ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 1

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Placarding Bulk Truckloads

Q. My truck has 4000kgs of drums of Class 3 UN1993 in it. Truck has Class 3 UN1993 placard on it . We pick up 1 empty tote (IBC) which is Class 3 UN1993 also. Can we keep the same placard on the truck or do we need to add Class 3 only? Same with empty drums. We just need to add primary CLASS card? All transported via ground within Canada.
A.Well the drums don’t need UN numbered placards since drums are considered small means of containment. A plain class 3 placard will do to represent the drums. It used to be in the Regulations that over 4000kg from one shipper could display UN numbered placard but it was repealed recently. Totes, even empty with residue, requires UN numbered placards for liquids in direct contact with the means of containment. You don’t need to add plain class 3 placard for the drums as both the drum and tote content is hazard class 3. So technically the truck displayed the correct placard (UN1993). If the drums were empty and less than 500kg gross mass then no placard will be required; however, if you Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: Sept 24

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Limited Quantity from Canada to the USA

Q: I ship my material as a limited quantity under TDG in Canada. What do I need to do to ship it to customers in the US? We are also considering opening a hub in the US.
A: You will have to receive training in 49 CFR. Even though there are many similarities between the 2 regulations they are not exact matches. You may be able to use some reciprocity agreements in regards to transborder shipments. A hub based in the US will definitely have to have 49 CFR training.

New testing, now what?

Q: We just ran some testing on one of our products. It has been shipped as UN2468 in the past. However, the test report O.1 came back and said our material is not an oxidizer. What does that mean for the next time we ship the product?
A: If you have proof that your product is no longer a hazardous material, then you do not have to ship it as such. It does not meet the classification criteria set out in 49 CFR starting in §173.50.

TDG wallet card requirements

Q: I have worked with a courier company for Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk Sept 17

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Is Paperwork Required for my Shipment? (TDG)

Q: Do I need to send paperwork to ship a class 2.2 empty oxygen cylinder through ground in Canada?
A: The TDGR 2.14(b) classifies a compressed gas as Division 2.2 if it has no other hazard class properties and has an absolute pressure less than 280 kPa at 20O C. Thus, if the cylinder only contained a Class 2.2 gas without other subsidiary hazards and the pressure is now below 179 kPa gauge, then it’s not DG and the regulations don’t apply. This means that the Class 2.2 labels must be removed.

How do I ship a product that is regulated by DOT, but is not regulated by IMDG?

Q: Can you please help me with the following?
  • HazMat is Class 3 Combustible Liquid w/i U.S. (fp of 168 F).
  • It is shipped in IBC (bulk packaging) and non-bulk.
  • If to be shipped by vessel in an IBC it would be a Class 3 Combustible Liquid per US DOT but not a Class 3 per IMDG.
How would one ship this HazMat in a bulk packaging by vessel when it must first be transported by highway to reach the port? If shipped as Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: Sept 3

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Lithium Battery Label (Ion/Metal)

Q: On the old lithium battery handling label, can I use an Avery address label for the words ion and/or metal?
A: What you propose is not the best option for lithium battery label. However, if it is your only option, then you most definitely will need to cover the Avery label with strong, clear packaging tape.  Regular old scotch tape won’t do as it won’t stand up to the durability requirements.

Adding an SDS to Your Shipment

Q: Do I have to put the SDS on each one of my hazmat boxes?
A: Technically, an SDS is not required to be attached to any packages.  Your carrier may request this though. If the SDS is being used as the “written emergency response information” required under 49 CFR and the US variation in IATA, then it should be with the shipping papers/declaration and not on the packages.

How Many Lithium Batteries Can Go in a Box?

Q: I have 4 pieces of equipment that are being shipped. Each has its own lithium metal battery inside a plastic bag. So, this is UN 3091 packed with equipment. The lithium content on each battery is 0.28 grams and Continue Reading…
Safety Data Sheets (SDS)
Should You Use CANUTEC as Your 24-Hour Number on Your SDS?
Compliant SDSs

SDS Requirements

Safety Data Sheets (SDSs) have been an important tool for worker safety for decades. In Canada, they became mandatory for hazardous materials in 1988, and although their basic format has been modified by WHMIS 2015 (the Workplace Hazardous Materials Information System 2015), one constant has always been a heading for “emergency telephone number.”

This brings up the question of what number should be on the SDS. Yes, it’s possible to run the emergency number internally, but most companies don’t use this solution. First, if you’re using it for transportation purposes, the law requires that the number be staffed 24 hours a day. Even if you have staff to do that, they must be trained to give effective advice over the telephone. That can be a difficult job, and requires professionals with both technical knowledge and the ability to remain calm in emergencies. Therefore, most companies these days outsource this function to specialist services.

Having a direct line to a live, knowledgeable person can be a true lifesaver in an emergency. Early in my training days, a customer told how he’d been given the job, late at night, of cleaning out a tank of chemicals by siphoning them into a waste container. In those days, safety standards were sometimes lax, and he was taught to start the siphon by mouth. Unfortunately, he was distracted during the procedure and ended Continue Reading…

Black steel drums
What Does that Word Mean? (Chime)

Blue Hazmat Drums

Updated Training

ICC Compliance Center constantly evaluates our courses to be sure they are the most up-to-date with current versions of the regulations.  Our Regulatory Team works hard to make sure the information we get you is complete and correct. In that regard, I am in the process of revising and updating our course on shipping reduced amounts of materials. It will focus on the options outlined in the US 49 CFR and the IATA regulation. We are talking about a focused course on the topics of small quantities, excepted quantities, limited quantities and consumer commodities.

During the course of the update, I came across an odd word in regards to drums under the Excepted Quantities exception. It was one not familiar to me at all even after 10 years of being in the “business.” Of course, my first thought was to look in the definitions or glossary section of the regulations. It wasn’t there. Then I tried to Google it. No luck. At this point, it was time to reach out to the Team. Sure enough, within minutes there was the answer and even where I could find it for future reference.

Defining “Chime”

What was the word? It was the word “chime.” In both 49 CFR and IATA for Excepted Quantities is the package test requirement that must be met for drums. It says that when the package is in the shape of Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: July 30

IBC Residue, Choosing Placards, IATA Special Provisions, and Hazard Class Label Size

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.

Residue in IBCs (TDG)

Q. Under TDG, do Intermediate Bulk Containers (IBCs) such as tote tanks that contain residues still have to be transported as dangerous goods? Should the placards remain or be removed?
A. Under TDG, packagings or containers that still contain enough residue to pose a hazard during transportation should still be treated as dangerous goods. Unfortunately, the regulations do not give a specific way of judging this, so they should be considered hazardous unless you are absolutely sure they are not. (There is some misinformation that you may come across about how to make this decision. TDG does not specify “triple-rinsing” as a standard for cleaning or declare that an inch or less of residue can be considered non-dangerous. These references may come from other regulations or industry guidelines, but do not apply to TDG.)

So, if your IBC contains a dangerous residue, it should be clearly identified as such for transportation. If it was originally placarded or labelled correctly, just leave those Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: July 9

Segregation Group, Passenger Vehicles, Classification Leachate, Verify DG Certificate, and Class 6.1 Subsidiary

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.

Segregation Group (IMDG)

Q. My carrier is asking for a segregation group number for my dangerous goods, but there is no entry in the IMDG Code (Column 16b). What should I provide?
A. Despite there not being an assigned code, you should review IMDG Code 7.2.5 that section says that a review of your product SDS (or similar document) may be indicated. Communication of product-specific considerations may be appreciated by the carrier even if they don’t trigger IMDG Code Chapter 7.1 or 7.2 specific segregation requirements.

Passenger Vehicles

Q. Does the fact that our salespeople use passenger vehicles to deliver samples to potential customers prohibit them from transporting things that are “forbidden” for transport in passenger-carrying vehicles?
A. No. If the requirements under the definition of “passenger” (e.g. doesn’t apply to an employee on duty), and any special case/provision restrictions, are met then the prohibition is not being violated. When checking term definitions in TDG, always verify any words in bold type. This means they also have definitions which Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 25

Carrier Variations, WHMIS vs. OSHA, Placarding, Lithium Batteries and More Lithium Batteries

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.

Carrier Variations

Q. Can you help me understand what I did wrong or how to respond to them?

DHL is the carrier for my product. It is UN3077 and it is packaged 25 kg per fiberboard box. They sent me the following comments regarding my shipment.

They told me the country of USA must be a part of my address on the shipper’s declaration. They also said I had to use PI 956 even though it is marked and labeled as a limited quantity shipment. Finally, they told me I had to include the place and title on the shipper’s declaration.

A. First of all, carriers can ask for things beyond what is in the regulations. Sadly, you must comply with their requests if you want your shipment to proceed. Having said that there are a few things about your points that I can provide some regulatory framework for should you choose to push the issue with them. As to the country of USA being required, the IATA regulations never Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 11

Segregating Flammable Gas and Explosives, WHMIS/OSHA Labeling, Lithium Batteries, Orientation Marks, and Net vs Gross

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

WHMIS/OSHA labeling

Q. Is a WHMIS 2015 compliant label going to be compliant within OSHA HazCom2012?
A. Maybe. While both the Canadian and US version of the GHS are very similar there are some differences in phrases used in regards to precautionary phrases. Also, WHMIS 2015 has the additional possibility of classifying something as a biohazard that is not found in the US standard. The best course of action would be for ICC to review your label for compliance within the 2 regulations.

Segregating Flammable Gas and Explosives (TDG)

Q. Is it okay to ship a class 2.1 dangerous good with a class 1.4 explosive in the same box shipping ground in Canada?
A. While the TDG and TP14850 do not have a segregation table, TP14850 12.89 states that Dangerous goods must not be offered for transport together with other dangerous goods or non-dangerous goods in the same container or overpack if the combining of those goods could:

  1. result in an evolution of heat or gas, or produce a corrosive effect or the formation of unstable substances that could endanger the integrity of the package or overpack; or
  2. cause a Continue Reading…