Compressed Gas
CSA Cylinder Standards – June 2018 Update

compressed gas cylinders

CSA issues new Editions of TDG Class 2 Cylinder Standards

Transport Canada has issued an update “Notice” to inform the regulated community of recent updates to the Canadian Standards Association (CSA) standards addressing the requirements for the manufacture/qualification, selection and use of cylinders used in the transportation of dangerous goods (TDG).

Although these standards are primarily for compressed gases, their use may also be required or permitted for DG substances, other than Class 2, that may produce toxic or flammable vapours. Typically, this information is cited in standard TP14850 by reference in the packing instructions.

The four standards involved are:

CSA B339, CSA B340
(design/manufacture/qualification and selection/use, respectively) regarding cylinders, spheres and tubes, and other similar containers.
CSA B341, CSA B342
(manufacture/qualification and selection/use, respectively) regarding UN pressure receptacles and multi-element gas containers (MEGC).

Why Two Sets? Origins

The B339/B340 set are the seventh revision to the standards based on the older CTC (Canadian Transport Commission, pre-Transport Canada) national standards for these types of containers. These versions are the seventh revision of the original editions commencing in 1983 and 1986 respectively.

This contrasts with the B341/B342 set derived from the standards in UN Recommendation model regulations. The Canadian versions referenced here are the 3rd editions following 2009 and 2015 editions. Issuing these as CSA standards, rather than just adopting the UN Recommendations, facilitates incorporating the country-specific aspects such as special permits, reciprocity, etc.

Details

Although the 2 Continue Reading…

USPS Regulations and Updates
U.S. Postal Service Creating New Rules for Mailing Liquids

Different bottle of perfume on a wooden table

After an Unfortunate Incident USPS New Rules are Being Created

It was a normal day at the Westgate Post Office, on the outskirts of Rochester, NY. Then a strange odor filled the air, irritating people’s eyes and respiratory passages. By the time the emergency crew had finished its investigation, six people had been sent to hospital for observation, and ten more had been evacuated. At last the culprit was discovered, lurking in an innocuous-seeming package. It turned out that a bottle of nail polish remover inside had broken and the liquid was dripping from the box.

Luckily, no one was seriously hurt. “This was unfortunate, but it could have been worse,” said Karen Mazurkiewicz, spokesperson for the U.S. Postal Service (USPS). It isn’t actually illegal for people to ship small amounts of hazardous materials through the mail in the U.S., as long as shippers comply with the “Hazardous Materials Regulations” of Title 49, Code of Federal Regulations (49 CFR), as well as the “Postal Service Regulations” in Title 39 of the Code (39 CFR). Guidelines for mailing hazardous materials can be found in USPS Publication 52 – Hazardous, Restricted and Perishable Mail.

Unfortunately, many shippers in private life (and even some in industry) aren’t even aware that these regulations exist. And what was created by the U.S. Department of Transportation (DOT) for commercial shippers may not provide workers and Continue Reading…

HazMat box with tape gun
PHMSA Update: Tape Specifications vs Packing Instructions

Man preparing shipment

PHMSA Changes Mind on Tape

If you are a frequent shipper of dangerous goods, then surely you know the importance of the type of tape that you use to close your hazmat packaging. In fact, a while back I wrote a blog on this very topic.

It doesn’t take much to fall out of compliance of the regulations outlined in the 49 CFR 178.601 (4) (ii) when it comes to tape. It’s quite simple, you either use the type of tape the package was tested with and is outlined in the closing instructions, or it is considered non-compliant.

Per the interpretation below, PHMSA even went as far as saying that using a wider version of the same exact type of tape was not permitted when using a UN tested outer box, stating specifically that, “it does not conclusively demonstrate how the package will perform when tested or transported.” Meaning if the box was tested with a type of tape that is 2 inches wide, you couldn’t use a 3-inch wide version of the same exact type.

Read the original interpretation.

However, recently PHMSA seemed to have a change of heart on this topic.

What’s The Change?

Recently PHMSA has decided to rescind the above interpretation, stating that, “increasing the width of the tape from that specified in the packaging test report and closure notification does not constitute a change in design, provided the Continue Reading…

TDG Standards on the Move – Explosives Plus TP14850 & TP14877

TDG Update - Red and white semi truck on the highway

CGSB.43-151 Class 1 Explosives Draft Update

There have been some recent developments in 2 of the packaging standards of potential interest to the DG community involved with Canadian transportation.

  • TP14850- Class 3-6.1, 8 and 9 Small Packaging pre-publication 3rd Edition-Transition to CGSB
  • TP14877- Rail Transition to CGSB

CGSB-43.151 Explosives Packaging Standard

Transport Canada has provided notice of a consultation on a proposed update of the Canadian General Standards Board (CGSB) standard “Packaging, Handling, Offering for Transport and Transport of Explosives (Class 1),” CAN/CGSB.43-151.

The new edition, to replace the current 2012 edition, will update the list of UN numbers and packing instructions to align with the UN Recommendations 20th edition; and update references to other dangerous goods container standards.

Also proposed in the draft are packing instructions for UN large packaging (ELP) to supplement the existing standards for IBC and portable tanks.

New Canadian domestic packing instructions (CEP 01) for jet perforating guns, used in oil well completion, are also included in the draft. Previously packaging of these (UN0124 and UN0494) had to be authorized on a case-by-case basis as referenced in EP 01.

CEP 02 replaces the previous EP 17 for highway and portable tank transport.

In common with the recent approach in other Canadian standards, changes to the organization of information, as well as regulatory requirement updates and additional definitions are part of the draft.

New or clarified definitions are provided for “IM” and “IMO-type” Continue Reading…

DOT 49 CFR USA
Updates to PHMSA HM-218H – New Compliance Dates

Winston Churchill and the 49 CFR

As a former high school science teacher, I had a few choice quotes posted around my classroom.  Some were motivational while others were thought provoking. One of my favorites was by Winston Churchill.

“All men make mistakes, but only wise men learn from their mistakes.”
-Winston Churchill

Granted I tweaked it from “men” to “people” so as not to exclude the other genders in my class. My purpose for that one was to prevent frustrations over calculations, lab results, or high school in general.

On June 2, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule on Docket No. HM-218H. That docket number had some as miscellaneous amendments to Hazardous Materials Regulations. Now, two years later we have a corrective rulemaking to HM-218H. Published on June 18, 2018 with an effective date of July 18 and compliance date of September 17, it addresses some appeals and comments to that previous rulemaking. Let’s see what changed or was corrected.

Updated/Changed Sections

  • 604 Emergency Response. Emergency response telephone numbers must be displayed in numerical format only. A shipper is no longer allowed to use alphanumeric phone numbers for the emergency response number. For example, 1-800 CLEAN IT is no longer an acceptable emergency response phone number. It must be listed as 1-800-253-2648 going forward. No enforcement actions will be taken from July 5, 2016 to Continue Reading…
TDG
Transport Canada Moves to Update ERAP Requirements

TDG Update - Man Staring in to warehouse

TDG Emergency Response Assistance Plans (ERAP) Update

On June 30, 2018, Transport Canada issued a proposed amendment to Part 7 of the Transportation of Dangerous Goods Regulations (TDG). This part covers the requirements for Emergency Response Assistance Plans, or ERAPs. Details can be found on Government of Canada’s website.

Canada’s ERAP requirements are unique, not being adopted from the UN Recommendations on the Transport of Dangerous Goods. Essentially, they require consignor of significant amounts of high risk dangerous goods to establish a specific protocol, often involving an on-call response team, that can assist local responders in case of a release. Transport Canada must review and approve the plan before the consignor can offer or import affected shipments (although the approval only has to be issued once.) Since the Lac-Mégantic disaster in 2013, improving ERAP requirements has been a particular concern of Transport Canada’s.

The June amendment has four main goals:

  1. To clarify how an ERAP should be implemented;
  2. To enhance emergency preparedness and response;
  3. To reduce the regulatory burden for those affected by the requirement; and
  4. To make some general “housekeeping” changes to keep all parts of the regulations harmonized.

Clarifying Implementation of ERAPs

Currently, the regulations are unclear as to how exactly an ERAP would be implemented – presumably it would be by emergency responders or by the person with control of the released material, but it’s never been Continue Reading…

Radioactive
Class 7 IAEA Regulatory Update – SSR-6 Rev. 1, June 2018

Radioactive material warning sign at the package

Regulations for the Safe Transport of Radioactive Material

– Specific Safety Requirements No. SSR-6 (Rev. 1)

As expected, the IAEA has published the 2018 amendment to SSR-6 as Revision 1 (SSR-6).

This Revision removes the term “radiation level” from Section 2 “Definitions,” replacing it by “dose rate” to designate the dose equivalent per unit time (e.g. mSv/h). The associated changes to sections referencing the term throughout the document account for many of the other paragraph (para.) changes.

Also deleted from this edition are the requirements for testing LSA-III material for residual water activity below 0.1 A2 in the 7-day leachate test.

Table 2 “Basic Radionuclide Values” has been updated to include entries for:
Ba-135m, Ge-69, Ir-193m, Ni-57, Sr-83, Tb-149 and Tb-161.

Enter SCO-III

Perhaps the most significant change is the expansion of surface contaminated objects (SCO – “a solid object that is not itself radioactive but which has radioactive material distributed on its surface”) to add SCO-III provisions in the regulation. The Table 1 list of UN numbers, proper shipping names and descriptions now includes SCO-III to SCO-I and SCO-II for UN2913.

In addition to meeting the general requirements for the SCO designation, SCO-III objects are defined in para. 413(c) as a large solid object that is too large to be transported in the type of package described in SSR-6. There are other criteria to be met regarding sealing of openings, insides being as dry Continue Reading…

Environmental Update
EPA e-Manifests Open to Waste Generators

Using computer near truck

Are You Ready for e-Manifests?

Paperwork – it’s one of the worst parts of dealing with hazardous waste shipments. In both Canada and the United States, hazardous wastes require a special document, the Waste Manifest that will not only serve as the transportation document for the dangerous goods/hazardous materials transportation regulations, but also allow environmental authorities to track the waste from the generator, who sends it for disposal, through the hands of the carrier, to the end receiver (in the US referred to as a TSDF, for Hazardous Waste Treatment, Storage and Disposal Facility).

In Canada, some jurisdictions have eased the burden by allowing the waste manifest to be created electronically. For example, in Ontario, the HWIN system has been used for years. However, until now, the United States has not had a system for electronic documentation, called e-Manifests. On June 30, 2018, that has changed.

The change has been a long time coming. Although the initial proposal by the Environmental Protection Agency (EPA) was made in 2001, it was not until 2012 that Congress passed the “Hazardous Waste Electronic Manifest Establishment Act.” Under the Act, a final rule was published in 2014 that approved the use of such manifests. Since then, the EPA has been working to create an online system that will allow the e-manifest to eliminate substantial chunks of the burden of manifests, as well as Continue Reading…

3D rendered IBC
New ASTM Standard for IBCs

Neatly stacked IBCs

ASTM IBC Standards

Recently I wrote a blog about our boxes meeting ASTM standards. For those that weren’t aware, I described ASTM International as an international standards organization that develops and publishes voluntary technical standards for a wide range of products including packaging. In addition to providing standards in the development of corrugated boxes, ASTM can provide guidance in testing hazardous materials packaging, specifically in this case hydrostatic testing of Intermediate Bulk Containers.

Hydrostatic Testing for IBCs is outlined in 49 CFR §178.803 and §178.814.

This states:

The hydrostatic pressure test must be conducted for the qualification of all metal, rigid plastic, and composite IBC design types intended to contain solids that are loaded or discharged under pressure or intended to contain liquids.

However, the current regulations have been described as “limited” on the specific details of how to perform the test. (See video below)

This guide provides the detail on how to conduct pressure testing on IBCs and will provide a more consistent process for container manufacturers, testing labs, and regulatory agencies. The new standard will thus help manufacturers pass performance tests and qualify their container designs to meet requirements of the U.S. Department of Transportation’s Title 49 Code of Federal Regulations as well as the United Nations recommendations on the transport of dangerous goods. The new standard will be published as ASTM D8134 and the scope is listed below:

Scope

Help Make the ERG Better

Emergency Response Guidebook

Calling All ERG Users

Many have heard the phrase, “Calling all cars” used in an emergency situation. The phrase references back to the old police radio days. It was used to call all patrol cars to help other officers. The phrase was the title for an old radio show back in the 1930’s, but also more recently as an episode of HBO’s “The Sopranos”.

How is that phrase being used here? The Pipeline and Hazardous Materials Safety Administration (PHMSA) has put out the call for input on ways to improve the Emergency Response Guidebook, or ERG. The new version is due for publication in 2020. To see the full notice go to https://www.gpo.gov/fdsys/pkg/FR-2018-05-23/pdf/2018-11055.pdf

What is the ERG?

It is a booklet that provides technical information and advice for those responding to emergencies involving hazardous materials as defined in 49 CFR. It is used mainly by emergency personnel such as police, fire-fighters, paramedics or other emergency responders. First issued in 1973, PHMSA’s goal is for all emergency response folks to have immediate access to it. As time has progressed there is a free online version and a downloadable app. Other countries may also have their own versions of the ERG. It is updated every 4 years.

It is broken down by the following color-coded sections:

  • White pages – At the start of the booklet, gives the instructions for how to use it and Continue Reading…