Or: “When I use a word,” Humpty Dumpty said, … “it means just what I choose it to mean …”
Lewis Carrol “Through the Looking Glass” in Bartleby’s “A Dictionary of Quotations”: http://www.bartleby.com/73/2019.html
Health Canada provided an FAQ presentation at a recent CIC (Current Issues Committee) meeting that may provide a useful lead in to the more detailed Guidance document published in December 2016.
The latter, “Technical Guidance on the Requirements of the Hazardous Products Act & Hazardous Products Regulations – WHMIS 2015 Supplier Requirements”, provides (at 540 pages) a detailed review of the content of the law and various aspects of guidance/interpretation. This document is available for download at:
The length of the document may be daunting to the casual user, so the FAQ presentation attempts to present Health Canada’s position on items that are of current concern.
The CIC is a multi-representative committee that meets several times a year to review, as it’s name implies, issues that can be improved to increase the effectiveness of WHMIS in helping to protect workers. Currently there are representatives from various government levels (Federal/Provincial/Territorial), Health & Safety organizations (e.g. CCOHS), industry organizations (e.g. RDC, CIAC, etc.) and Labour (CLC, Unifor, etc.).
One aspect of the International Harmonization amendment (SOR/2017-137) of the Canadian Transportation of Dangerous Goods Regulations (TDGR) that did not receive a lot of attention is the change in Special Provision 23. This special provision (SP) deals with the assignment of markings on containers and descriptions on shipping documents for entries related to goods which exhibit inhalation toxicity. Although the basic concept for classification remains the same- i.e. gases in Class 2.3 and Class 6.1 with associated inhalation toxicity. The majority of the latter are in PG I, but there are several PG II entries invoking SP23).
Marking – Keep It Simple?
A significant difference is the change in wording applied to means of containment (MoC). Following the transition period, markings required under SP23 must read “inhalation hazard” for all entries except UN 1005 (anhydrous ammonia). This eliminates the previous options of either “toxic by inhalation” or “toxic-inhalation hazard” (TBI or TIH).
UN1005 retains the previous wording “Anhydrous Ammonia, Inhalation Hazard” when the option of using the ammonia placard (rather than Class 2.3) is chosen. However small MoC of UN1005 will use the standard Class 2.3 label and “inhalation hazard” wording.
As the video above shows, you never know how the pressure change on an airplane will affect our sealed containers. From exploding shaving cream cans in checked luggage, to scattered potato chips at our feet on the floor of an airplane, the unpredictability of a high altitude can certainly cause its share of messes. Aside from having to do laundry while on your vacation, these examples are relatively mild. In the world of shipping dangerous goods, the consequences can be far more severe. For this reason when shipping hazardous liquids by air, our single and inner packaging must pass a hydrostatic pressure test that essentially ensures the pressure differential at high altitudes will not cause a disaster mid-air. You may ask, what is hydrostatic pressure and how is it measured?
What is Hydrostatic Pressure?
Hydrostatic pressure is the pressure exerted by a fluid at equilibrium at a given point within the fluid, due to the force of gravity. For the purpose of shipping dangerous goods, this is measured in kPa or Kilopascal. When you see a UN Marking on a single package it usually looks something like this 1H1/Y1.8/100. The “100” is referencing the maximum hydrostatic pressure this Continue Reading…
It seemed such a simple task at the time. A company decided to expand their consumer product line to include perfumes. They expected to send orders to customers, as they did their other products, by airmail. Yet, when setting up the shipment, an unexpected roadblock appeared. The U.S. Postal Service (USPS) told them that the perfume was a hazardous material.
How can a common consumer product like perfume be hazardous for transportation? Most perfumes have an alcohol base, designed to evaporate quickly leaving the scent behind. Unfortunately, this means that such perfumes are flammable liquids for transportation and are subject to Department of Transportation (DOT) as well as USPS restrictions for both ground and air transport.
So, the decision to go into perfumes created some major headaches for the company. But they recently got some good news. If the perfume is based on ethanol, one of the most common alcohols, the company will get a break – USPS has reduced the requirements for this one solvent. Ethanol, or ethyl alcohol, can be found in many consumer products, ranging from perfumes to hairspray to bath oil. By reducing the requirements for shipment of these products, shippers will enjoy reduced costs and complexity.
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.
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.
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.
Determining which of your consumer chemical products would require a GHS Safety Data Sheet (SDS), can sometimes be difficult and confusing. Which products actually do need to have compliant SDS, can differ depending on which country/region you are in, and how the product is being used.
In Canada, chemical products that are labeled, packaged, and sold at retail outlets as consumer products, are regulated by the Canadian Consumer Product Safety Act (CCPSA), and the Consumer Chemicals and Containers Regulations 2001 (CCCR 2001). Examples of ‘retail’ outlets are stores such as Canadian Tire, Home Depot, Rona, and corner gas stations that anyone off the street can walk into and buy chemical products in, etc.
Chemical products, which are intended for use in worksites and not sold at retail outlets, on the other hand, are regulated by the Hazardous Products Act (HPA) and Hazardous Products Regulations (HPR, or “WHMIS 2015“). It is the HPA and HPR (WHMIS 2015), where GHS SDS requirements are found, while the CCPSA and CCCR 2001 do not currently contain any SDS requirements at all.
In the HPA, in Part II, Section 12(j) and Schedule 1, CCPSA consumer products are actually excluded from the application of the Continue Reading…
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.
Retention of Shipping Papers: In IATA, the retention of documentation is found in Section 22.214.171.124. 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.
Use of Technical Names: Entries in the blue pages listed with a star (*) symbol tells the shipper a technical name is needed. Section 126.96.36.199(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 Continue Reading…
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” Continue Reading…
On April 28, 2017, IDC Technologies held their second Dangerous Goods Conference in Mississauga, Ontario. Two of our regulatory staff from ICC were among the presenters during a day of informative sessions that covered transportation, environmental, and safety aspects of the Transportation of Dangerous Goods Regulations (TDG).
ICC Regulatory Consultant Clifton Brown presented his study of the effect the current lithium battery regulations are having on air safety, with a look over the history of accidents involving these batteries since they were first introduced in the early 1990s. Clifton did a lot of sifting through reports from government and industry sources to conclude that the regulations on lithium batteries have a way to go to make them a negligible hazard. Perhaps by the time they are, we’ll have invented safer methods of energy storage.
I presented an overview of the Globally Harmonized System (GHS) changes to health and safety regulations, and whether the GHS Purple Book has achieved worthwhile harmonization in the same way as the UN Recommendations on the Transport of Dangerous Goods (the Orange Book). Unfortunately, we’ll have to deal with a lot of disharmonization remaining in the short Continue Reading…
Language, as defined by the Merriam-Webster dictionary, is the formal system of words or signs that people use to express thoughts and feelings. Learning a new language is often a complex undertaking. It is also a time that lends itself to funny stories. While living in Austria for a few years taking German lessons was part of our visa process. We were encouraged to practice often. On one of my first attempts was to buy a certain pretzel. Somehow my request came out as asking for the “slow one” rather than the “long one”. My husband told a co-worker he “believed” he was a pencil. While neither request caused harm, it was confusing to the German speakers who heard us. I mention this because the language of transport regulations can be confusing as well until you have a good handle on the language used in them.
Let’s take a look at two simple words. We will compare their “everyday” usage with how they are used for transporting hazardous materials or dangerous goods. The two words will be “should” and “may”.
Word #1: Should
In normal usage, this word indicates certain obligations or expectations. Take for example the statement, “John should be ready Continue Reading…