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Shipping by Air? Don’t Overlook the Latest IATA Addendum

As we start our new year, one of our resolutions should be to make sure our dangerous goods shipments get where they’re going. Which means, of course, that we need to update to the 2020 edition of the Dangerous Goods Regulations (DGR) from the International Air Transport Association (IATA). But don’t rely on that completely, because as always, there will be a few corrections and additions that IATA needed to make after the book has gone to print.

In December, IATA published an addendum to the DGR which is available as a free download. These will take effect as of January 1, 2020, so they’re in effect now. The majority of the corrections and additions have to do with State and Operator variations (country variations and airline policies that apply in addition to the DGR), although some affect more general areas. To find the addendum, go to the bottom of their webpage at https://www.iata.org/en/publications/dgr/#tab-2, from where you can download the file as a .pdf in various languages.

First, let’s look at some of the significant changes that are not specific to countries or airlines.

  • In section 2.3.2.3, on shipping wheelchairs and mobility aids with spillable batteries, paragraph (c)(2) includes a corrected cross-reference.
  • A significant change has been made to several packing instructions for Class 3 liquids when shipped Cargo aircraft only. In the original versions of Packing Instructions 360 to Continue Reading…
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2020 Vision or Still Blurry for Lithium Battery Shippers?

The title says it all, can you see clearly when you ship lithium batteries, or are the waters still a little murky? If it is the former rather than the latter for you, that may change as Amazon has announced new global FBA requirements for all lithium batteries and products which contain lithium batteries. A Lithium Battery Test Summary will now need to be uploaded to Amazon, starting this past 1st of January 2020. This new rule will affect those who sell a variety of products, from watches to smartphones to toys. This type of change is not only exclusive to Amazon, as IATA and IMDG Code will now also be enforcing a new regulation that requires the test summary for the lithium battery/cells to be made available throughout the entire distribution network. 

What is the Test?

Lithium cells and batteries that are manufactured after June 30, 2003, and equipment powered by those cells and batteries have to be tested in accordance with the UN Manual of Test and Criteria Part III, Section 38.3. If the testing passes, the test facility provides a summary certificate to the manufacturer that confirms that the cells or batteries meet an international standard and can be shipped around the world in accordance with the appropriate regulations. The test standard includes eight tests total: Altitude Simulation; Thermal Test; Vibration; Shock; External Short Circuit; Continue Reading…

Complacency of Own Safety During Air Travel

As a former member of the Canadian Armed forces, I have always tried my best to keep keenly aware of any possible hazards/dangers that could affect me, my family, or others. I have never been one to stand by idly and say nothing or do nothing. I have noticed a trend developing lately in air travelers where it seems the majority are seemly unaware or oblivious of safety regulations and the reasons why some rules even exist.

I remember as a teenager embarking on my first flight in the mid-1980s being very attentive to all demonstrations; looking at every exit; observing every rule. It was easily noted that every traveler was watching the hand gestures of the flight attendant, knowing where our life jackets were, and again knowing the location of the nearest exit. But, as air travel safety has improved it seems complacency has increased. I have noticed hardly anyone listens to the flight safety briefing anymore as they are more preoccupied with taking their shoes off and looking at their phones.

Here are a couple of rules that exist and why:

NO lithium batteries in checked baggage
It is imperative to not check any lithium batteries in your luggage. If a lithium battery in your electronic device fails, thermal runaway occurs. The heat at which it will burn will melt aluminum which is what aircrafts are made of. Continue Reading…

ICC’s 2020 Regulatory Resolutions

Here it is – January 2020.  The time when all holiday decorations are put away and people make resolutions for the coming year.  Things we would like to change about ourselves, our workplace or our home.  We’ve all heard them.  I’m going to work out more.  There will be more family time.  We will eat healthier.  I’ll be kinder to my co-workers.  That one is mine in case you were wondering. 

Now at this point you are asking how does resolution making have anything to do with transportation of dangerous goods?  Well, I asked our Regulatory Team what their “regulatory resolutions” would be.  In other words, if they had the power, what changes or resolutions would they make to a regulation.  Oddly enough, with their responses, not a single regulation escaped a “resolution”!  Some of the items listed below were mentioned on more than one person’s list.

49 CFR:

  • Resolve to get rid of the combustible liquids.No one else in the world regulates these.
  • All lithium batteries should be transported as fully regulated with UN Specification Packaging and paperwork.No more exceptions. 
  • Resolve to adjust the packaging recertification requirements.Align them more with Canada’s.  As long as the components and specifications do not change there should be no need to re-test UN packaging every 2 years.  49 CFR should allow packaging manufacturer’s to simply send in an application for certification every 5 Continue Reading…
ICC Top 10 List
2019 Top Ten OSHA Violations

Top Ten lists are often the topic of very enjoyable discussions. Whether its movies, music, sports teams, or restaurants. However some top ten lists aren’t based on entertainment value and taste, some are based on more serious topics. As the year comes to a close, the National Safety Council and the Occupational Safety and Health Administration announced the preliminary Top 10 most frequently cited workplace safety violations for the 2019 fiscal year.

Once again, Fall Protection – General Requirements is OSHA’s most frequently cited standard in the most cited violations of 2019. This makes nine years in a row that Fall Protections has topped this list. Although there is some good news with that as the number of citations for fall protection was 7,720 last year and dropped down to 6,010 for the 2019 fiscal year. The rest of the preliminary list of OSHA’s Top 10 violations for the fiscal year 2019 also remained mostly the same from last year, with only one minor change. Lockout/Tagout, which was ranked No. 5 in 2018, is now No. 4, switching places with Respiratory Protection. Below is the 2019 most cited violations per OSHA.

  1. Fall Protection – General Requirements (1926.501): 6,010 violations
  2. Hazard Communication (1910.1200): 3,671
  3. Scaffolding (1926.451): 2,813
  4. Lockout/Tagout (1910.147): 2,606
  5. Respiratory Protection (1910.134): 2,450
  6. Ladders (1926.1053): 2,345
  7. Powered Industrial Trucks (1910.178): 2,093
  8. Fall Protection – Training Requirements (1926.503): 1,773
  9. Machine Guarding (1910.212): 1,743
  10. Personal Protective and Lifesaving Equipment – Eye Continue Reading…
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Training … the necessary evil of TDG – Part 3

Hello everyone. I’m back with the subject of TDG training. In my last blog, we made it clear who has responsibility for a list of the most important elements. We used the sections of the Canadian TDG Regulations for each part stating the implications of the various stakeholders.

Now, in order to fully understand what TDG requires as training, we will discuss what is the normal duration for a TDG training that would provide you with adequate skills and especially training applicable to your responsibilities.

It should be noted that the primary purpose of Part 6 of the TDG (article 6.2) is to ensure that the person has a solid knowledge of all of the topics listed in paragraphs (a) to (m) that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport.

It is important to clarify here that Transport Canada does not define clearly or exactly what training should contain. TDG leaves much room for the interpretation of what constitutes appropriate training, and it remains the responsibility of the company to establish this.

For this reason, we will be discussing a training standard in the industry and it is equally important to believe that if a training facility declares that it is certified by the government or any other departmental entity that this is completely false. Continue Reading…

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Training … the necessary evil of TDG – Part 2

Hello everyone and welcome back! In my last blog, we made it clear who needs to be trained by using the definitions available to us in the Canadian TDG Regulations. Now, let’s try to properly interpret what TDG requires as training. It should be noted that the primary purpose of TDG regulations is the safety of dangerous goods in transport and to achieve an acceptable level of safety, it is, of course, essential that the persons managing dangerous goods in transport have adequate competency. To do this, in Part 6 of the TDG, the Regulations clearly state that any person who handles, offers for transport, or transports dangerous goods must have appropriate training and hold a training certificate. To fully understand what constitutes appropriate training, we must refer to article 6.2 and this article states that a person must have a solid knowledge of all the listed topics as well as the dangerous goods that he is called to handle, transport or offer for transport.

Let’s try to understand these topics that are specified and for each of the points, I will name who is responsible under the TDG.

  • Classification from Part 2 of the TDG. What does classification mean? This consists of defining whether your product meets the characteristics of a dangerous good included in one or more of the 9 hazard classes.
    Person responsible for this Continue Reading…
Environmental Update
Proposition 65 List Update for 2019

Here is one more blog in support of knowing it is autumn even though the weather may not feel like it.  The Office of Environmental Health and Hazard Assessment (OEHHA) in California just published a revised list.  If you aren’t familiar with the OEHHA, you likely do know about California’s Proposition 65 list.  As per usual, the list has changed a few times over the course of the year. 

To refresh your memory, the Safe Drinking Water and Toxic Enforcement Act of 1986 is the official name for California’s Proposition 65.  The list has to be revised and republished at least once per year.  California’s Office of Environmental Health Hazard Assessment (OEHHA) is the agency responsible for the implementation.  Chemicals are added or removed from the list when some other “authoritative body” makes a determination regarding a substances ability to cause cancer, birth defects, or other reproductive harm.

Shown below are all of the new substances that were added and or removed by month. They are listed by name, type of toxicity, and Chemical Abstracts Service Registry Number (CAS).  Now would be a good time to see not only if you are up to date on the new required “warnings” but if any of your products or substances were added to the new list.

Proposition 65 – Additions and Deletions

March 2019

Recalled Macbook Pro Laptops – Prohibited on US Flights

If you were planning on watching your favorite movie or a TV show on your Macbook Pro on your next flight well instead you may need to take a book.

Following Apple’s recall in June 2019 for certain 15-inch Macbook Pro laptops sold between September 2015 to February 2017, the US Federal Aviation Administration (FAA) has announced that effectively immediately these laptops are prohibited on all US commercial fights.  This isn’t a new regulation but rather a reminder of already existing regulations which bans recalled lithium batteries and lithium battery powered devices for air carriers.  These Macbook pros contain lithium batteries which may overheat and pose a fire safety risk. This restriction applies to both carry-on and checked in luggage.

Ensure you check your Macbook Pro model to confirm you are not in the recall group.

For more information, visit ICC Compliance Center’s website or call one of our Regulatory Specialists today! USA: 888-442-9628 | Canada: 888-977-4834

Taking Part in the BC Provincial CVSA Challenge

In June of this year, I was invited to participate in the Commercial Vehicle Safety and Enforcement (CVSE) Inspectors Commercial Vehicle Safety Alliance (CVSA) Challenge in Surrey, BC, Canada as a judge. I know it doesn’t sound fun but honestly, it was awesome.

The challenge was over a 3-day period and the competitors were seven (7) very qualified CVSE inspectors from all over BC to test their skills and knowledge. The winner from this competition would go on to compete in the North American Inspectors Championship (NAIC) in Pittsburgh, PA, USA. The NAIC includes the best of the best inspectors from Canada, the United States and Mexico competing for the title of Grand Champion. This is some serious stuff and of course, comes with bragging rights!

For the provincial competition, the competitors first have to write a series of qualifying exams, which advances them to the provincial competition. This year’s competition consisted of driver interview, dangerous goods cargo tank inspection, coach bus inspection, and dangerous goods packaging inspection. 

I came in as a judge for the dangerous goods inspections. We provided some of the dangerous goods packaging with “compliance issues”. That was fun for me. I got to make dangerous goods stuff incorrect on purpose for once. 

A few incompliance issues that I added: 

  • put primary and subsidiary hazard labels on opposite sides of the package, 
  • left out the telephone number on Continue Reading…