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.
Sometimes no matter how many precautions you take, there is no way to stop the inevitable. Football players with helmets designed to protect their brains still get concussions. You cross every “t” and dot every “i” on your federal income tax return and you still get audited. And sometimes even if you follow all of the safety tips for lithium ion batteries in my previous blog, they still can explode. http://blog.thecompliancecenter.com/safety-tips-for-lithium-ion-batteries/
However, by not taking the proper preventative measures in all of the cases listed above, the chances of a negative outcome can be greatly increased. With the travel season looking to pick-up in the coming months and many of us looking to hop on a plane and head out to our idea of paradise, I think it is safe to say that none of us want to end up in a situation like the story below.
Just like any other domestic flight, passengers on a Delta flight in New York City were stowing their carry on items in the overhead storage bins and preparing for take-off for a scheduled departure to Houston, Texas. Suddenly, passengers started to smell something burning, similar to the smell of a camp-fire. It was at that point that passengers started to see smoke in the cabin and begin panicking. The panic was caused by a vape pen that started smoldering Continue Reading…
If your business is like most, you don’t usually deal with shipping explosives in Class 1. However, this class sometimes shows up in places you’d least expect it. While it’s expected to deal with explosives in construction, mining, and the military, you can also find explosives in unexpected products such as toys (caps for cap guns), pyrotechnics for stage and movie productions, and animal tracking collars (some use explosive bolts to free the animal so it doesn’t have to make a permanent fashion statement).
Shipping explosives can be more complex than many other classes of dangerous goods. They are subject to other regulations, such as the Explosives Act, and may require special licensing depending on what type they are. In addition, they are often excluded from some of the common exemptions found in Canada’s Transportation of Dangerous Goods Regulations (TDGR). For example, explosives can’t use the Limited Quantity exemption of section 1.17, or the Excepted Quantity exception found in section 1.17.1. Some low-level explosives may qualify for the 150 Kilogram Gross Mass Exemption in section 1.15 and the 500 Kilogram Gross Mass Exemption in section 1.16, but only if they fall into certain divisions, compatibility groups or UN numbers. You’ll need to read each exemption closely to ensure that your particular explosive will qualify.
To balance things out, TDGR does contain some provisions for shipping small amounts of low-level Continue Reading…
The Canadian Transportation of Dangerous Goods Regulations (TDGR) were uncharacteristically quiet in 2018. This represents the first year in a 5-year stretch where stakeholders didn’t see at least one amendment to the TDGR.
That doesn’t mean, however, that there was no activity within this very active government department. For example, in keeping with the move to adopting ambulatory references to cited standards, the responsibility for several standards (e.g., TP14850 small container performance packaging, and TP14877 rail containers) began their return to the Canadian General Standards Board. In addition, there were various consultations on topics such as ERAPs (TDGR Part 7), and discussion of training requirements (TDGR Part 6) – the latter in conjunction with establishing a CGSB committee.
NEW & ONGOING RESEARCH
Various research projects were explored in 2018 including collaboration on examining crude oil flammability, properties of produced water in oil and gas activities, as well as validation testing of a proposed SAE standard for lithium battery packaging. These activities a
Various topics referenced above and others undertaken in the 2016-2018 period were given status updates, including proposed Canada Gazette (CG) I (final consultation) or II (final amendment) at a late November GPAC (General Policy Advisory Council) session:
At this time of year all the regulatory updates start. Every time a notation comes across my desk or email I can’t help but think about a famous line in the movie “Sixteen Candles”. That particular line is “What’s happening hot stuff?” Click here to see the actual movie clip. One of these days, I want a presentation to start with this. It would sure break the ice on some rather detailed subject matter.
Having prepared you for thinking about what’s happening or changing, we have to start at the UN level specifically. Much of this information comes from a presentation by Duane Pfund at the Pipeline and Hazardous Materials Safety Administration. We need to focus on is what changed from the 2015 – 2016 biennium. That biennium gave us Revision 20 of the UN Model Recommendations for the Transport of Dangerous Goods. Revision 20 is what will drive the changes starting in January 2019.
What’s Happening or Changing for 2019?
Class 8 Corrosive Materials:
A new alternative method for classifying these mixtures is being introduced. It revolves around using the GHS Purple Book bridging principles and calculation methods. Note that flammable gases and explosives are on the list for this same concept in the current biennium.
IBC Residue, Choosing Placards, IATA Special Provisions, and Hazard Class Label Size
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. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.
Residue in IBCs (TDG)
Q. Under TDG, do Intermediate Bulk Containers (IBCs) such as tote tanks that contain residues still have to be transported as dangerous goods? Should the placards remain or be removed?
A. Under TDG, packagings or containers that still contain enough residue to pose a hazard during transportation should still be treated as dangerous goods. Unfortunately, the regulations do not give a specific way of judging this, so they should be considered hazardous unless you are absolutely sure they are not. (There is some misinformation that you may come across about how to make this decision. TDG does not specify “triple-rinsing” as a standard for cleaning or declare that an inch or less of residue can be considered non-dangerous. These references may come from other regulations or industry guidelines, but do not apply to TDG.)
So, if your IBC contains a dangerous residue, it should be clearly identified as such for transportation. If it was originally placarded or labelled correctly, just leave those Continue Reading…
CSA issues new Editions of TDG Class 2 Cylinder Standards
Transport Canada has issued an update “Notice” to inform the regulated community of recent updates to the Canadian Standards Association (CSA) standards addressing the requirements for the manufacture/qualification, selection and use of cylinders used in the transportation of dangerous goods (TDG).
Although these standards are primarily for compressed gases, their use may also be required or permitted for DG substances, other than Class 2, that may produce toxic or flammable vapours. Typically, this information is cited in standard TP14850 by reference in the packing instructions.
The four standards involved are:
CSA B339, CSA B340
(design/manufacture/qualification and selection/use, respectively) regarding cylinders, spheres and tubes, and other similar containers.
CSA B341, CSA B342
(manufacture/qualification and selection/use, respectively) regarding UN pressure receptacles and multi-element gas containers (MEGC).
Why Two Sets? Origins
The B339/B340 set are the seventh revision to the standards based on the older CTC (Canadian Transport Commission, pre-Transport Canada) national standards for these types of containers. These versions are the seventh revision of the original editions commencing in 1983 and 1986 respectively.
This contrasts with the B341/B342 set derived from the standards in UN Recommendation model regulations. The Canadian versions referenced here are the 3rd editions following 2009 and 2015 editions. Issuing these as CSA standards, rather than just adopting the UN Recommendations, facilitates incorporating the country-specific aspects such as special permits, reciprocity, etc.