Explosives
Explosives Consultation – Ports & Other Proposals

Recognizing Technological Evolution while Maintaining Safety & Security

Explosives Regulations (ER) – Ports & Wharves

The Explosives Safety & Security Branch (ESSB) of Natural Resources Canada, and Transport Canada, have issued a Gazette I (CG I) proposal to amend their respective Explosives Regulations (ER, under the Explosives Act), and the Cargo Fumigation and Tackle Regulations (CFTR, under the Canada Shipping Act).

The initial reason for the proposed amendment is to remove reference to the express requirement to use quantity/distance principle (QDP) restrictions and ESSB Inspectors from the CFTR. A more modern approach of quantitative risk assessments (QRA), based on actual probable hazards following, methodology authorized by the ESSB (Chief Inspector of Explosives), would replace the more rigid QDP.

QDP, currently covered in CAN/BNQ 2910-510/2015, were established mainly for fixed manufacturing/storage facilities and specifically exclude transportation activities from the scope of the standard.

The proposal also provides for having qualified individuals, not just ESSB Inspectors, determine the risk following an approved QRA methodology. The requirements will appear in a new ER section 203.1 instead of the current CFTR section 155(2) & (3).

It is expected that international trade and commerce will be improved without sacrificing safety or security under this proposal.

Explosives – Other Amendments

The CG I amendment proposes to also include ER changes under the topics of:

  1. Eliminating or relaxing license requirements for certain “low risk” explosives (7 components);
  2. Clarification of wording (13 components); and
  3. Increasing Continue Reading…
Regulatory Helpdesk: December 4, 2017

Top 4 Questions from the Regulatory Helpdesk

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.

IMDG Editions

Q. What edition of the IMDG should I be using?

A. The customer would still need the 38th edition to get him through all of next year. The new 39th edition will be published at the end of 2018 but it can’t be used at all until Jan 1, 2019. Even then the 38th is still a viable option.

IMDG Transition Timeline
IMDG Transition Timeline

Placement of the Consignor’s Certification Statement

Q. Can the Consignor’s certification appear on a second page or on the back of the shipping document?

A. Yes, if there is no other non-DG information intervening when using the phrase in TDGR 3.6.1(1)(a). This phrase requires that the certification appear below the information specified in 3.5. The Transport Canada FAQ page indicates that the “consignor’s certification may appear on the back of the shipping document as long as it is after the information required under Section 3.5“.

Limited Quantities Under IMDG

Q. Can limited quantity provisions be used to ship under the IMDG Code?

A. Yes, but you should have IMDG Code training or consider a re-packing service if you are not trained, since the requirements are not the Continue Reading…

Regulatory Helpdesk: November 20, 2017

Top 5 Questions from the Regulatory Helpdesk

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.

Overpacks

Q. My shipment was refused even though I followed what the regulations and my training said for shipping an overpack. My drums were on a pallet and shrink wrapped. All of the information on the drums could be seen. I placed a sticker with the words “Overpack Used” on the shrink wrap and listed it that way on my paperwork. Can you tell me why my carrier refused it?

A. Per Section 7.1.7 the actual wording that must be used on your pallet is just the word “overpack”. It seems confusing to have different terminology used but that is how the regulations work and why you should be trained every 2 years for IATA.

Using Combustible Liquid, N.O.S. (USA)

Q. Since this product meets the combustible definition, can we use ‘NA1993 Combustible Liquids, n.o.s.’ to ship to Canada or does Canada only recognize the ‘UN1993 Flammable Liquids, n.o.s.’?

A. Basically, to me, she is asking what is the difference between NA1993 and UN1993 and how it impacts transporting into Canada. NA1993 is a US only identification number. It is used for transporting combustible liquids in the US.  Technically, a combustible liquid is NOT Continue Reading…

Regulatory Helpdesk: November 13, 2017

Top 4 Questions from the Regulatory Helpdesk

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.

WHMIS Label Size Requirements

Q. Is there were size requirements for WHMIS labels?

A. No, the HPR does not mandate a size requirement other than saying it has to be legible. But, what does legible mean? As a general rule of thumb, which we have developed from reviewing many different labeling regulations is 10 mm for one side of the pictogram, and 2 mm for the font size (1.6 mm for a worst-case scenario).

IATA Special Provision

Q. What does  IATA’s Special Provision A191 mean?

A. It was determined that SP A191 means if you have a manufactured article with less than 5 kg of mercury in it (like a thermometer) then you don’t need the Class 6.1 label for mercury’s subsidiary hazard and you don’t have to list the 6.1 subsidiary hazard on the shipper’s declaration.   From what we can tell that only applies to UN3506 which is Mercury contained in manufactured articles.

Quantity Limits – TDG (Canada)

Q: What does the quantity limit in TDG Columns 8 & 9 represent in terms of Passenger conveyance restrictions- package, consignment, …?

A: Good point which many find confusing. The answer is in the often-overlooked Continue Reading…

Regulatory Helpdesk: November 6, 2017

Top 4 Questions from the Regulatory Helpdesk

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.

Equivalent Exemption (Canada & US)

Q. What is the  US “equivalent” to TDGR Part 1 Special Case 1.33?

A. The reference is found in 49 CFR§173.150. Essentially the US says that, with conditions, a low risk flammable liquid may be “reclassified” as a combustible liquid; & combustible liquids may be exempted when in non-bulk packaging. Before using the exemption, also check the following:

  1. Verify that the actual ingredients don’t trigger the (US only) “RQ” requirement to classify as “hazardous substance” or “marine pollutant” designation which will negate the exemption under (f)(2).
  2. Verify that there is no subsidiary hazard class which would negate the exemption (US (f)(1) & TDG 1.33(a)).

Organic Peroxide Shipped by Ocean

Q. Can you confirm the packing group for UN3104 with Dibenzoyl Peroxide for IMDG?

A. UN3104 is Organic Peroxide Type C, solid. This is a class 5.2 material that does not have a packing group. However, Chapter 2.5 should be reviewed as well as Packing Instruction P520 and packing methods OP6.

A Spill Involving a Limited Quantity

Q. If I have a product being shipped in Limited Quantity, it’s not considered as being dangerous any more? So if there is Continue Reading…

Graduation Cap
ICC Teaches A Dangerous Goods Course in Europe

Teaching DG Training in Switzerland

Going to Switzerland!

This September, ICC was offered an interesting opportunity – presenting a class on North American hazardous materials regulations in Switzerland! So, I gathered my passport and computer, and set off for Europe.

The course was organized by SAFETY Training Plus GmbH, a well-known provider of dangerous goods training in Germany and Switzerland. However, SAFETY Training Plus found that many of its customers were looking for help with shipments to North America. Although European and North American regulations are usually based on the UN Recommendations for the Transport of Dangerous Goods (better known as the Orange Book based on its cover), a number of variations still exist between the various countries and regions.

For example, a European shipper to the United States might be puzzled about why a product not classified as an environmental hazard under the EU regulations (ADR/RID) or the International Maritime Dangerous Goods Code (IMDG) for ocean would have to be treated as such for entry into the U.S. Surprise! It’s the Hazardous Substance rule, involving a list of over a thousand chemicals that are classified as environmentally hazardous in Title 49, U.S. Code of Regulations (49 CFR). Another shipment may hit a snag entering Canada due to Canada’s requirement for an Emergency Response Assistance Plan. This requirement usually applies to high-risk goods in large means of containment, but may sometimes affect smaller materials Continue Reading…

Regulatory Helpdesk: October 30, 2017

Top 4 Questions from the Regulatory Helpdesk

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.

WHMIS Labeling

Q. If a product is manufactured in Canada strictly for export into the US, does it require the French on the GHS label?

A. HPR (Hazard Products Regulations) section 5.14, subsection 3. These exemptions from labeling and SDS (safety data sheet) requirements apply to importation (subsection 5.14(2) of the HPR) and sale, for the purposes of exportation (subsection 5.14(3) of the HPR), of hazardous products that are not meant to be used in a work place in Canada. Such hazardous products do not require an HPR compliant label or SDS.

Lithium Battery Labels

Q. When does the 12 mm UN number height requirement start?

A. The IATA 59th edition states the UN number height should be 12 mm. Since IATA 59th edition becomes mandatory on January 1, 2018, the UN height change is effective then. Keep in mind however that IATA defines “should” as a recommendation, it is not mandatory.

Q. I have a question on the red slash marks all the way around the label – what is the requirement on that?

  • Do they have to be so many of the red slash marks? – is there a specific Continue Reading…
Repacking Dangerous Goods
Shipping ID8000 by Air

Shipping ID8000 by Air

What do you do when an empty package weighs almost as much as the maximum weight allowed?

Those who ship dangerous goods via air understand there are maximum weight restrictions per package to abide by. For example, in the case of ID8000 the maximum weight per package is 30 kg G. The “G” represents gross weight.

The Request

I had a packaging service request to prepare a shipment (2 boxes) heading to Europe via air. As per the SDS the goods are classified as ID8000 for air transport. No problem! Normally ID8000 packaging jobs are pretty straightforward. When the boxes arrived at our warehouse, I was shocked at how big they were. I attempted to lift one off the pallet and move it to my packaging area, and our warehouse coordinator said, “Easy there, Muscles. Those are heavy boxes.” I asked him how much the packages weighed. He grabbed the courier slip and it said 89 kg (196.11 lbs).

The Problem

Right off the bat, the maximum weight per package was now exceeded. I opened one of the boxes to see inside (as I always do with any packaging job) and inside were a bunch of smaller boxes with aerosol cans. I took out all the smaller boxes and weighed the empty box (yes, I got help from Mr. Hercules … there is a lot of love around our office) to find Continue Reading…

Regulatory Helpdesk: October 23, 2017

Top 4 Questions from the Regulatory Helpdesk

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.

#4. Shipping Lithium Batteries (USA-Ground)

Q. The customer asked if they had to fill out shipping papers for a battery contained in equipment that is less than 1 gram and less than 20 WH if shipping by ground within the U.S.

A. Shipping paper requirements are contained in 49 CFR Part 172 Subpart C.  The 49 CFR, 173.185 (C) states that a package containing lithium cells or batteries, or lithium cells or batteries packed with, or contained in, equipment, that meets the conditions of this paragraph is excepted from the requirements in subpart(s) C through H of part 172 of this subchapter, which in this case means that they are exempt from shipping paper requirements.

#3. Shipping Dry Ice by Ground in the USA

Q. A customer contacted me regarding the labeling and paperwork regulations of shipping dry ice by ground within the US. They normally ship through air internationally and wanted to know the difference.

A. I directed the customer to column 1 in the hazmat table in the 49 CFR for UN1845, which has an “A” and “W” symbol. I let the customer know these symbols mean unless it Continue Reading…

Repacking Dangerous Goods
Acetic Acid – Shipping Apple Juice …

Shipping Acetic Acid

… well not quite but it looks like apple juice!

I had a client inquire about shipping acetic acid, which looks very much like apple juice, via air.

I asked him about the quantity, the concentration, and current packaging of the product. There was approximately a total of 11 litres, contained in 2 plastic jugs with 90% concentration. I asked him which carrier he wanted to use and he said, “whichever one I recommend“. Based on the volume of the product I advised him he could do one of two things. Either ship 11 individual boxes (definitely the more costly option), or ship it all in one box via carrier of his choice.

Of course, it made sense to put them all in one box and ship with a cargo aircraft only mark. I asked him to decant the 2 jugs into smaller inner containers with a maximum volume of 2.5 litres each. Plastic is preferred for this chemical. He brought in 11 individual plastic bottles that completely resembled an apple juice bottle. Using adequate UN packaging I packaged the bottles with plenty of vermiculite and sent it with FedEx. The package arrived the next day without any hiccups. I love these straightforward packing jobs!

Here are a few photos of the job:

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