shipments of lithium batteries prepared under Section 1B, you have to include the letters “IB” after the Packing Instruction number. There is even an additional note in this section. It says if you can’t fit the letters “IB” in the column with the Packing Instruction number that it is ok to put it in the authorizations column.

This information is not found in the Packing Instructions themselves. Neither PI965 nor PI968 mention of this requirement to include the letters “IB” on the declarations.

Needless to say, after class that day I made a note to update all of our training materials on batteries to include this information.

For all of your lithium battery needs, contact ICC Compliance Center today. We have updated classes for both webinars and public courses, new handling marks, and new class 9 labels ready for you.

Lithium
What Does the Laptop Ban Mean for Travelers?

Cargo loading on aircraft

Recent Airline Laptop Ban

On March 25, 2017, the United States government implemented a ban on passengers bringing carry-on electronic devices such as laptops on board certain airlines. This ban will affect electronics that exceed the size of a cellphone—typical products that will be banned include laptop computers, tablets such as the iPad and Android versions, gaming devices larger than a cellphone, DVD players, and portable printers and scanners. These devices may still be carried by travelers, but must be stowed in checked luggage during the flight. Medical devices will be exempted from the restrictions.

The ban affects flights leaving from ten airports in eight Middle Eastern countries.

Airports Involved in the Ban:

  • Abu Dhabi International Airport, Abu Dhabi, United Arab Emirates
  • Ataturk International Airport, Istanbul, Turkey
  • Cairo International Airport, Cairo, Egypt
  • Dubai International Airport, Dubai, United Arab Emirates
  • Hamad International Airport, Doha, Qatar
  • King Abdulaziz International Airport, Jeddah, Saudi Arabia
  • King Khalid International Airport, Riyadh, Saudi Arabia
  • Kuwait International Airport, Kuwait City, Kuwait
  • Mohammed V Airport, Casablanca, Morocco
  • Queen Alia International Airport, Amman, Jordan

The ban affects flights of the following airlines leaving from any airports listed above:

  • EgyptAir
  • Emirates
  • Etihad Airways
  • Kuwait Airways
  • Qatar Airways
  • Royal Air Maroc
  • Royal Jordanian Airlines
  • Saudia
  • Turkish Airlines

The ban is intended to only apply to direct flights from these locations to the U.S., which would total just about 50 flights a day. If a traveler were to make a connection, say, in Frankfurt or Paris, the ban would not apply. (One imagines some very jealous passengers watching others enjoying their electronic entertainment simply because they boarded at a different airport.)

Why a Ban?

The exact concerns that triggered the ban is not clear. The U.S. Department of Homeland Security (DHS) has cited a “sophisticated” laptop bomb involved in an incident on board a Daallo Airlines flight in 2016. This new development in explosive devices could, it’s feared, be smuggled past security in countries with laxer procedures for inspecting carry-on baggage. If a powerful bomb could be hidden in a relatively small device, it would make detection difficult.

But why permit these potentially lethal devices in checked baggage? It appears that intelligence believes that such devices would require direct triggering, rather than a timer or remote control. In the cargo compartment these devices would be electronically isolated from commands by Bluetooth or similar means, and they would probably be too small to include an effective timer. In addition, such devices would, due to their small size, have a relatively small explosive radius. By requiring them to be checked, terrorists may be prevented from positioning the bombs in an effective manner. Other experts claim that the ban would do little to prevent a bomb from being detonated in an aircraft hold.

To add to the confusion, the United Kingdom (UK) has created its own list of fourteen restricted airlines, only four of which are on the U.S. list. Canada is also contemplating implementing a similar ban. Canadian Minister of Transport Marc Garneau has discussed the ban with Secretary of Homeland Security John Kelly, but no restrictions affecting Canada have yet been announced.

Does the Ban Introduce New Dangers to Aircraft?

Protecting air travel against terrorism and protecting against hazardous materials sometimes are clashing goals. After the “shoe bombing” incident, DHS started to ban matches and lighters in carry-on baggage. They advised travellers that they should put these goods in their checked luggage, apparently unaware that this would put the travellers in violation of Federal Aviation Administration (FAA) rules banning such articles.

The problem with electronic devices is that they generally contain lithium batteries. Such batteries have caused multiple incidents on aircraft due to their tendency to overheat and catch fire if damaged or improperly handled. Travellers can consult the Dangerous Goods Regulations (DGR), published by the International Air Transport Association (IATA) for guidance on carrying electronic devices that contain lithium batteries.

According to Table 2.3.A, Provisions for Dangerous Goods Carried by Passengers or Crew, “[p]ortable electronic devices containing lithium metal or lithium ion cells or batteries, including medical devices such as portable oxygen concentrators (POC) and consumer electronics such as cameras, mobile phones, laptops and tablets, when carried by passengers or crew for personal use (see 2.3.5.9)” are allowed as carry-on or as checked baggage. However, the provision goes on to note “[f]or lithium metal batteries the lithium metal content must not exceed 2 g and for lithium ion batteries the Watt-hour rating must not exceed 100 Wh.” These levels are usually met by consumer electronics, but it is a good idea to check the manufacturer’s specifications to be sure.

A further requirement is that when such devices are put in checked baggage passenger must take measures to prevent unintentional activation. While most such devices protect the on/off switch by their design, some (such as the iPad) could be turned on during flight by bumping the power button, and must therefore be cushioned in some manner to prevent this.

In the past, airlines have recommended that portable electronics be kept in the passenger compartment. Lithium battery fires can get out of control in the hold of an aircraft, while in the passenger compartment trained flight crews can quickly access the device and extinguish it. Placing more consumer electronics in inaccessible holds will, ironically, increase the risk from lithium fires.

Spending hours on overseas flights without our digital assistants for work and play would be much different from the experience most travellers have come to take for granted. The U.S. ban on portable electronics is currently temporary, due to expire in October, but much will depend on what happens over the next few months. If a legitimate threat is found, the ban could well become permanent or spread to other airlines and departure points. Additionally, the risk of terrorist attack must be balanced against the threat of lithium battery fires in aircraft holds.

As always, the airlines may have their own standards or ways of implementing these rules. If you have an electronic device that you wish to fly with, and you’re planning a trip that would be affected by the ban, consult with the airline in advance. They can confirm if, say, the new Nintendo Switch handheld console is an acceptable size.

Are you planning on travelling with portable electronic devices, and need to know how to do it safely? Our regulatory staff at ICC Compliance Center will be happy to help. Just contact us at 1.888.442-.628 (USA) or 1.888.977.4834 (Canada).

Consumer Chemical Spray Bottle
Compliances for Importing Consumer Chemicals Products to the US

To control the amount of toxic substances that are imported into the country, standards and regulations have been put in place. This helps to reduce the number of chemicals that are banned from entering the country, but also regulating the type of chemicals sold through various companies.

Those wishing to import consumer chemical products to sell on shelves have specific guidelines and regulations that must be followed. Failure to comply with the regulations will be subject not having the ability to import the products.

TSCA Import Certification Requirements

All consumer chemicals being imported must adhere to the stringent rules of the Toxic Substances Control Act (TSCA) for entry. This requirement states that you must acknowledge whether the chemicals being imported comply with the policy or do not require further certification.

The requirements for complying with the TSCA Import Certification Requirements are listed in section 13 of The Toxic Substance Control Act. In addition to the TSCA regulations, the EPA also has a set of guidelines that must be adhered too. Their policy statement is at 40 CFR 707.20.

Who Must Certify the Import

The importer or legal representative of the importer must certify the chemical substance being imported whether it is a part of a mixture or a bulk shipment.

Certification Statements

A positive certification statement must be written, and signed by the importer. It must state that everything being shipped, whether in bulk or as part of a mixture, complies to all chemical regulations set forth by the country. Furthermore, by signing this agreement, you agree that all the chemicals meet the requirements as they are regulated by the TSCA.

A negative certification statement would be written up and signed to state that the chemical products being imported are exempt from the TSCA’s rules and regulations.

A negative certification covers the following items:

  • Pesticides
  • Any foods, additives, cosmetics, or drugs
  • Special nuclear material or by-product material
  • Firearms or ammunitions (those defined under section 3 by the TSCA)
  • Chemicals separate but part of articles
  • Tobacco or products of tobacco

Certain chemicals have more specific requirements for import under section 6 listed in TSCA to avoid chemical accidents. Some of the chemicals include mercury, PCBs and asbestos, though there are others.

To comply with the requirements for import, all the chemicals must:

  • Not be imported for misuse or prohibited use
  • adhere to the Globally Harmonized System of Classification (GHS) and be properly labeled, as well as SDS requirements
  • Not exceed restrictions specified or import volume
  • Not to be imported for any significant new use
  • Comply with all other applicable and mandated requirements

All chemical products being imported must also fully comply with the REACH list of prohibited chemicals. This list removes many chemicals from entering the country and is subject to change without notice.

To have chemicals shipped to the country safely, it is imperative to have use of the right overseas transporter to guarantee that all laws and regulations are abided by and that all proceeds in accordance with the laws set forth for importing consumer chemical products.

Fire Safety
Spring Ahead – Fire Safety

Smoke Detector

Springtime Fire Safety

It is that time of year again, where we all lose an hour in our day. The good news is that we also gain an hour of daylight, and it means that warmer weather is just around the corner.

Many organizations including the National Fire Protection Association (NFPA) suggest taking the time to also check smoke alarms. The NFPA states:

Roughly two-thirds of home fire deaths occur in homes with no smoke alarms or working smoke alarms. When smoke alarms should have worked but failed to operate, it is usually because batteries were missing, disconnected, or dead. NFPA provides the following guidelines around smoke alarms:

  • Test smoke alarms at least once a month using the test button.
  • Make sure everyone in the home understands the sound of the smoke alarm and knows how to respond.
  • Replace all smoke alarms when they are 10 years old.
  • Replace the smoke alarm immediately if it doesn’t respond properly when tested.
  • Smoke alarms with nonreplaceable (long-life) batteries are designed to remain effective for up to 10 years. If the alarm chirps, a warning that the battery is low, replace the entire smoke alarm right away.
  • For smoke alarms with any other type of battery, replace batteries at least once a year. If the alarm chirps, replace only the battery.

Fire Extinguishers

Also, take time to make sure your fire extinguishers are in good working order. If they are in a business, ensure that inspections are up-to-date. The NFPA provides the following guidance regarding the use of an extinguisher:

Safety tips

  • Use a portable fire extinguisher when the fire is confined to a small area, such as a wastebasket, and is not growing; everyone has exited the building; the fire department has been called or is being called; and the room is not filled with smoke.
  • To operate a fire extinguisher, remember the word PASS:
    • Pull the pin. Hold the extinguisher with the nozzle pointing away from you, and release the locking mechanism.
    • Aim low. Point the extinguisher at the base of the fire.
    • Squeeze the lever slowly and evenly.
    • Sweep the nozzle from side-to-side.
  • For the home, select a multi-purpose extinguisher (can be used on all types of home fires) that is large enough to put out a small fire, but not so heavy as to be difficult to handle.
  • Choose a fire extinguisher that carries the label of an independent testing laboratory.
  • Read the instructions that come with the fire extinguisher and become familiar with its parts and operation before a fire breaks out. Local fire departments or fire equipment distributors often offer hands-on fire extinguisher trainings.
  • Install fire extinguishers close to an exit and keep your back to a clear exit when you use the device so you can make an easy escape if the fire cannot be controlled. If the room fills with smoke, leave immediately.
  • Know when to go.

Sources:
http://www.nfpa.org/news-and-research/news-and-media/press-room/news-releases/2014/nfpa-encourages-testing-smoke-alarms-as-daylight-saving-time-begins

http://www.nfpa.org/public-education/by-topic/fire-and-life-safety-equipment/fire-extinguishers

PHMSA Update
A Small Victory for Harmonization … For Now (HM-215N)

PHMSA Withdraws Final Rule

—PHMSA Update HM-215N

The Pipelines and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) has withdrawn a Final Rule that was intended to be published in the Federal Register on January 26.

The Final Rule, HM-215N, would have updated the U.S. “Hazardous Materials Regulations” to reflect international standards. This was due to the new administration’s Regulatory Freeze executive memorandum, issued January 20, 2017.

Harmonization

HM-215N would have harmonized the 49 CFR regulations to the latest version of the UN Recommendations on the Transport of Dangerous Goods, the ICAO Technical Instruction’s on the Safe Transport of Dangerous Goods, the International Maritime Dangerous Goods Code.

New lithium battery label     New Lithium Battery Mark and Pictogram
New marks and labels introduced in the upcoming international regulations.

 

This delay has made it particularly confusing for shippers of lithium batteries, who have transitioned to the new handling mark, and hazard class 9 label, shown in these international regulations.

Usage

Last week, PHMSA issued a Notice that allows offerors and carriers to use the 2017-2018 versions of the international regulations without fear of enforcement. In addition, it is allowing users to mark and label packages in accordance with either the 2015-2016 or 2017-2018 IATA/ICAO and IMDG regulations.

This notice is limited to 49 CFR Parts 171.4(t) and (v). This notice is expected to be in place until HM-215N is release, or this notice is otherwise rescinded or otherwise modified.

For a full version of the notice, please click here.

ICC is your source for hazardous materials products, services, and training, all under one roof. Contact us today.

Oil drum spill
What to Do – Accidents/Incidents Involving Dangerous Goods

Hazmat Incident

Unfortunately, Accidents Do Happen

Dangerous goods, necessary for Canadians’ quality of life, are transported from one area to another across the country every day. These goods, which travel by road, air, rail, and sea, leave Canada by the same routes, railway stations, airports, and ports. All these displacements increase the risk of incidents harmful to human beings and the environment. Therefore, it is essential that manufacturers, shippers, carriers, terminal operators, users, and governments strive to minimize the risk of incidents and the damage they can cause.

Approximately 30 million shipments of dangerous goods are shipped annually in Canada, and 99.998% of them travel to destinations without any incident!

When a dangerous goods incident occurs, the person in possession of the dangerous goods at the time of the incident must call the relevant competent authority (usually the local police, or call CANUTEC at *666 / 613-996-6666 / 1-888-CANUTEC, or call the 24-hour number that appears on the transport document or in the case of an ERAP call that activation number).

When first responders arrive at the scene of an accident involving dangerous goods, they will consult the Emergency Response Guide (ERG). They may also contact CANUTEC for assistance.

CANUTEC is Transport Canada’s Canadian Transport Emergency Center where bilingual scientists are always ready to answer. They are trained in emergency response and are ready to assist when an accident happens involving dangerous goods. CANUTEC’s role is to provide technical and scientific advice in an incident involving dangerous goods and to bring together all persons involved in the incident. The CANUTEC’s staff handles nearly 1,000 emergencies and answers more than 22,000 phone calls every year!

Note that CANUTEC advisors do not go to the scene of an incident.

CANUTEC also provides a 24-hour emergency telephone service for registered Canadian shippers who enter the CANUTEC emergency telephone number (1-888-CAN-UTEC (226-8832) or 613-996-6666) on their dangerous goods shipping documents. The free online registration for this service is available on the CANUTEC website.

TDG Reporting Requirements

Newly amended, Part 8 (Reporting Requirements) of the Transportation of Dangerous Goods (TDG) Regulations improves the data collection process, increases risk analysis capacity and specify the reporting requirements.

Part 8 of TDG requires that CANUTEC be contacted in the case of:

  • a Release or Anticipated Release Report (Road, Rail, Marine);
  • a Dangerous Goods Accident or Incident Report (Air);
  • an Undeclared or Misdeclared Dangerous Goods Report (Air);
  • a Loss or Theft Report (Road, Rail, Marine, Air); or
  • an Unlawful Interference Report (Road, Rail, Marine, Air).

Part 8 has three tier reporting for road, rail and marine:

  1. Emergency report to local authorities if the release endangers or could endanger public safety* consult 8.2;
  2. A Release or Apprehended Release report, only if special requirements are met consult section 8.4;
  3. A 30-day follow-up report, if a release or apprehended release report was required, consult section 8.6.

*Note that public safety refers to safety related to human life and health, property and the environment.

Transport Canada released Safety Awareness Kits aimed at target audiences – First Responders, Communities/Municipalities, Industry and the General Public – containing valuable information on the Transportation of Dangerous Goods. You can consult them at:
Transportation of Dangerous Goods Safety Awareness Materials and FAQ webpage

Safety Data Sheets (SDS)
How to Read a Safety Data Sheet (SDS)

Hockey Goalie

Safety Data Sheets Defend Your Employees

Chemical Safety in the workplace can be a topic most employers would like to avoid. However, not only is it vital to the employee’s and community’s wellbeing, it is a requirement by law. In comes Safety Data Sheets (SDS) to the rescue! If Chemical safety in the workplace was a hockey team, training, storage requirements, purchasing, disposal, and inventory requirements would make up the Center, Forwards, and Defense, leaving the cornerstone of any hockey team, the Goalie to represent Safety Data Sheets (SDS). OSHA Standard 1910.1200 (g)(8) states that The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). However without correct understanding of Safety Data Sheets, it would be like having an injured goalie in your starting lineup. Below are some tips for reading a 16-section format SDS.

Section 1. Identification:

Identifies the chemical on the SDS and displays the recommended uses. This section also provides contact information of the manufacturer as well as an emergency phone number.

Section 2. Hazard Identification:

The purpose of this section is to identify various hazards the chemical presents as well as any warning information. This includes Hazard class, signal words, pictograms and hazard statements.

Section 3. Composition/Information on Ingredients:

Displays the ingredients contained in the product. It gives the concentration of each ingredient that is classified as a health hazard.

Section 4. First Aid Measures:

Describes any first aid that should be given by untrained responders if there is exposure to the chemical. This includes symptoms and recommended immediate medical care.

Section 5: Fire-Fighting Measures:

Gives recommendations of how to handle a fire that is caused by this chemical. This includes extinguishing equipment, protective equipment, and information on other hazards that can arise if the chemical burns.

Section 6: Accidental Release Measures:

Lays out the recommended response to spills, leaks, or releases of the chemical. This includes cleanup practices, emergency procedures for evacuation, protective equipment, and spill volume.

Section 7: Handling and Storage:

Outlines the procedure for safe storage of the chemical. This includes ventilation requirements if applicable.

Section 8: Exposure Controls/Personal Protection:

Recommends the specific types of personal protection such as gloves, respirators, or glasses when using the chemical referenced in the SDS.

Section 9: Physical and Chemical Properties:

This section identifies the appearance, odor, density, flammability or explosive limits, as well as other physical properties of the chemical.

Section 10: Stability and Reactivity:

Breaks down the different reactive hazards of the chemical and stability information. This includes an indication of whether the chemical will react in certain situations such as pressure or temperature change, as well as any safety issues that may arise if the product changes in physical appearance. There is also a description of specific test data for the chemical.

Section 11: Toxicological Information:

Identifies any information about immediate or chronic health effects that may arise from exposure to the chemical. This also includes symptoms of exposure from lowest to most severe.

Section 12: Ecological Information:

This section measures the impact the chemical has on the environment if it were released. This includes test results if available.

Section 13: Disposal Considerations:

Provides information on how to properly dispose of the chemical as well as safe handling practices.

Section 14: Transport Information:

Provides guidance on classification information for shipping and transporting by ground, air, or sea. This includes UN number, proper shipping name, and hazard class.

Section 15: Regulatory Information:

Displays the specific regulations for the product not indicated anywhere else on the SDS.

Section 16: Other Information:

Indicates when the SDS was created and the level of revision. This section states where the changes have been made to the previous version.


As always, if you have any questions regarding SDS Services contact ICC Compliance Center at 1.888.442.9628 (USA) or 1.888.977.4834 (Canada).


Source: https://www.osha.gov/Publications/OSHA3514.html

Shipping by Road
TDGR US Import Cross-Docking – All We Want are the FAQs…*

Cross-Docking is Reshipping

On February 8 Transport Canada issued an addition to FAQ regarding the Transportation of Dangerous Goods Regulations (TDGR) Part 9, s. 9.4. This section deals with the re-shipping of dangerous goods (DG) received by road from the US when safety marks differ from those specified in the TDGR. In general, (more on this later**), TDGR 9.1 allows receipt of US shipments to first destination with the safety marks that were legally applied under 49 CFR at the US shipping point.

Cross-Docking

The FAQ defines “cross-docking” as “the process of transferring dangerous goods from one vehicle to another before reaching their final destination”. Changing drivers or tractor units does not trigger the term. When DG are cross-docked, Transport Canada considers this to be “re-shipping” and the provisions of TDGR 9.4 apply (note: although the FAQ refers to “reshipping” in quotes, the term is not specifically defined in the TDGR other than as described by s. 9.4).

Reshipping

Basically, the requirements in s. 9.4 are to remove placards which do not meet TDGR requirements and replace them with TDGR-compliant versions. Examples of these could be US “DANGEROUS” placards; or those with the midline adjusted (e.g. Class 7, 8, 9); or worded and “combustible” placards.
In addition, if means of containment (soon to become “packaging” we hope!) have labels or other safety marks differing from TDGR requirements, then the shipping paper must be annotated accordingly as indicated in s. 9.4 (2).

Part 10 is not referenced in the FAQ, but presumably similar logic will apply to cross-docking rail car shipments (TDG s. 10.4) – or to transfers between rail/road vehicles.

Just the FAQs

Although the author hasn’t seen anything in official consultation documents, statements in casual conversations on two occasions indicate that the current practise of including interpretative guidance as italicised text within the body of the regulations will likely be discontinued. Apparently, this very useful (in my humble opinion) practise is at odds with regulatory convention that expects only the mandatory legal requirements to appear in the regulation. FAQ are the preferred vehicle for the type of information we currently see italicised within the TDGR.

The FAQ referred to in this Blog is available at:
http://www.tc.gc.ca/eng/tdg/awareness-materials-and-faq-1159.html#a99_0

* with apologies to Sgt. Joe Friday/Jack Webb’s often misquoted statement:
http://www.snopes.com/radiotv/tv/dragnet.asp

** Reciprocity has its limits
Although we often hear of “reciprocity” for shipments inbound from the US, we must remember that it has limits. As referenced in the above-mentioned FAQ, the “inhalation hazard” version of Class 2.3 and 6.1 labels or placards are not acceptable even to first destination. The “regular” versions, applied with qualifying marks as required by TDGR SP 23 also need to be present. Similarly things done by US special permit- although potentially to be accepted to first destination under the CG I International Harmonization proposal- will not necessarily be approved for reshipping. Perhaps once the CG II is finalised we’ll have another Blog on this aspect…

Lithium
Lithium Battery Labels as of Feb 1, 2017

Both 49 CFR and TDG are expecting to harmonize lithium battery labels into the regulations; however, both regulations are pending. HM-215N (49 CFR) was recalled, and will not be reissued for at least 60 days.

Transport Canada has not provided an ETA on the harmonization.

Find out the correct labels to use below: