If you are supplying chemical products that require Safety Data Sheets (SDS’s) to multiple countries, you are also likely to know this headache well.
With the implementation of the Globally Harmonized System of Classification & Labeling (GHS) around the world progressing, issues are beginning to appear which emphasize points where…. Maybe requirements are not so ‘harmonized’. One such issue, is ingredient disclosure requirements on SDS’s for mixtures across different regions of the world.
The United Nation’s (UN’s) GHS system, does contain some standardized recommendations for SDS, including that SDS’s should be provided only for chemicals classified as ‘hazardous’, SDS’s should contain basic minimum information (e.g., 16 sections with specific headings), as well as more detailed recommended guidance on how to prepare each section of the SDS.
Ingredient disclosure recommendations, in particular, appear in Annex 4 of the GHS. In general, the GHS recommends that for a mixture classified as hazardous, the SDS should list all ‘hazardous’ ingredients, which are individually hazardous to health or the environment, when the ingredients are present above concentration cutoff levels. There’s several parts of that general requirement, which can be viewed as a ‘can of worms’.
Are the cutoff levels the same for each region of the world? How should one handle ingredient disclosure when you are in a region that doesn’t regulate environmental hazards on SDS’s? Are ‘non-hazardous’ chemical mixtures really not Continue Reading…
UPS Makes Changes to its International Special Commodities (ISC) Program
UPS has announced it will be making changes to its International Special Commodifies (ISC) Program which enables selected customers under contract to ship certain prohibited articles.
This initiative has added more than 50 countries that can ship biological substances, shipments utilizing dry ice, and goods in excepted quantities internationally.
What does this Include?
UPS will now pick up and deliver packages containing UN3373 (Biologic Substances, Category B, Diagnostic Specimen and Clinical Specimen) as well as UN1845 (Carbon Dioxide, solid or dry ice) to 51 added countries and territories bringing the total number of countries to over 100.
In addition, the countries that were added to the list can now ship dangerous goods in excepted quantities internationally if authorized by the regulations.
Dangerous goods shipped in excepted quantities allow relief from certain regulations in small quantities outlined by IATA in §2.6. Be sure to check IATA for specific details and to use the label below when shipping in excepted quantities.
Where can I find packaging for UN3373 Category B Specimens and dry ice shipments?
At ICC we have a wide variety of packaging specifically designed for biological packaging as well as dry ice shippers for international shipments similar to the kit below:
Updated TDG Packaging Standard – Small Containers for Classes 3, 4, 5, 6.1, 8, & 9
In addition to expanding the title to reflect the various types of containers contemplated in the Transportation of Dangerous Goods regulation (TDGR) §5.6, 5.12 (and cited within other referenced standards), this “final draft” reflects the penultimate result of a review that’s been active since the adoption of the current edition in 2015.
Anatomy of Development
The 2nd Edition of TP14850, published October 2010 was adopted into the Canadian TDGR in July 2014, replacing CGSB-43.150-1997 and becoming the mandatory standard for packaging the “common” classes of dangerous goods in Canada in January 2015.
The 16th Edition (2009) UN Model was the primary basis for the 2010 TP14850 standard, so it was time to move forward in the spirit of harmonization.
Transport Canada began the process of forming a consultative committee in mid-2015. A public notice regarding the consultation was published in early 2016 with provision for general public input. The committee, formed in April 2016, consists of about 3 dozen participants.
The committee includes a core group of 6–8 from Transport Canada with the remainder representing a variety of industry associations, individual manufacturers, users, provincial/US regulatory interests, and labour organizations.
The draft presently open for general comment was developed by consensus following discussions, including face-to-face meetings and a series of web/teleconference sessions, between April 2016 and June 2017. Continue Reading…
Those who follow the IATA DGR will have an idea of many of the changes resulting from the UN Recommendations expected to result from the changes in the 20th Edition of the commonly titled “Orange Book”.
Those who work with other modal/government regulations may not be familiar with changes that will likely follow in those regulations as all or part of the amended Model become incorporated.
Changes in Terminology
As often happens, terminology changes were introduced to this edition to clarify or technically improve concepts covered by the regulations. Throughout the document the term “risk” has been replaced by “hazard” to reflect the intent of referring to a danger.
Similarly, most references to “devices” now refer to “articles” which is defined in 220.127.116.11 as including “machinery, apparatus or other devices”.
New UN Numbers
UN3535 to UN3548 have been added to the collection:
UN3535 refers to “TOXIC SOLID, FLAMMABLE, INORGANIC, N.O.S.”
UN3536 is a new “LITHIUM BATTERIES INSTALLED IN A CARGO TRANSPORT UNIT” applicable to either ion or metal-based batteries.
UN3537 through UN3548 cover a sequence of listings for “ARTICLES CONTAINING…, N.O.S.” applicable to a variety of Class 2-5, 6.1, 8 and 9 dangerous goods.
The additional entries result in related changes to classification sections and special provisions.
As we’ve seen over the last few years regulation of lithium battery regulations continues to evolve.
Although much of the information in the FAQ, detailing the purpose of the Part 11 and other related changes, was covered in the Gazette II RIAS (CGII Regulatory Impact and Analysis Statement), there are a couple of points that may be of interest.
Schedule 1 – Column 8 Clarification
The FAQ clarifies that the Col. 8 restriction is based on the specific categorization of the number of passengers as dictated in s. 1.10, not on the definition of “passenger carrying vessel” itself in s. 1.4
The amended reference to restriction of DG on board passenger-carrying vessels resulted in a separation on the basis for applying the Schedule 1, Col. 8 restriction. Formerly there was a qualifier in the Part 1.4 definition of “passenger carrying ship”, that invoked the restriction, based on a number of passengers per ship and/or per meter of ship length.
The current Canada Shipping (CS) Act has a definition for “Passenger, but not “passenger carrying vessel””.
Similarly, the Cargo, Fumigation and Tackle Regulations (CFTR), in s. 142, defines “passenger vessel” in the terms currently found in s. 1.10 of the TDGR.
Presumably, without the clarification in the FAQ, shippers might conclude that 1 passenger (based on the s. 1.4 definition) would invoke the Col. 8 Continue Reading…
A new state variation was added for Ethiopia. This new addition includes 4 variations including mandatory requirements for the shipper’s declaration form and a mandatory inclusion of an (M)SDS.
UPS Airlines (5X), Air Canada (AC), Air France are some of the others who have operator variations. Check these carefully, as there are several pages dedicated to these changes.
Table 2.3A – Provisions for Dangerous Goods Carried by Passengers or Crew has been regarding Lithium Batteries. This section is not only important for shippers, but also for travelers.
Section 18.104.22.168 has been completely revamped. There isn’t an easy way to go in and make the changes they have listed. As a courtesy to our customers, you can download a revised section with all the changes, deletions and additions. It fits on one page and can be printed for adding into IATA.
A change was added for Dangerous Goods in Excepted Quantities. The number of packages must now be shown on in the Nature and Quantity of Goods box on the waybill, unless they are the only thing being shipped.
Transport Canada issues new Part 11 and makes other miscellaneous changes
The December 13, 2017 edition of the Canada Gazette II contains the expected rewrite of Part 11 “Marine” requirements of the Transportation of Dangerous Goods Regulations (TDGR). In addition, there are related changes in other parts, as well as some unrelated miscellaneous changes in other areas.
The most wide-reaching change, although perhaps of relatively minor significance to the general regulated community, is the replacement of the term “ship” with “vessel”. This, among other changes, is to update the TDGR to current Canada Shipping Act (CSA, and related regulations) terminology. Many aspects of Part 11 related to the CSA had not been updated since 2008.
This differs from the TDGR definitions for road and rail vehicles which expressly exclude “muscle power” as a means of propulsion. (“Means of transport” in TDGR is a different story, but perhaps we’ll leave that one for another blog!)
Other definition changes include elimination of the reference to “short run ferry”, previously defined in TDGR Part 1.3 as operating between points “not more than 3 km apart”. TDGR 1.30 special case exemption now refers only to “Ferry,” but describes within the exemption that it’s applicable to operating between two points “not more than 5 km apart.
Here we are at the end of 2017 and the best word to summarize it is “change”. Every transport regulation had some sort of change this year. The most recent one is to the IMDG Code. A Corrigenda was published earlier this month that makes some changes to the 38-16 version. Note that this version becomes mandatory for use starting January 1, 2018.
Here are a few of the highlights:
The words “fishmeal” and “seedcake” are now divided into separate words throughout the regulation. You now have “fish meal” and “seed cake” throughout the code.
The words “marking” and “markings” have all been replaced with “mark” or “marks” through the entire code.
Several chapters in the regulation have been renumbered such as the subheadings under 5.1.1, 7.8.6 and 7.8.7.
Packing Instruction P002 has a change to Special Packing Provision PP11 to include 5H1, 5L1 and 5M1 bags.
Special Packing Provision PP40 has been deleted from several UN numbers including 1396 (PG III), 1398 (PG III), 1402 (PG I) and 3132 (PG III) to name a few.
For the new Lithium Battery mark there is now the allowance that it can also be a “suitable contrasting background” rather than just black and white.
The new Class 9 Hazard Label for Lithium Batteries also received some clarification in Chapter 22.214.171.124.1.3 in that the number of vertical stripes Continue Reading…
PHMSA Issues Notice of Change on Termination of M-Number and R-Number Approvals with no Expiration Date
PHMSA has made a proposal to terminate previously approved M-numbers and R-numbers that were issued without an expiration date. Unless approval holders can either show why their approvals should not be terminated as provided in 49 CFR 107.713(c)(1) or apply for a modification of their approval in accordance with 49 CFR 107.705 prior to the effective date, their M-number may be considered expired. Modified approvals will conform to the Approvals and Permits Division’s standardized format in which all approvals have a 5-year expiration date.
What is an M-Number?
An “M-Number” or manufacturer number is issued by the D.O.T. to a manufacturer of packaging related to hazardous goods as a means of identification. This number is used in place of the manufacturer’s name and address as authorized in 49 CFR 178.503. In addition, an “R” number was a number previously given to companies that recondition their hazardous goods packaging, but PHMSA now uses M-numbers in their place. Often times the M-number is displayed on the outside of a package (like in the above picture). Manufacturer’s symbols can come in two formats. The first format lists the manufacturers sequentially by Identification Number (M#). The second format lists each state’s manufacturers alphabetically by city and company name. The identification number, the name and address, the status, and Continue Reading…
The wording in recent, current and upcoming editions of the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) has some potential to confuse the regulated community, especially regarding shipping lithium batteries.
Exemptions Restricted or Not?
The paragraph providing an exemption from the lithium battery mark (pka “Handling Label”) is found in the last sentence of the second paragraph in Section II “Additional Requirements”, for the packing instructions (PI) for both UN3091 and UN3481 “contained in…” lithium battery entries:
This requirement does not apply to:
packages containing only button cell batteries installed in equipment (including circuit boards); XXX
consignments of two packages or less where each package contains no more than four cells or two batteries installed in equipment.
The “XXX” is the key that led to this discussion.
2016 as the Baseline:
In the IATA DGR 57th (2016) Edition, both PI 967 and PI 970 (“contained in equipment”, ion and metal respectively), the “XXX” in each case read “or”.
In other words, whereas cells/batteries other than button cells were limited to 2 packages per consignment, the number of packages per consignment were not limited when there were only button cells (of course, the maximum net battery weight per package restrictions in Table II of each PI must also be met).
Looking Forward to 2017?
Things then look as though they’re changing when reading the Appendix H (Intended Changes for Continue Reading…