Television talk shows have been around forever. Back in the 1950s there was Joe Franklin who moved over from talk radio and the emergence of “The Tonight Show” with its first host Steve Allen. In the 1970s and 1980s the formatting changed to include more tabloid type themes. Eventually shows became more about interviewing celebrity guests, comedy skits, and musical performances.
After all, where else could you see Tom Cruise jump around on a couch or see a presidential candidate play a saxophone? In case you didn’t catch the references, Tom Cruise’s antics were on the “Oprah Winfrey Show” and Arsenio Hall had Bill Clinton playing his saxophone.
What’s This Have to do with Dangerous Goods?
Speaking of Arsenio Hall, a part of his show included the skit called “Things That Make You Go Hmmm“. While quite funny, most aren’t appropriate for company blog. I mention this because of a recent regulatory inquiry that made it’s way to me.
A customer of ours wanted to ship a can of root beer from the US to a client in France. They wanted to know if the root beer would be considered a hazardous materials shipment. Good question if you think about it. Root beer could be considered hazardous because of the compressed gas (carbon dioxide) in solution which is hazard class 2.2.
Shipping Alkaline Batteries, IBC Pressure Gauges, and SDS Expiry Under WHMIS 2015
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.
Shipping Spent Alkaline Batteries (49 CFR)
Q. Can spent alkaline batteries (Duracell) be shipped to a recycling facility by ground without being declared dangerous goods?
A. Assuming that these are dry alkaline batteries that are used or spent for recycling, they are not required to be shipped as dangerous goods by ground in the USA per 172.102 Provision 130 (d) provided they are rated under 9 volts per below.
Ground Transport (US DOT): 49 CFR 172.102 SPECIAL PROVISION 130
Used or spent battery exception. Used or spent dry batteries of both non-rechargeable and rechargeable designs, with a marked rating up to 9-volt that are combined in the same package and transported by highway or rail for recycling, reconditioning, or disposal are not subject to this special provision or any other requirement of the HMR.
Pressure Gauge Requirements for IBCs
Q. What are the pressure gauge testing requirements for 31A IBCs?
A. I referred the customer to 178.814 d (1) (2) which lists 2 consecutive tests that must be administered with a rating of 65kPa first followed by 200kPa.
How should you provide quantity on a shipper’s declaration for an engine?
Generating a shipper’s declaration for an engine isn’t exactly new to me. I have been creating shipper’s declarations for engines since the very first time I stepped into the DG packaging world, and that was a long time ago. Therefore, it hit me pretty hard when a client’s shipment, containing an engine, was rejected by their air carrier.
Engines and UN Numbers
For many years the UN number for engines and vehicles were the same and it was classified as hazard class 9. Just recently it was changed so that each type of engine has their own UN number and hazard class. Therefore, internal combustion engines containing flammable liquid is classified as UN3528 and falls under hazard class 3.
My client said there was a small amount of diesel fuel inside (it wasn’t drained). Based on this I classified his engine as UN3528. He provided me with the completed shipment detail form which provided me with all the details of the shipment including net weight of the engine and the amount of fuel inside the engine.
Quantity of the Engine on the Shipper’s Declaration
I started to work on the shipper’s declaration and had to stop at the “Quantity and type of packing” section. There wasn’t an immediate measurement I could use for the engine. As per column “J” and Continue Reading…
A freight forwarder contacted me to get some help on shipping perfume to Hong Kong. I asked him how he is sending it and he replied, “Air.” I said, “That’s simple.” It would fall under ID8000, Consumer Commodity. Explained to him what that actually meant. Basically, it’s goods that are “packaged and distributed in a form intended or suitable for retail sales for purposes of personal care or household care”; however, there are a few restrictions such as only certain hazard classes and packing groups are permitted. Perfume definitely falls within the criteria.
He came by our office and dropped off 8 decent sized boxes of these goods. I asked the forwarder if he plans on shipping the boxes individually or will be consolidating them (e.g, on a pallet). He said his plan was to take the boxes back to the office once I prepare the boxes and he will palletize it. I advised him he can’t do that, because that would be considered an “overpack” and would require marking and labeling on the outside of the shrink wrap (assumed it would be shrink wrapped). He said “Oh”. I told him we could help him. We will provide the shrink wrap and prepare the shipment completely at our location. He said he already had a heat-treated pallet (all wooden pallets must be heat-treated Continue Reading…
My family has always been made up of people who like to read. It starts with the little ones being read to by others and generally leads to a love of independent reading later in life. I saw the process start with the next generation during the recent United States’ holiday of Thanksgiving. In order to get the 18-month old to settle down for a nap his father read to him. Funny enough, the story was that of Chicken Little. For those that don’t remember the story it is about Chicken Little getting hit on the head by an acorn and thinks the sky is falling. To protect friends and family the character decides to go tell the king. On the way, Chicken Little meets various friends and proceeds to tell each of them that the sky is falling. Hearing the refrain of “the sky is falling” said throughout the telling of the story it got me thinking …
The Sky is… Not Falling?
What if rather than panicking about the event Chicken Little followed proper procedure? When handling hazardous materials there must be plans in place to handle accidents. This includes spills and injuries at your location and more importantly during transport. One such procedure is set in 49 CFR for US ground transportation. In Section 172.604 it states that an emergency response telephone number must be Continue Reading…
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.
#5. Shipping Toxic Aerosols as a Limited Quantity by Sea (International)
Q. A customer wanted to know if shipping a toxic substance in an aerosol can be shipped as a limited quantity at 20 ounces per can as an inner package by sea? Also, the customer wanted to know what the limited quantity amount would be for UN1993 packing group III when shipping by sea.
A. I referred the customer to SP277 in the IMDG Code, which states “for aerosols or receptacles containing toxic substances, the limited quantity value is 120 ML”. In this case the customer can’t ship 20 ounces of a toxic substance in an aerosol can because this exceeds 120 ML. The limited quantity amount for UN1993 packing group III is 5L per the IMDG Code.
#4. Shipping Methyl Methacrylate (USA)
Q. I have a 2.5 liter metal container of UN1247, PG II, Methyl Methacrylate. The container is properly factory sealed. The container is then in its own “outer” box (but again, we don’t really look at that box). It’s like how cough medicine is in a bottle, but that bottle is then in an “outer” box on Continue Reading…
Determining which of your consumer chemical products would require a GHS Safety Data Sheet (SDS), can sometimes be difficult and confusing. Which products actually do need to have compliant SDS, can differ depending on which country/region you are in, and how the product is being used.
In Canada, chemical products that are labeled, packaged, and sold at retail outlets as consumer products, are regulated by the Canadian Consumer Product Safety Act (CCPSA), and the Consumer Chemicals and Containers Regulations 2001 (CCCR 2001). Examples of ‘retail’ outlets are stores such as Canadian Tire, Home Depot, Rona, and corner gas stations that anyone off the street can walk into and buy chemical products in, etc.
Chemical products, which are intended for use in worksites and not sold at retail outlets, on the other hand, are regulated by the Hazardous Products Act (HPA) and Hazardous Products Regulations (HPR, or “WHMIS 2015“). It is the HPA and HPR (WHMIS 2015), where GHS SDS requirements are found, while the CCPSA and CCCR 2001 do not currently contain any SDS requirements at all.
In the HPA, in Part II, Section 12(j) and Schedule 1, CCPSA consumer products are actually excluded from the application of the HPA’s requirements.
What does this exclusion mean?
Keep in mind that the CCPSA and CCCR 2001 do not contain any SDS requirements, while the HPA and HPR Continue Reading…
At a recent training, the group hosting invited someone from the Federal Aviation Administration (FAA) to come and speak. Throughout the brief discussion, the speaker mentioned things she sees most often while doing site audits. Listed below are a few of the main items. See if you can guess what the officer sees during audits that is not accurate.
Retention of Shipping Papers: In IATA, the retention of documentation is found in Section 184.108.40.206. According to this section the declaration of dangerous goods “must” be maintained for a minimum of 3 months. There are no state or operator variations attached to this section which may be why people get caught. In United States’ variation USG-01 it clearly tells shippers the document must be maintained by not less than 2 years.
Error Found: Only 3 months’ worth of documentation can be produced during an audit.
Use of Technical Names: Entries in the blue pages listed with a star (*) symbol tells the shipper a technical name is needed. Section 220.127.116.11(d) outlines how to determine the name, the number or names, and the type of names allowed. “The technical name must be a recognized chemical or biological name or other name currently used in scientific and technical handbooks, texts and journals. Trade names must not be used.”
Chemical Safety in the workplace can be a topic most employers would like to avoid. However, not only is it vital to the employee’s and community’s wellbeing, it is a requirement by law. In comes Safety Data Sheets (SDS) to the rescue! If Chemical safety in the workplace was a hockey team, training, storage requirements, purchasing, disposal, and inventory requirements would make up the Center, Forwards, and Defense, leaving the cornerstone of any hockey team, the Goalie to represent Safety Data Sheets (SDS). OSHA Standard 1910.1200 (g)(8) states that The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). However without correct understanding of Safety Data Sheets, it would be like having an injured goalie in your starting lineup. Below are some tips for reading a 16-section format SDS.
Section 1. Identification:
Identifies the chemical on the SDS and displays the recommended uses. This section also provides contact information of the manufacturer as well as an emergency phone number.
Section 2. Hazard Identification:
The purpose of this section is to identify various hazards the chemical presents as well as any warning information. This includes Hazard class, signal words, pictograms and hazard statements.
Section 3. Composition/Information on Ingredients:
When we think of UN Testing, several things may come to mind. We have the drop test which evaluates the package’s ability to handle collisions, the vibration test which simulates movements created by a motorized vehicle, the Cobb test which is designed to ensure the fiberboard will not disintegrate when exposed to water, and the stacking test which checks the integrity of the package by stacking various weights over the top of it. However, those that want to test their packages under the ISTA 6-FEDEX-A requirements for packages 150 lbs. or under are finding it to be difficult to get a passing grade.
What Are The Differences?
Under standard testing, each sample is dropped only one time at a specific height for a total of 5 drops total from 5 different samples.
Under the ISTA 6-FEDEX-A testing, 1 complete sample is dropped 10 times focusing on every corner and edge of the package. Any significant leaking on either of these tests would result in a failure, which makes the ISTA testing very difficult to pass because of the number of drops. In addition, flat and elongated packages must go through a bridge or concentrated impact test procedure. This procedure consists of dropping a wooden box measuring 12″ x 12″ x 12″ dense wooden box weighing 21 lbs. on the midpoint of the package.