TDG
New Draft: CGSB Standard 43.145

Man preparing shipment

TDG Large Packaging

Still Time to Review the draft “Design, Manufacture and Use of Large Packaging for Transportation of Dangerous Goods in Classes 3, 4, 5, 6.1, 8 and 9

Transport Canada provided notice last month of the availability of a draft Canadian General Standards Board (CGSB) standard for large packagings for specified classes of dangerous goods (DG). The contents of the draft are largely based on the UN “Recommendations on the Transport of Dangerous Goods Model Regulations” (UN TDG Model) 20th Edition.

The draft is open for comment by interested parties until June 8, 2018.

Similar, but Not Identical

Although the current draft is based on the 20th edition of the UN Model, there are some differences – for example: the Canadian TDG regulations (TDGR) have not yet updated Schedule 1 to the current UN numbers above UN3534; TDGR cite Class-specific standards for certain DG (Classes 1, 2, 6); and not all of the lithium battery packaging has been incorporated.

The CGSB-43.145 proposal does, however, contain a supplementary instruction for UN2794 and UN2795 permitting these batteries to be shipped unpackaged on shelving that is permanently fixed within a vehicle. This LP801 standard presumably replaces equivalency certificates providing the option to battery distributers and members of automotive industry associations.

The UN Model and CGSB 43.145 are similar in restricting the use of large packaging to the lesser hazardous Classes/Divisions, typically at the packing Continue Reading…

Repacking Dangerous Goods
Can I Ship Dangerous Goods to Brazil with my TDG Training Certificate?

Calcium Oxide UN1910 UN Packaging

The answer is: No.

Shipping Dangerous Goods from Canada to Brazil

Now the Background Story

I was forwarded an email from a very nice lady (let’s call her Jane), who is registered to take our public TDG training coming up in a couple of weeks at our Delta, B.C. office.

She said she has some product that needs to be shipped to Brazil, which she was told was dangerous goods. Jane wanted to know if we sell corrosive labels and if we can do up the dangerous goods document or if she would be able to do it herself after she takes her training. I asked Jane to call me; sometimes it is just easier to talk on the phone.

Training or Repacking?

While on a call I asked her if she is taking our public air (IATA) training and she said, “No. Just the TDG“. I explained to Jane that by completing the TDG training she will be certified to ship, handle, transport, and import dangerous goods within Canada via road, rail, and domestic marine; therefore, even after she takes her TDG training she can’t ship dangerous goods to Brazil.

After clarifying this with her I advised that if she wants to ship this product to Brazil she will need to either take an air training course or use our repackaging service.

I provided her with a repackaging quote and explained, “this is Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 2

How to determine if a product is regulated, SAPT on a SDS, Shipping a drone, and using a UN package

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 my product regulated?

Q. I have 2 products I distribute to various stores to sell. The SDS files say my product is not regulated under DOT and TDG in Section 14. Since this is sold as a consumer product, doesn’t that mean it is regulated for IATA should I ship it via air? (the SDS were emailed to me)
A. Nothing in your SDS files leads me to believe either one would meet any of the 9 hazard classes in IATA. This is further confirmed by neither SDS classifying the products for DOT and TDG. Basically, what you have are containers of non-regulated liquids.  There is no need for UN Specification packaging or paperwork for IATA or any other transport regulation.

SAPT on my SDS

A. Since the addition of UN numbers for polymerizing substances, we’ve been told we must include the Self-Accelerated Polymerization Temperature (SAPT) on our SDS documents in Section 9. Is this a new requirement?
Q. There is no requirement in OSHA HazCom 2012 to include that particular data point in Section 9. All of the Continue Reading…
dangerous goods forms, IATA, IMDG, 49 CFR, TDG documentation
How to Document Weights on DG/HazMat Transport Paperwork

Dangerous goods and hazmat forms

IATA, IMO, 49 CFR, & TDG Documentation

No one wants to talk about their weight. Ever. In the world of transport though, you have no choice. You are required to list on your transport paperwork some sort of weight, mass, or volume. The trick is to know which regulation requires what. Should be the net weight or gross weight? Is it per package or per packaging? Sadly, depending on the regulation, the answers to those questions may differ.

Before getting started, be sure you understand what all of those terms mean. I tend to default to the IATA regulations when it comes to definitions. These are found in Appendix A. Take note that these terms are also defined in the other regulations, too. In 49 CFR check in §171.9. For IMDG they are in 2 places – Volume 1, Chapter 1.2 and Volume 2, Appendix B. TDG defines them Part 1.4.

Definitions:

Package
The complete product of the packing operation consisting of the packaging and the contents prepared for transport.
Packaging
A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.
Means of containment
(in TDG) a container or packaging or any part of a means of transport that is or may be used to contain goods.
Means of transport
(in TDG) a road or railway vehicle, aircraft, vessel, pipeline or any other contrivance that is or may be used Continue Reading…
Square on point with x marked out
Symbols in Transportation Regulations

Symbols in the IATA, IMDG, and 49 CFR

Solving the Mystery of the Regulation Symbols

As an avid reader and science nerd, the author Dan Brown is a different type of read. His lead character, Dr. Robert Langdon, is a professor of symbology. This means he studies and understands various symbols found in history and codes. Sometimes in transportation, we must be our own Dr. Langdon to decipher what the regulations are trying to tell us.

Here are some of the common symbols you could see with their meanings. Also included is where in each regulation you can find further information. By the way, have you purchased the March 2018 version of 49 CFR?

Symbols in IATA and IMDG:

  1. ■ The square: This symbol tells us new material has been added to the regulation or edition.
  2. ▲ The triangle: Here it indicates some part of that section of the regulation changed in some way.  It could be as simple as one word, sentence, or entire section that was reworked or clarified.
  3. ∅ The crossed-out circle: This one is a space holder showing some part or section has been removed, deleted or cancelled from the current edition. A very useful symbol, because it will keep you from looking for something that you knew was there but now can’t find.
  4. ☛ The pointing finger: Here is a symbol found only in IATA. It signifies this section or statement is more Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: March 26

Proper shipping name, 500 kg exemption, MANCOMM symbol, and a TDG error

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.

Proper Shipping Name (49 CFR)

Q. The customer wanted to know if they can print the product name in section 1 of the SDS next to the UN number on a hazard class label instead of the proper shipping name.

A. No. The proper shipping name on the outside of the box is a requirement per 49 CFR §172.301 (a) (1) and must be marked along with the UN number in a non-bulk packaging.

500 kg Exemption (TDG)

Q. Can I apply the 500 kg exemption when I have a mixed load where part of the load is excluded from using a DANGER placard under the 1000 kg Class restriction in TDGR §4.16 but the remainder is less than 500 kg gross? An example would be a consignment offered that included 1200 kg of Class 3, 100 kg of Class 8 and 300 kg of Class 9 (no ERAP required for either)?

A. In the DANGER placard scenario in 4.16, the Class 3 is restricted from using the DANGER placard specifically, based solely on quantity. Regular placarding requirements apply to the load based on the guidance text Continue Reading…

TDG Methanol Classification
Big Change in Methanol Transport Classification (TDG)

TDG Update - Man Staring in to warehouse

New Transport Canada Update Means Big Changes for Many Companies

Recently, Transport Canada posted on their FAQ web page, a few questions regarding shipping mixtures of Methanol.

The first three FAQs are for the most part, not surprising, with one exception in Question 2. These FAQ’s appear as follows (these FAQ’s are directly from their website): (keep reading, the biggest surprise is coming).

Question: How do I classify a product that contains methanol as the only dangerous good?
Answer: As per Section 2.3 of the TDG Regulations, when the name of a dangerous good is shown in Schedule 1, that name and the corresponding data for that shipping name (class, subsidiary class(es), packing group (PG)) must be used. Therefore, when methanol is the only dangerous good in the product and it meets the criteria for Class 3, Flammable Liquids, it should be transported as UN1230, METHANOL, Class 3 (6.1), PG II. Note that PG II is the only packing group available for methanol as per Schedule 1 of the TDG Regulations. Note: Subparagraph 1.3(2)(d)(iv) of the TDG Regulations allows a person to indicate the word “SOLUTION” or “MIXTURE” and also the concentration of the solution or mixture after the shipping name, as applicable.
Question: Tests results for a solution containing methanol as the only dangerous good indicate that its packing group should be III. How do I choose the proper shipping name?
Answer: Even if a dilution would lead to a Continue Reading…
TDG
March 2018 TDG TP 14877 Update

Railway Tanker Transporting Dangerous Goods

Rail TDG Standard TP 14877 Update

On March 15 Transport Canada released a notice on the intent to issue a new January 2018 edition of standard TP 14877 “Containers for Transport of Dangerous Goods by Rail” to replace the current 2013 (with Corrigendum) edition.

This is the penultimate culmination of the public process, in part arising out of the Lac Mégantic 2013 disaster, undertaken by a stakeholder Consultative Committee that began in February of 2016.

The main features of the proposed 2018 edition include:

  • Improved usability by incorporating external technical requirements, such as those in Protective Direction 34, 37 and 38.
  • Updated dangerous goods list to align with the 19th edition of the UN Model Regulations. Adjusted special provisions to reflect updated transportation requirements for Sulphuric Acid (UN1831) and Hydrogen Peroxide (UN2014 / UN2015).
  • Updated technical requirements for Class 3, Flammable Liquids and the new tank car specification known as TC 117.
  • Improved harmonization between tank car requirements in Canada and the US, including tank car approvals, tank car design requirements and a new mechanism to secure One Time Movement Approvals (OTMA) – Category 2.
  • Updated material of construction requirements for tank cars, including the addition of stainless steel, normalized steel for dangerous goods classified as a toxic inhalation hazard (TIH) and improved thickness requirements for new tank car construction.

Comparing the 2013 and 2018 Standard TP 14877

A brief comparison of the TABLE OF CONTENTS Continue Reading…

TDG
2018 TDG Registration and Fines FAQ

Red semi truck on highway

REGISTRATION and FINES and FAQs, OH MY!

February and March contain some interesting items potentially impacting the Canadian TDG landscape…

Registration-CID Consultation

Transport Canada, through a consultation notice published in late February, has solicited input from stakeholders on a plan to require those who handle/offer for transport, transport or import dangerous goods to register with Transport Canada.

The premise is that, “… public safety depends” on Transport Canada knowing who is transporting DG, including where, when, and how much. The main thrust of this proposal seems to be for targeting enforcement and consultation activities.

The proposal as currently presented does not appear to distinguish among the size, frequency, or nature of DG involved; and will require period re-registration with submission of data to the “Client Information Database” (CID).

There’s nothing in the posted information to indicate whether there will be a cost to “clients” for registration, in addition to the record-keeping burden they will bear.

(For those familiar with the 49 CFR §107 (Subpart G) requirement, intended to subsidize government response activities, this TDG version does not serve the same purpose.)

The only exemptions currently contemplated, extend to those falling under a TDGR Part 1 “special case” exemption. This contrasts with 49 CFR’s registration which has exemptions based on load sizes and hazard types.

The TC proposal and comment provisions are found at:
https://letstalktransportation.ca/cid

Contraventions Regulations

While not directly cited in the Transport Canada TDG Act or regulations, Continue Reading…

Regulatory Helpdesk: March 5

Batteries, 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.

Why do I need an SDS for a Laptop Battery?

Q. We are shipping used laptops with batteries in the units from the US to HK via air. There are multiple manufacturers and models, are (M)SDS sheets required for each model? Our forwarder is requesting them in order to provide pricing.
A. To answer your question, it would depend on why the forwarder is requesting them. They may be asking for them to meet the written emergency response requirements. However, they could be asking for them for classification purposes to prove which part of the packing instructions these meet.

The SDS could tell them the watt-hour rating which would then drive which part of the instruction to use. Forwarders and carriers have a lot of leeway. I can only speak to what the regulations say. There is nothing in 49 CFR or IATA that indicates you must use an SDS. Most people tend to default to them because they meet so many parts of the regulations in one place.

Manufacturer’s Packaging (Lithium Battery)

Q. Should I remove the manufacturer’s packaging from lithium ion batteries being shipped by air under PI 965 Continue Reading…