PHMSA Announces Public Meeting to Solicit Input for 2020 Emergency Response Guidebook

On May 7, 2019, the Pipeline and Hazardous Materials Safety Administration announced there will be a public meeting scheduled for June 17, 2019 to solicit input on the development of the 2020 edition of the Emergency Response Guidebook (ERG). During the June 17 meeting, PHMSA will discuss different ways to determine the appropriate response protective distances for poisonous vapors resulting from spills involving dangerous goods considered toxic by inhalation in the “green pages” of the 2016 ERG. PHMSA will also discuss new methodologies and considerations for future editions of the ERG and outcomes of field experiments including ongoing research to better understand environmental effects on airborne toxic gas concentrations and other updates that will be published in the 2020 ERG. The 2020 ERG will be published in English, French, and Spanish and will increase public safety by improving emergency response procedures for hazardous material incidents across North America. For more information on how to be a part of the public meeting visit the link below:

https://www.federalregister.gov/documents/2019/05/07/2019-09299/hazardous-materials-public-meeting-notice-for-the-2020-emergency-response-guidebook-erg2020

PHMSA first published the ERG Guidebook in 1973 for use by emergency services personnel to provide guidance for first responders during the critical first 30 minutes of hazardous materials transportation incidents. Since 1980, PHMSA’s goal has been to provide free access of the ERG to all public emergency response personnel including fire-fighters, police, and rescue squads. PHMSA has distributed more than 14.5 Continue Reading…

Transport Canada Updates ERAP Requirements

On May 1, 2019, Transport Canada issued an 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 at http://www.gazette.gc.ca/rp-pr/p2/2019/2019-05-01/pdf/g2-15309.pdf.

ERAPs are unique to Canada, and are intended to ensure support for local responders in catastrophic spills, such as the 2013 Lac-Mégantic derailment. 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.)

The amendment has three main goals:

  • clarify ERAP implementation and reporting;
  • enhance emergency preparedness and response; and
  • make housekeeping changes that address smaller issues.

The amendment replaces all the text of Part 7, although unamended requirements will remain the same. Changes also occur in Parts 1, 3 and 8.

Clarifying Implementation of ERAPs

The original requirements of Part 7 didn’t go into any detail as to how 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 established precisely. The amendment addresses initial notification of an accident requiring ERAP response, and clarifies that the person with the ERAP Continue Reading…

International World Day for Safety and Health at Work

The International Labour Organization (ILO) was created in 1919.  It is a United Nation’s agency that sets standards, policies and programs for the work force.  Comprised of workers, employers and governments the main goals are to “promote rights at work, encourage decent employment opportunities, enhance social protection and strengthen dialogue on work-related issues.”  Each branch, if you will, has equal footing in regards to what programs and actions are implemented.  

Starting in 2003, the ILO started “International Worker’s Memorial Day” as a way to bring awareness to workers and the workplace including accidents, diseases, safety and health.  It has evolved into the “International World Day for Safety and Health at Work” and is celebrated every year on April 28.  This date also coincides with the International Commemoration Day for Dead and Injured Workers. 

Since the ILO is celebrating 100 years of existence in 2019, they are looking back at what the past 100 years and using that experience to look at the current and future workplace.  The theme to this year’s event is “A Safe and Healthy Future of Work: Building on 100 Years of Experience”.  There is a fantastic video on the ILO site found here that focuses on this year’s theme.  The longer report covers the changes to the workforce overtime and what are some of the upcoming changes.  The numbers in it are staggering when viewed from a global perspective.  It is well worth the read and is free to download.

Thinking about how Continue Reading…

OSHA HazCom 2012
OSHA Stance on Wearable Lithium Batteries

Here’s the thing. I am a TV junkie. A huge amount of my time has been dedicated to researching new shows, setting them up on my DVR, and watching said shows. One that has my attention right now is “The Rookie” starring Nathan Fillion. In the show, he is a 40-year old rookie cop in Los Angeles. It has my attention for multiple reasons aside from the obvious. The main REGULATORY one is the fact that every officer on the show wears a body camera. It got me to thinking … surely those body cameras come with rechargeable batteries. If so, what happens when in the course of the show, one of those cameras is damaged? My brain then jumped to what about workers who wear battery powered devices.

Believe it or not, OSHA recently published in their newsletter an article called, “Preventing Fire and/or Explosion Injury from Small and Wearable Lithium Battery Powered Devices”. You can find the article at https://www.osha.gov/dts/shib/shib011819.html.

In this article, they do a good job describing batteries and cells as well as how they work. There is also a lengthy section on lithium battery hazards including what can cause enough damage to create fire and explosion risks. These include such things as physical impacts, usage/storing at temperatures too high or too low and failure to follow the manufacturer’s instructions.

As to ways to prevent injuries Continue Reading…

Skull and Cross Bones
National Poison Prevention Week

The main part of my job is to train companies, workers, handlers, and the like on how to manage hazardous materials or hazardous chemicals safely. This can be done under the umbrella of the transport regulations of 49CFR, IATA, and IMDG, or under the OSHA HazCom standard. However, not everyone is going to take one of my courses. Sad, but true.

Granted all of those folks do their jobs well and use marks, labels, placards, and safety data sheets to convey information about their products to other users. But it begs the question, how is the general public made aware of the “other” dangers or poisons out there? Think about the laundry pod scare recently to make my point.

Back in 1962, the first-ever National Poison Prevention Week was announced. In 2019, the week will be from March 17-23. Supported directly by the American Association of Poison Control Centers (AAPCC), the goal is to promote safety tips and the emergency services provided by the Poison Control Centers in the US.

To emphasize just how important Poison Control Centers are, take a look at some numbers from 2016 taken directly from the AAPCC website at www.aapcc.org.

  • There were 2,700,000 cases managed by the centers.
  • Someone called the centers every 14 minutes.
  • Over $1,800,000,000 saved in medicals costs.

For this year’s event, people are encouraged to use the hashtags #NPPW19, #PreventPoison, and #PoisonHelp. Continue Reading…

New Dangerous Goods Fees to Go in Effect for Amazon

Last month I wrote a blog regarding penalty fees Amazon was looking to implement for packages that fail to comply with safety requirements when shipping dangerous goods. Amazon ultimately decided to take this a step further adding storage, and fulfillment fees for products they deem asdangerous goods. 

Who does this affect?

For sellers that utilize Amazon’s FBA program (Fulfillment By Amazon) in which third-party sellers send their goods to be stored, picked, packed, and shipped in Amazon warehouses before they are sold on Amazon, some of the new fees will go into effect on February 19, 2019, according to a note on Amazon’s forum for sellers.

Specifically, Amazon announced that it will be introducing a new fee for “dangerous” items like aerosol cans, and lithium-ion batteries that sellers send to Amazon warehouses. The fees will be higher than the regular fees Amazon charges for using Fulfillment By Amazon.

What are the fees?

The table below shows the new monthly inventory storage fees for dangerous goods containing flammable or pressurized aerosol substances. This change will first be reflected in April 2019 charges for storage that occurs in March 2019.

Storage Month Standard Size Oversize
January – September $0.99 per cubic foot $0.78 per cubic foot
October – December $3.63 per cubic foot $2.43 per cubic foot

Other fees include an introduction of separate fulfillment fees for dangerous goods that contain flammable or pressurized aerosol substances, and items that contain lithium-ion batteries.

Too see Continue Reading…

ICC Compliance Center
Stranded in a Vehicle During a Winter Storm

Living in the St. Louis Metro Area planning before heading out onto the highways is a good idea. With a population upwards of 2 million, there are always lots of vehicles on the roads. Add to that the number of those passing through on their way out west, and you can imagine some of the traffic snarls happening on a daily basis. If there should be any sort of inclement weather, the number of accidents multiply on an exponential basis. Given we just passed the first official day of winter, it seems appropriate to think about what to do if you get stranded in your car during a winter storm.

After researching this a bit, it was interesting where I found the best advice. The Weather Channel, and several insurance agencies seemed to provide the most logical ones. Many ideas center around concepts that make sense for being a responsible car owner.

What to do when stranded:

  • Have a survival kit in your car. Create one for the types of situations you could find yourself. It should include extra gloves, water, a flashlight, a blanket, a cell phone charger, and an ice scraper just to name a few items. 
  • Stay inside the vehicle with your seatbelt connected. By staying in place you avoid exposure to the elements, which can put you at risk for hypothermia, frostbite, and getting lost. Your seatbelt is Continue Reading…
Web address monitor icon
Amazon Now Targeting Sellers That Ship Unsafe Packages to Warehouses

With the holiday season many of us are opting out of the busy malls and stores, and simply shopping from the comfort of our own homes. To make this option even more enticing some retailers are even offering free 2-day shipping during the holiday season. While this seems like a win-win situation for all there are some obstacles that have been coming to the surface, and unfortunately we are not just talking about late deliveries.  According to the Office of Hazardous Materials Safety, the world’s largest internet retailer, Amazon, has seen a sharp increase in reports of shipments allegedly violating the U.S. Department of Transportation regulations. In 2009, Amazon only had two incident reports, but that number jumped to 32 in 2016 before reaching 42 so far this year. This has caused Amazon to ultimately respond as they soon plan on adding new penalty fees for packages that fail to comply with its safety requirements.

Incidents

The main issue here is many third-party sellers on Amazon aren’t trained to ship dangerous goods, and simply don’t understand that what they are shipping is indeed hazardous. These third-party sellers often don’t realize what actions need to be taken per the Hazardous Material Regulations that exist to safeguard those who may come in contact with the dangerous goods. For that reason, often times the correct labeling, packaging, and paperwork required to Continue Reading…

Fire Safety
NFPA’s Fire Prevention Week 2018
2018 Fire Prevention Week -  Look Listen Learn

October 7 – 13 Is Fire Prevention Week

The National Fire Protection Association (NFPA) has designated the week of October 7th-13th as Fire Prevention Week. This date was chosen as the Great Chicago fire started on October 8, 1871. Each year a theme for the week is chosen in an effort to keep fire safety present in people’s minds. This year’s theme is “Look. Listen. Learn. Be aware – fire can happen anywhere.

Those 3 words are simplistic but necessary when it comes to fire prevention, preparedness and risk. It carries over from the home, to the workplace and more. Look is for people to look around their home, office and workplace. Listen is mainly focused on the sound of smoke or fire alarms. Learn is about knowing multiple ways out of a room. Here are some further thoughts on each word for you to consider.

Look for places fire could start:

  • Cooking areas
  • Heating equipment
  • Electrical and lighting equipment
  • Candles

Listen for the sound of the smoke alarm:

  • Take them seriously
  • Know where are they located in the home, office and workplace
  • Test them monthly
  • Replace any over 10 years old

Learn two ways out of every room:

  • Have an escape plan in the home, office and workplace
  • Set a meeting place
  • Know the path from each exit to the outside
  • Keep the areas near the exit points easily accessible

The NFPA 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…