Here it is – January 2020. The time when all holiday decorations are put away and people make resolutions for the coming year. Things we would like to change about ourselves, our workplace or our home. We’ve all heard them. I’m going to work out more. There will be more family time. We will eat healthier. I’ll be kinder to my co-workers. That one is mine in case you were wondering.
Now at this point you are asking how does resolution making have anything to do with transportation of dangerous goods? Well, I asked our Regulatory Team what their “regulatory resolutions” would be. In other words, if they had the power, what changes or resolutions would they make to a regulation. Oddly enough, with their responses, not a single regulation escaped a “resolution”! Some of the items listed below were mentioned on more than one person’s list.
Resolve to get rid of the combustible liquids.No one else in the world regulates these.
All lithium batteries should be transported as fully regulated with UN Specification Packaging and paperwork.No more exceptions.
Resolve to adjust the packaging recertification requirements.Align them more with Canada’s. As long as the components and specifications do not change there should be no need to re-test UN packaging every 2 years. 49 CFR should allow packaging manufacturer’s to simply send in an application for certification every 5 Continue Reading…
It’s really no surprise that something new has come up with shipping lithium batteries again. Frankly speaking, these days it’s easier to ship a radioactive shipment on a passenger aircraft then a cell phone. Of course, I am referring to the process of shipping when I make this statement. Crazy isn’t it?
Effective Jan 2, 2020, anyone shipping any of the following:
Lithium-Ion batteries packed with equipment – UN3481 Section II PI966
Lithium-ion batteries contained in equipment – UN3481 Section II PI 967
Lithium metal batteries packed with equipment – UN3091 Section II PI 969
Lithium metal batteries contained in equipment – UN3091 Section II PI 970
With Air Canada cargo must complete and sign Lithium Batteries – Section II – Shipper’s Transport Document. The contents of the document include:
certifying shipment doesn’t include forbidden lithium battery shipments such as defective/damage batteries;
verifying the watt-hour for lithium-ion batteries meet Section II requirements;
verifying lithium metal content for lithium metal batteries meet Section II requirements;
airway bill includes the statement, if applicable;
lithium battery mark is on the package(s), if applicable; and
shipper’s declaration statement.
This document reinforces the fact that any person preparing or offering Section II lithium batteries must receive adequate instruction (IATA section 1.6). Basically, have some sort of dangerous goods training before you can ship lithium batteries.
Hello everyone. I’m back with the subject of TDG training. In my last blog, we made it clear who has responsibility for a list of the most important elements. We used the sections of the Canadian TDG Regulations for each part stating the implications of the various stakeholders.
Now, in order to fully understand what TDG requires as training, we will discuss what is the normal duration for a TDG training that would provide you with adequate skills and especially training applicable to your responsibilities.
It should be noted that the primary purpose of Part 6 of the TDG (article 6.2) is to ensure that the person has a solid knowledge of all of the topics listed in paragraphs (a) to (m) that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport.
It is important to clarify here that Transport Canada does not define clearly or exactly what training should contain. TDG leaves much room for the interpretation of what constitutes appropriate training, and it remains the responsibility of the company to establish this.
For this reason, we will be discussing a training standard in the industry and it is equally important to believe that if a training facility declares that it is certified by the government or any other departmental entity that this is completely false. Continue Reading…
Hello everyone and welcome back! In my last blog, we made it clear who needs to be trained by using the definitions available to us in the Canadian TDG Regulations. Now, let’s try to properly interpret what TDG requires as training. It should be noted that the primary purpose of TDG regulations is the safety of dangerous goods in transport and to achieve an acceptable level of safety, it is, of course, essential that the persons managing dangerous goods in transport have adequate competency. To do this, in Part 6 of the TDG, the Regulations clearly state that any person who handles, offers for transport, or transports dangerous goods must have appropriate training and hold a training certificate. To fully understand what constitutes appropriate training, we must refer to article 6.2 and this article states that a person must have a solid knowledge of all the listed topics as well as the dangerous goods that he is called to handle, transport or offer for transport.
Let’s try to understand these topics that are specified and for each of the points, I will name who is responsible under the TDG.
Classification from Part 2 of the TDG. What does classification mean? This consists of defining whether your product meets the characteristics of a dangerous good included in one or more of the 9 hazard classes. Person responsible for this Continue Reading…
In June of this year, I was invited to participate in the Commercial Vehicle Safety and Enforcement (CVSE) Inspectors Commercial Vehicle Safety Alliance (CVSA) Challenge in Surrey, BC, Canada as a judge. I know it doesn’t sound fun but honestly, it was awesome.
The challenge was over a 3-day period and the competitors were seven (7) very qualified CVSE inspectors from all over BC to test their skills and knowledge. The winner from this competition would go on to compete in the North American Inspectors Championship (NAIC) in Pittsburgh, PA, USA. The NAIC includes the best of the best inspectors from Canada, the United States and Mexico competing for the title of Grand Champion. This is some serious stuff and of course, comes with bragging rights!
For the provincial competition, the competitors first have to write a series of qualifying exams, which advances them to the provincial competition. This year’s competition consisted of driver interview, dangerous goods cargo tank inspection, coach bus inspection, and dangerous goods packaging inspection.
I came in as a judge for the dangerous goods inspections. We provided some of the dangerous goods packaging with “compliance issues”. That was fun for me. I got to make dangerous goods stuff incorrect on purpose for once.
A few incompliance issues that I added:
put primary and subsidiary hazard labels on opposite sides of the package,
Since Canada first created regulations on the transportation of dangerous goods, those who “handle, offer for transport or transport” dangerous goods must be adequately trained. The question, of course, is what does “adequately” mean? Section 6.2 of the Transportation of Dangerous Goods Regulations (TDGR) says that it means “the person has a sound knowledge of all the topics … that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport,” but that still doesn’t clarify how the employer should verify that the knowledge is “sound.” Now Transport Canada, in consultation with the Canadian General Standards Board (CGSB), has attempted to answer that question.
The proposed standard would establish two levels of training. First, a “general awareness” segment, that should be approximately 2 hours long, which would cover the basics of how the TDGR works. Then, when employees are familiar with those concepts, they would receive “job specific” training, which would specifically address the job functions they do in that organization.
When a train carrying flammable liquids is involved in an incident, first responders are often the first on scene. These types of incidents are not typical for first responders. They require a unique approach. And for that reason, Transport Canada has put out a video on how to respond to rail-car incidents that involve flammable liquids. Below are the factors and steps from the video when dealing with these types of incidents.
A Rail Car is involved in an accident and a fire starts on impact. The rail car is properly placarded with the appropriate class 3 flammable Placard. Below are the factors that can influence the fire as well as steps and tools to utilize during the incident.
Whether it’s Gasoline, Diesel, Ethanol, Crude oil, or bitumen, knowing the properties of each is important to first responders because all can behave differently under spill and fire conditions. This is where the importance of proper placarding will come into play as first responders can detect exactly what type of flammable substances are on the train based on the UN number. Below are important factors of flammable substances that would help first responders determine the proper course of action:
Viscosity- Gives an indication on how fast the fire can spread.
Density- Will determine if substance will sink or float if it is near a body of water.
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…
Part 1 – The Importance of Training for Regulatory Compliance
Training is an eternal problem that has been going on for so many years. I started my career in 1999, and at that time the regulations did not help us to define our needs for training requirements regarding the Transportation of Dangerous Goods Regulations (TDGR). It is fair to state that in many ways, we are not that much further ahead today.
It is essential to understand which sections of the Transportation of Dangerous Goods Regulations apply to your business to define whether or not your company should have a training program, and determine who in the company should receive training, what needs to be covered, the frequency of training, and how long the training needs to be for maximum effectiveness.
This blog is one of a series that will try to make it as clear as possible and help your process to establish the training needs for your employees.
We start by asking ourselves relevant questions that we will answer with regulatory sections and afterward, I will attempt to explain accurately and guide you to the best solution for your business.
Before I begin, I would like to clarify the term ”Transportation”. When Transport Canada uses the term transportation it is to include any activity that relates to the request for transportation by all modes of transport (contacting a carrier Continue Reading…
One of the most frustrating issues with shipping dangerous goods is finding a carrier that will transport the goods. When a client contacts us for repackaging services, besides the DG information, I always ask if they have arranged a carrier to transport their goods. Most of the time it’s a “no”. Then I get started with what their options are; ground or air.
For shipments going from Canada to the US, believe it or not, it is easier to ship by air than ground. Of course, it does depend on the quantity being shipped and whether the DG is allowed for air transport. It is definitely more cost-effective to send anything via ground than air; however, that is not always true especially for small DG shipments. I have been told that sending a small, e.g., 20 lbs, DG package by air will cost about the same as sending it via ground.
Carriers such as FedEx and Purolator do not haul DG packages from Canada to the US via ground service. They do offer air but not ground. UPS which offers both air and ground does transport certain dangerous goods (just check for limitations on the UN# being shipped on UPS’s website under “UPS Dangerous Goods Acceptance Tool” prior to shipping) from Canada to the US but you must have a DG account set up with them.