Repacking Dangerous Goods
Can You Spot the Error?
Can you Spot the error on this UN marking

The UN Number Reads: 1H2/Y1.5/30

This was the plastic drum used for shipping UN1760, PG II product. 

I received a call from one of our clients to assist them with a rejected shipment. They are air certified but they don’t ship via air that often; hence, why they had some issues and needed our expertise. For the folks that ship air regularly, we all know that if you don’t cross your “t” and dot your “i” it won’t go and it can be frustrating for those shipping via air infrequently.

1H2 or 1H1?

The shipment consisted of 2 plastic pails which was dropped to our location by the carrier as directed by our client.  First thing I look for is if the pails are UN standardized and yes, they were. Based on the quantity limit per package, it had to go cargo aircraft only and must follow packing instruction 855.  Looked at PI 855 and sure enough a “1H2” is not permitted to be used as a single packaging.  Our client mainly ships ground and this pail is acceptable for ground shipping but since it’s going via air and it’s PG II, it must be a closed head drum, a 1H1.

Yes, it’s very frustrating. Called our client back and advised him it can’t go the way it’s currently packaged. Must be transferred into a 1H1 or another closed head single Continue Reading…

Repacking Dangerous Goods
Shipping DG by Air With More than One Air Carrier

What do you do when your shipment involves two air carriers, but they are not interline?

It is common for one shipment to travel with multiple air carriers; however, almost all are interline which means they will coordinate and transfer shipments among themselves without issues. It helps when there is a freight forwarder involved who will take on this task for us, as we would expect them to take on all the coordination of a shipment. In some cases when the shipper is doing it all themselves, it can be challenging … like last week.

Let Me Set the Scene

The shipper is in Vancouver, BC and is shipping a variety of products (DG and non-DG) to 2 different communities in Northern Canada. They decided to do the logistics themselves. Since they don’t have air certification they asked for our repackaging services for the DG. The DG included some compressed cylinders, batteries, and life saving appliances. All commodities are acceptable for air transport. There would be 3 pallets leaving from Vancouver; 2 pallets are destined for one community and 1 pallet is destined for another community.

Here is the Issue

All 3 pallets are going to Ottawa, ON first. From there 2 of the pallets are going to one community and 1 pallet to another. All 3 pallets are going on Air Canada from Vancouver to Ottawa, from Ottawa the pallets 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…

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…

WHMIS 2015 Concentration Ranges – Finally Some SDS ‘Relief’

WHMIS Update

Health Canada Amendment to the HPR (Hazardous Product Regulations)

Health Canada published a proposed amendment to the HPR (Hazardous Product Regulations), which included an option to use specified concentration ranges for ingredients rather than the exact or actual chemical concentration on their SDSs (safety data sheets) (October 21, 2017).

That proposed amendment to allow ranges, would offer industry some Confidential Business Information (CBI) protection of formulations without having to go through a potentially costly CBI application claim under the Hazardous Materials Information Review Act (HMIRA).

Ahhh….’Relief’

After receiving comments and questions on the proposed amendment to allow the use of concentration ranges on SDSs, Health Canada has advised that the amendment has been approved and registered as of April 4, 2018. The approved amendment has yet to appear in the official Gazette II publication, but is expected to appear on April 18, 2018. Since it is officially registered, the amendment is effective, and can be applied, now.

The Details…

Health Canada, through this new amendment, is giving the option to suppliers, to list prescribed concentration ranges for ingredients on SDSs, without having to apply for a potentially costly exemption, in accordance with the HMIRA.

Suppliers may use this option when they wish to protect exact concentrations, or ‘actual concentration ranges’, which they feel are trade secrets.

The following are the approved, prescribed, list of concentration ranges:

0.1 – 1.0%
0.5 – 1.5%
1.0 – 5.0%
3.0 – 7.0%
5.0 Continue Reading…
How to Ship My Motorcycle

Riding motorcycle on dirt road

I need to ship my motorcycle. What do I need to do?

Normally around this time of the year we start to get calls about shipping a motorcycle as folks are planning their vacations and motorcycle adventures.

To be honest, I enjoy receiving these motorcycle inquiry calls because it always had to do with someone either visiting our beautiful country and now returning back home or they will be traveling to a beautiful destination and need to ship their bike. It gives me a chance to chat with them about their travels, too! Which is exciting, as I am a world traveler myself. I thoroughly enjoy speaking to them about their travels and adventures before I get into discussing the “exciting” world of shipping dangerous goods.

Here’s All that is Involved with Shipping a Bike:

We can help you! It is a simple procedure and it involves very little stress.

1. You will need to complete the “Motorcycle Declaration Form”

This can be completely electronically in the comfort of your home. This form can be downloaded here (Kel-Ex Vancouver) or here (ICC Repacking). It’s a simple document which gives us the details of your bike (i.e., shipper and consignee address, how it will be packaged, weight, confirmation that the fuel tank will be drained to less than ¼ tank upon drop off). In most cases motorcycles are dropped off “as is” meaning Continue Reading…

Regulatory Helpdesk: March 12

Combustible Liquids, Using Chemtrec’s Number, Keeping Up-To-Date, and Other Paperwork

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.

DG Documentation on Overpacks

Q. If there are multiple skids of dangerous goods (overpacks) in a shipment on which one should the copies of the invoices and shipping papers be attached?
A. Neither the DOT nor IATA regulations tell you to put “paperwork” on the outer packages or overpacks. That is a carrier/driver thing. All the regulations care about is the proper marking and labeling that they require. You also have to be able to physically hand your paperwork to the carrier. Your best bet would be to talk to your carrier directly as to how they want it handled.

Combustible Liquids

Q. I have a liquid with a flashpoint of 100° F and it does not meet any other hazard classes. It is not an RQ, waste or marine pollutant. After manufacturing, it is placed in tubes and then shipped for sale in retail stores. What marks and labels are needed on the outside of the packages?
A. The flashpoint of this material is 100° F and there are no other hazards under the transport regulations. This means it technically meets the definition of a flammable liquid in Packing Group III per §173.120 Continue Reading…
Repacking Dangerous Goods
Help! My DG Shipment is Delayed

Help! My dg shipment was delayed

… and I was told to call ICC

It’s very common to hear this from our first-time clients whose dangerous goods shipment is delayed somewhere and now they are panicking to get it “unstuck”. I had a similar situation couple of weeks ago.

Delayed Shipment of Dangerous Goods

A gentleman was referred to us by an air carrier. Let’s call him Jack. Jack called asking if we can assist him with his package that is held up by the air carrier at the air carrier’s location. The air carrier was local to ICC; hence, they gave Jack our contact information. In an effort to understand what happened I asked him about what he was shipping and he told me very plainly, samples.

Now we all know “samples” can mean just about anything. Jack said that they were samples from their equipment and he was shipping them to the USA for testing. I asked him if he had the SDS for these samples and if he could email it to me along with the quantity per sample.

Apparently, there were two (2) 0.5 litre bottles inside this box. Jack is based in northern B.C. so his shipment was transported via ground and then it was supposed to go air from Vancouver, B.C. Jack mentioned that supposedly his shipment started to leak and it seeped to the outside of the package. The air Continue Reading…

Safety Data Sheets (SDS)
GHS SDS Ingredient Disclosure

Young female Industrial Worker

Another SDS ‘Headache’

If you are supplying chemical products that require Safety Data Sheets (SDS’s) to multiple countries, you are also likely to know this headache well.

With the implementation of the Globally Harmonized System of Classification & Labeling (GHS) around the world progressing, issues are beginning to appear which emphasize points where…. Maybe requirements are not so ‘harmonized’. One such issue, is ingredient disclosure requirements on SDS’s for mixtures across different regions of the world.

The United Nation’s (UN’s) GHS system, does contain some standardized recommendations for SDS, including that SDS’s should be provided only for chemicals classified as ‘hazardous’, SDS’s should contain basic minimum information (e.g., 16 sections with specific headings), as well as more detailed recommended guidance on how to prepare each section of the SDS.

Ingredient disclosure recommendations, in particular, appear in Annex 4 of the GHS. In general, the GHS recommends that for a mixture classified as hazardous, the SDS should list all ‘hazardous’ ingredients, which are individually hazardous to health or the environment, when the ingredients are present above concentration cutoff levels. There’s several parts of that general requirement, which can be viewed as a ‘can of worms’.

Are the cutoff levels the same for each region of the world? How should one handle ingredient disclosure when you are in a region that doesn’t regulate environmental hazards on SDS’s? Are ‘non-hazardous’ chemical mixtures really not Continue Reading…

IMDG
How Do You Ship Bullets? (IMO)

shipping bullets by ocean

What to do when you are moving and need to ship a whole lot of bullets?

98% of our repackaging clientele are businesses, but there are 2% of our clientele that are regular people. At least, this is how I refer to them. These folks are a “Mr. or Mrs. Smith” who have absolutely no idea about the dangerous goods world, but what they wish to send is considered dangerous goods. These folks are referred to us from carriers, freight forwarders, and sometimes by internet search results.

Recently I had a Mr. Smith call us to ask about packaging cartridges as recommended by his freight forwarder. He is moving to Europe and is packing up his entire house, which includes his firearms and the cartridges that go with them. He already had all his ducks in a row meaning his export/import documentation and certification for the firearms and whatever else was needed to ship the firearms and cartridges, but he needed to get the cartridges packaged up for transport. That’s where ICC comes in.

What Are We Really Dealing With?

Mr. Smith didn’t have any transport information such as UN number or shipping name. So, I asked him to email me pictures of the cartridges, because he mentioned they were all in their original retail packages. I was able to call the manufacturer directly and ask for the shipping info. Continue Reading…