Single Packaging
5 Common Mistakes When Shipping Dangerous Goods

Man preparing shipment

With the amount of hazardous materials being transported every day, It is no surprise that dangerous goods shippers may struggle to be compliant. Whether it is a misinterpretation of the regulations, or not knowing that a specific regulation exists, the end result is the same, fines and endangering the safety of others. Below are some common mistakes when shipping dangerous goods.

1. Failure to Use UN Specification Packaging:

Shipping dangerous goods isn’t as easy as throwing it in a box and taping it closed. Depending on the specific hazardous substance, there are regulations in place that tell us what type of packaging is acceptable. These regulations will also tell us if the hazardous substance requires UN Specification packaging or not, depending on the quantity. Your best bet would be to always err on the side of caution when packaging dangerous goods and make sure your understanding of the regulations is correct.

49 CFR 173.24, Subsection 5.12(1) of the TDG Regulations.

2. Improper Marking and Labeling of Packages in Shipment:

The exact violation will differ with each shipment, however, whatever the violation is they all have one thing in common: a misunderstanding of the Hazardous Material Regulations (HMR) and how they apply to the hazardous materials you are shipping. It is the responsibility of the shipper to ensure the package is marked and labeled correctly. Section 4.10 of the TDG regulations, 172.400 49 CFR.

3. Failure to Follow Closure Instructions and to Maintain Them in Accordance with DOT:

Inaccurate record keeping is one of the most frequently occurring violations assessed by the Department of Transportation. The Hazardous Materials Regulations require shippers to maintain a copy of the manufacturer’s notification, including closure instructions (See 178.2(c)(1)(i)(B) of the 49 CFR and clause 4.4 of TP14850), unless it is permanently embossed or printed on the packaging itself. The packaging closure instructions must be available for inspection by a DOT representative upon request for the time period of the packaging’s periodic retest date.

4. Failure to Train Hazmat Employees:

The terms “hazmat employee” and “hazmat employer” are clearly defined in 49 CFR 171.8. Stated briefly, a hazmat employee is anyone who directly affects hazardous materials transportation safety, and a hazmat employer is anyone who uses employees in connection with transporting hazardous materials in commerce, causing hazardous materials to be transported, or manufacturing or offering packaging as authorized for use in transportation of hazardous materials. Section 6.2 of the TDG Regulations.

Before any employee begins working with dangerous goods, that person must be provided function-specific training applicable to the functions of the job that they perform. Also, if a new regulation is adopted, or an existing regulation is changed that relates to a function performed by a hazmat employee, that hazmat employee first must be instructed in those new or revised function-specific requirements. 172.704 (a)(2)(i) 49 CFR.

5. Failure to register with PHMSA:

Federal Hazardous material transportation law requires a person who offers for transportation certain hazardous materials, to file a registration statement with the U.S Department of Transportation and to pay an annual registration fee. The registration regulations are found at 49 CFR 107.601-107.620.

As always, if you have any questions regarding shipping dangerous goods contact ICC Compliance Center at 1.888.442.9628 (USA) or 1.888.977.4834 (Canada).

Placarding
Is a Placard Required?

Placards on a truck

Answers from the Helpdesk

Placarding is one of the more complicated areas of the hazardous materials regulations. There are so many variables and exceptions, no wonder it becomes confusing.

Let’s practice using a real helpdesk question.

What placards are required for each shipment (49 CFR or TDG)? Write down your answer before scrolling down to read the answer.

SHIPMENT 1: 

9000 LBS (4082 KG) CORROSIVE UN1719, (ALL NON-BULK PACKAGING)

 SHIPMENT 2: 

(ALL NON-BULK PACKAGING)

9000 LBS (4082 KG) CORROSIVE UN1719
1500 LBS (680 KG) CORROSIVE UN1791

1500 LBS (680 KG) CORROSIVE UN3264
1500 LBS (680 KG) CORROSIVE UN3265

 SHIPMENT 3: 

(ALL NON-BULK PACKAGING)

200 LBS (91 KG) CORROSIVE UN1719
200 LBS (91 KG) CORROSIVE UN1791,

200 LBS (91 KG) CORROSIVE UN3264
200 (91 KG) LBS CORROSIVE, UN3265

Click here to see the 49 CFR answers »
Click here to see the TDGR answers »

49 CFR Regulations

The placarding requirements are found in Part 172.500 of the Hazardous Materials Regulations. The general rule is going to be:

If in bulk, you always need a placard.

If non-bulk, then it depends on if the hazard class is in Table 1 or 2, and the amount that is being shipped.

Also, in most cases, 4 placards are required, one on each side and one on each end.

When shipping in bulk, a UN number is required on the placard. You will find this referenced in the marking section Part 172.331.

(a) Each person who offers a hazardous material to a motor carrier for transportation in a bulk packaging shall provide the motor carrier with the required identification numbers on placards or plain white square-on-point display configurations, as authorized, or shall affix orange panels containing the required identification numbers to the packaging prior to or at the time the material is offered for transportation, unless the packaging is already marked with the identification number as required by this subchapter.

(b) Each person who offers a bulk packaging containing a hazardous material for transportation shall affix to the packaging the required identification numbers on orange panels, square-on-point configurations or placards, as appropriate, prior to, or at the time the packaging is offered for transportation unless it is already marked with identification numbers as required by this subchapter.

For non-bulk, the following references are also important:
The reference for this is 49 CFR §172.301(a)(1)(3):

“(3) Large quantities of a single hazardous material in non-bulk packages. A transport vehicle or freight container containing only a single hazardous material in non-bulk packages must be marked, on each side and each end as specified in the §172.332 or §172.336, with the identification number specified for the hazardous material in the §172.101 Table, subject to the following provisions and limitations:

(i) Each package is marked with the same proper shipping name and identification number;

(ii) The aggregate gross weight of the hazardous material is 4,000 kg (8,820 pounds) or more;

(iii) All of the hazardous material is loaded at one loading facility;

(iv) The transport vehicle or freight container contains no other material, hazardous or otherwise; and

(v) The identification number marking requirement of this paragraph (a)(3) does not apply to Class 1, Class 7, or to non-bulk packagings for which identification numbers are not required.”

Answers:

Which placards are required according to 49 CFR?

Shipment 1: 4- Class 8 placards are required with UN1719

Why? The class 8 placard is required as it is being shipped as a single commodity in non-bulk exceeding 8,820 lbs (4000.68 kg)

Shipment 2: 4- Class 8 placards are required, UN number not required

Why? The class 8 Placard is required, the UN number is not required because there are multiple hazardous goods being shipped on the same shipment

Shipment 3: No placards are required

Why? No placards are required because Class 8 materials appear on table 2 and is under 454 kg (1001 lbs)

Transport Canada

The placarding requirements are found in Part 4 of the Transportation of Dangerous Goods Regulations (TDG).

The following are some general rules for placarding under the TDG regulations in Canada.

In most cases, four placards are required, on both sides and both ends of the transport unit.

A placard is required if the chemical is in a quantity or concentration for which an ERAP is required.

If 500 kg or more of a quantity is being transported of one hazard class a placard is required.

4.15.2 UN Numbers on a Large Means of Containment says:

UN numbers, except UN numbers for dangerous goods included in Class 1, Explosives, must be displayed on a large means of containment in accordance with subsection 4.8(2) if the dangerous goods

(a) are in a quantity or concentration for which an emergency response assistance plan is required; or

(b) are a liquid or a gas in direct contact with the large means of containment.

4.16.1 Placarding Exemption for Dangerous Goods Having a Gross Mass of 500 kg or Less says:

Subsection (1) provides an exemption from placarding requirements if the dangerous goods in or on a road vehicle or railway vehicle have a gross mass that is less than or equal to 500 kg.

Subsection (2) sets out which dangerous goods cannot be counted in the 500 kg and are, therefore, subject to the placarding requirements.

  1. Except in the case of the dangerous goods listed in subsection (2), a placard is not required to be displayed on a road vehicle or railway vehicle if the dangerous goods in or on the road vehicle or railway vehicle have a gross mass that is less than or equal to 500 kg.
  2. The exemption set out in subsection (1) does not apply to dangerous goods
    • (a) requiring an emergency response assistance plan;
    • (b) requiring the display of a subsidiary class placard in accordance with section 4.15.1;
    • (c) included in Class 1, Explosives, except for
      • (i) explosives referred to in subsection 4.17(1), and
      • (ii) explosives included in Class 1.1, 1.2, 1.3 or 1.5, if
    • (A) the explosives are not subject to special provision 85 or 86 and have a net explosives quantity that is less than or equal to 10 kg, or
    • (B) the explosives are subject to special provision 85 or 86 and the number of articles of explosives is less than or equal to 1000;
      • (d) included in Class 2.1, Flammable Gases, if the road vehicle or railway vehicle is to be transported by ship;
      • (e) included in Class 2.3, Toxic Gases;
      • (f) included in Class 4.3, Water-reactive Substances;
      • (g) included in Class 5.2, Organic Peroxides, Type B, liquid or solid, that require a control or emergency temperature;
      • (h) included in Class 6.1, Toxic Substances, that are subject to special provision 23; or
      • (i) included in Class 7, Radioactive Materials, that require a Category III – Yellow label.

Answers:

Which placards are required according to the TDGR?

Shipment 1: 4- Class 8 placards are required UN number not required

Why? Class 8 placards are required, because this shipment exceeds 500 KG, but the UN number is not required as there is no ERAP and it is not in a large means of containment

Shipment 2: 4- Class 8 placards are required, UN number not required

Why? Placards are required as the shipment is over 500 KG, but UN numbers on the placards are not required because the ERAP is either non-existent or is not met.

Shipment 3: No placards are required

Why? Because no ERAP are met, and the quantity is less than 500 kg.

No Placards are required for class 8 hazardous material for shipments under 500 KG and when no ERAP is met.


ICC Compliance Center has a variety of tools and “cheat sheets” to help you understand the placarding requirements. Visit our website for more information.

Oil drum spill
What to Do – Accidents/Incidents Involving Dangerous Goods

Hazmat Incident

Unfortunately, Accidents Do Happen

Dangerous goods, necessary for Canadians’ quality of life, are transported from one area to another across the country every day. These goods, which travel by road, air, rail, and sea, leave Canada by the same routes, railway stations, airports, and ports. All these displacements increase the risk of incidents harmful to human beings and the environment. Therefore, it is essential that manufacturers, shippers, carriers, terminal operators, users, and governments strive to minimize the risk of incidents and the damage they can cause.

Approximately 30 million shipments of dangerous goods are shipped annually in Canada, and 99.998% of them travel to destinations without any incident!

When a dangerous goods incident occurs, the person in possession of the dangerous goods at the time of the incident must call the relevant competent authority (usually the local police, or call CANUTEC at *666 / 613-996-6666 / 1-888-CANUTEC, or call the 24-hour number that appears on the transport document or in the case of an ERAP call that activation number).

When first responders arrive at the scene of an accident involving dangerous goods, they will consult the Emergency Response Guide (ERG). They may also contact CANUTEC for assistance.

CANUTEC is Transport Canada’s Canadian Transport Emergency Center where bilingual scientists are always ready to answer. They are trained in emergency response and are ready to assist when an accident happens involving dangerous goods. CANUTEC’s role is to provide technical and scientific advice in an incident involving dangerous goods and to bring together all persons involved in the incident. The CANUTEC’s staff handles nearly 1,000 emergencies and answers more than 22,000 phone calls every year!

Note that CANUTEC advisors do not go to the scene of an incident.

CANUTEC also provides a 24-hour emergency telephone service for registered Canadian shippers who enter the CANUTEC emergency telephone number (1-888-CAN-UTEC (226-8832) or 613-996-6666) on their dangerous goods shipping documents. The free online registration for this service is available on the CANUTEC website.

TDG Reporting Requirements

Newly amended, Part 8 (Reporting Requirements) of the Transportation of Dangerous Goods (TDG) Regulations improves the data collection process, increases risk analysis capacity and specify the reporting requirements.

Part 8 of TDG requires that CANUTEC be contacted in the case of:

  • a Release or Anticipated Release Report (Road, Rail, Marine);
  • a Dangerous Goods Accident or Incident Report (Air);
  • an Undeclared or Misdeclared Dangerous Goods Report (Air);
  • a Loss or Theft Report (Road, Rail, Marine, Air); or
  • an Unlawful Interference Report (Road, Rail, Marine, Air).

Part 8 has three tier reporting for road, rail and marine:

  1. Emergency report to local authorities if the release endangers or could endanger public safety* consult 8.2;
  2. A Release or Apprehended Release report, only if special requirements are met consult section 8.4;
  3. A 30-day follow-up report, if a release or apprehended release report was required, consult section 8.6.

*Note that public safety refers to safety related to human life and health, property and the environment.

Transport Canada released Safety Awareness Kits aimed at target audiences – First Responders, Communities/Municipalities, Industry and the General Public – containing valuable information on the Transportation of Dangerous Goods. You can consult them at:
Transportation of Dangerous Goods Safety Awareness Materials and FAQ webpage

Shipping by Road
TDGR US Import Cross-Docking – All We Want are the FAQs…*

Cross-Docking is Reshipping

On February 8 Transport Canada issued an addition to FAQ regarding the Transportation of Dangerous Goods Regulations (TDGR) Part 9, s. 9.4. This section deals with the re-shipping of dangerous goods (DG) received by road from the US when safety marks differ from those specified in the TDGR. In general, (more on this later**), TDGR 9.1 allows receipt of US shipments to first destination with the safety marks that were legally applied under 49 CFR at the US shipping point.

Cross-Docking

The FAQ defines “cross-docking” as “the process of transferring dangerous goods from one vehicle to another before reaching their final destination”. Changing drivers or tractor units does not trigger the term. When DG are cross-docked, Transport Canada considers this to be “re-shipping” and the provisions of TDGR 9.4 apply (note: although the FAQ refers to “reshipping” in quotes, the term is not specifically defined in the TDGR other than as described by s. 9.4).

Reshipping

Basically, the requirements in s. 9.4 are to remove placards which do not meet TDGR requirements and replace them with TDGR-compliant versions. Examples of these could be US “DANGEROUS” placards; or those with the midline adjusted (e.g. Class 7, 8, 9); or worded and “combustible” placards.
In addition, if means of containment (soon to become “packaging” we hope!) have labels or other safety marks differing from TDGR requirements, then the shipping paper must be annotated accordingly as indicated in s. 9.4 (2).

Part 10 is not referenced in the FAQ, but presumably similar logic will apply to cross-docking rail car shipments (TDG s. 10.4) – or to transfers between rail/road vehicles.

Just the FAQs

Although the author hasn’t seen anything in official consultation documents, statements in casual conversations on two occasions indicate that the current practise of including interpretative guidance as italicised text within the body of the regulations will likely be discontinued. Apparently, this very useful (in my humble opinion) practise is at odds with regulatory convention that expects only the mandatory legal requirements to appear in the regulation. FAQ are the preferred vehicle for the type of information we currently see italicised within the TDGR.

The FAQ referred to in this Blog is available at:
http://www.tc.gc.ca/eng/tdg/awareness-materials-and-faq-1159.html#a99_0

* with apologies to Sgt. Joe Friday/Jack Webb’s often misquoted statement:
http://www.snopes.com/radiotv/tv/dragnet.asp

** Reciprocity has its limits
Although we often hear of “reciprocity” for shipments inbound from the US, we must remember that it has limits. As referenced in the above-mentioned FAQ, the “inhalation hazard” version of Class 2.3 and 6.1 labels or placards are not acceptable even to first destination. The “regular” versions, applied with qualifying marks as required by TDGR SP 23 also need to be present. Similarly things done by US special permit- although potentially to be accepted to first destination under the CG I International Harmonization proposal- will not necessarily be approved for reshipping. Perhaps once the CG II is finalised we’ll have another Blog on this aspect…

Lithium
Lithium Battery Labels as of Feb 1, 2017

Both 49 CFR and TDG are expecting to harmonize lithium battery labels into the regulations; however, both regulations are pending. HM-215N (49 CFR) was recalled, and will not be reissued for at least 60 days.

Transport Canada has not provided an ETA on the harmonization.

Find out the correct labels to use below:

 

TDG
HO! HO! HO! TDG Under the Tree – Proposed Harmonization

The November 26th Canada Gazette I provides an early “gift” to the regulated community which may help relieve boredom over the holiday season.

Harmonization Transportation Style

Although the DG world (unlike WHMIS/OSHA) has been fairly well harmonized under the UN Recommendations for some years now, there have been issues from time to time with; the editions standards referenced in the TDG regulations (TDGR); differences between DOT/TDG requirements for pressure receptacles; and confusion in the status of cross-border shipments when special permits (DOT) or equivalency certificates (TDG) are applied to consignments (for brevity, we’ll refer to these both under the generic term “permit for equivalent level of safety”- PELS).

Ambling Along

An example of the former is the Table of Safety Standards in TDGR 1.3. The recognized edition of the UN Recommendations is the 17th Ed. (2011)- despite the fact that we’re currently looking at the 19th Ed. (2015) and are on the verge of the 20th (2017). This can lead to confusion since the modal regulations are usually consistent with the current edition of UN Recommendations.

To help resolve this issue, and presumably to reduce the amount of catch-up amending necessary, Transport Canada proposes to expand the listing of “ambulatory references” – refer to the latest edition (i.e. “as amended from time to time” rather than a specific date)- for equivalency of other regulations and some selected technical standards.

Canada-US Regulatory Cooperation

Issues reviewed at the joint Canada-US Regulatory Cooperation Council are also appearing in this harmonization proposal.

The US DOT is following a parallel track, with proposed amendment HM-215N published in September, to include similar provisions in 49 CFR. (see Barbara’s Blog of Oct. 13, 2016)

U.S. Publishes Proposed Rule HM-215N on International Harmonization

Key aspects of this initiative include expanding the reciprocity provision to fill and use US DOT pressure receptacles in Canada rather than only accepting those which had been filled within the US. Requalification, repair, marking, etc. must be in accordance with the country where it’s done.

TDGR Parts 9 and 10 also would extend recognition of US PELS regardless of the existence of a Transport Canada-issued corresponding permit, reducing the need to apply for, or determine the existence of, a similar provision. The PELS number would have to appear on the shipping document. Application of the reciprocity would continue to be disallowed for things that are forbidden in TDGR or are not regulated under 49CFR. Each country’s regulations would still have to be reviewed regarding general special case/special provision exemptions.

Additionally, “one-time movement approvals” (OTMA) for moving damaged tank cars, for example, would be recognised in each country to facilitate dealing with situations where the car must be moved to safely empty and repair the means of containment.

Safety Marks, Labels, and Placards

Lithium Battery Mark, Label and Placard

The adoption of the “new” lithium battery mark will replace the provision for marking equivalent wording on packages subject to SP 34. This includes indicating the UN number of the contents instead of just the battery type by name. All SP34 packages will require the mark, but a notation on documentation will no longer apply.

The TDGR also will adopt the new lithium battery Class 9 label for packages requiring this hazard label. As with the other modal/US regulations/proposals, the mandatory use will have a 2-year transition period.

Placarding May not be Harmonized

The TDGR amendment as proposed will require the use of a placard corresponding to the lithium battery Class 9 label instead of a standard Class 9 placard when means of containment require placards.
This is at odds with the 49CFR HM-215N proposal to maintain the use of a “regular” Class 9 placard despite the new lithium battery Class 9 label (“…Class 9 placards, when used, must conform to the existing requirements in …172.560”).
Ditto final (i.e. adopted) IMDG Code Amendment 38-16 -see 5.3.1.1.2: “For dangerous goods of class 9 the placard shall correspond to the label model No. 9 as in 5.2.2.2.2; label model No. 9A shall not be used for placarding purposes.” – i.e. must use the standard Class 9, not the lithium version.

Updating to Current International Regulations

Other proposals will “catch up” the TDGR with many of the changes in the UN Recommendations regarding classifications and listings in TDGR Schedule 1 with applicable editing of special provisions (e.g. specific entries for the various types of combustion engines, solid/liquid polyester resin kits, etc.).

Overpack Marking Clarified

Included in 2 dozen or so “typographical corrections and minor miscellaneous changes” is the removal of the need to mark “Overpack” when the DG marks are visible; but when it is required it must be in minimum 12 mm high characters.

Other Safety Marks (in addition to lithium batteries discussed above)

The proposed amendment will adopt the international standard Class 9 convention of underlining the “9” on both labels and placards.
Also the new “fumigation” label is included in the Appendix to Part 4, presumably to catch up with the information included in the amendment in SOR/2014-159.

Missing from this proposal however, is the requirement for a 2 mm thickness for the inner border line on labels, as currently specified in the UN Recommendations, 49 CFR, IATA DGR and the IMDG Code.

The amendment will not, of course, be finalized until published in Gazette II, with a proposed 6 month general transition period (but until Dec.31, 2018 for the lithium battery mark and lithium battery Class 9 label). There is a 60 day comment period on the proposal and the detailed version may be consulted at:

http://www.gazette.gc.ca/rp-pr/p1/2016/2016-11-26/html/reg3-eng.php


If you have any questions about these changes and how they can affect your operations, please contact us here at ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).

Danger Placard
Does My Personal Vehicle Need Placards? – Answering Regulatory Helpline Questions

One of the great services offered by ICC Compliance Center to our customers is our Regulatory Helpline. Current customers can call in and have basic questions answered for free. Our Specialists are trained in all of the transport regulations for the US and Canada. We also answer questions surrounding HazCom2012 and WHMIS 2015. A great benefit of our service is getting the customer a “right” answer. Occasionally it may require some information gathering, but we still give you an answer. Being relatively new to our Helpline, I tend to take a bit longer to get an answer.

I mention this because of an interesting question that came in last week. A customer called and posed the following question:

If I want to move a container of oxygen in my personal vehicle, does [my vehicle] have to be placarded?

On the surface this seems easy enough to answer, but in reality that is not the case. As I discovered a good bit more information was needed to formulate a “right” answer.

Answer Step 1:

What is meant by “a container of oxygen”? This information is needed for several reasons. We have to determine if what the caller has is truly a hazardous material/dangerous good. For example, is it pure oxygen or is it a blend of oxygen and nitrogen similar to a SCUBA tank? One is much more dangerous in the event of a fire than the other. In this case, the container is of pure oxygen.

Answer Step 2:

What is the description of the container? The assumption is the container is a cylinder. If so, what size? There could be exemptions in place depending on how large or small the container is. The caller said it is a steel cylinder that weighs 15 kilograms and it has TC on the outside.

Answer Step 3:

Where is this person located? We need to have this information so that the proper regulations can be checked. If the caller was in the United States, but I used Canada’s transport regulation to answer that may not have worked. In this case the caller is from Canada. This is helpful because there was a mention of using a “personal vehicle”. In the U.S. this could have led to a discussion of Materials of Trade exemptions. Since Canada does not have that type of exemption it would make no sense to go over them with the caller.

Answer Step 4:

Now we almost have the whole picture. We have a steel cylinder full of pure oxygen that weighs 15 kilograms. It is being transported in a personal vehicle in Canada. With all of that information, the caller MAY meet the 150 kilogram Gross Mass Exemption in the Canadian Transportation of Dangerous Goods regulations per Section 1.15. This prompted one more question. Was this cylinder purchased by the caller at a location open to the general public? The answer was “yes.”

Final Answer:

The final answer is “no”, the caller is not required to placard his personal vehicle to transport a cylinder of oxygen. Per the 150 kilogram Gross Mass Exemption, he does not need a shipper’s declaration, training or … any sort of “dangerous goods safety marks”. This section also includes placards. He may voluntarily display it per Section 4.1.1 of the regulation but there are multiple provisions.

So while this looks like a complicated process, it is in fact not. As long as we have all of the information, answering your questions can be quite easy. Give us a call today to see just how easy it is – ICC Regulatory Helpline 855.734.5469. We are here to help. As always, ICC Compliance Center is here to help you with all of your regulatory needs.

Canada!
Transport Canada Consults on Revised Packaging Standard TP14850

A draft version of the 3rd Edition of Transport Canada’s TP14850- Small Containers for Transportation of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 & 9” is available for public review and comments will be considered when received by October 13.

Transport Canada began planning the review in Q3 2015 and announced the formation of a Technical Committee in a public notice in early 2016.

The Committee was formed in April; consisting of participants representing interests from production, marketing, distribution, sales, use and/or regulation of dangerous goods packaging. The Committee met initially by phone and, following the review of a preliminary draft, followed up with a meeting in Ottawa in May to provide input for the aforementioned first draft.

The intent of the 3rd Edition is to incorporate updates from the 19th (2015) Edition of the UN Recommendations and possibly prepare for inclusion of aspects of the 20th Edition expected in 2017.

Some features of the first draft, in addition to the harmonization with the 2015 model UN Recommendations, include:

  • clarification of the requirements for packaging distributors to provide instructions on assembling and closing packages;
  • removal of some redundant provisions that are already in the regulations;
  • clarification of special cases and expanding some Substance Specific Provisions (SSP) removing the need for certain Equivalency Certificates (e.g. UN3268);
  • locating SSP within the packing instruction (PI) applicable to the UN number, similar to the UN Recommendations & the IMDG Code practise;
  • requiring Transport Canada “acceptance” of alternative leakproofness testing procedures;
  • consideration of using plastic containers beyond the 5-year limit when the use is under the control of a fleet operator registered with Transport Canada;
  • mandating a periodic (5 year) retest by manufacturers of prototypes from production of approved containers

Following the comments received on the first draft of the 3rd Edition of TP14850, the Committee will meet again in Q4-16 to review the comments and provide input for a 2nd draft. The 2nd draft is expected to be released for additional public comment in the Spring of 2017. The objective is to release the final 3rd Edition in October 2017.

To obtain a copy of the first draft click here »

Motorcycles – Yes, They are Dangerous Goods

If you are feeling “Born to Be Wild” – Steppenwolf and looking to race down life’s highway on two wheels this summer, but short on time, or looking for an even better adventure across the pond, fly your bike and meet it there.

Wait! You can’t just show up at the airport and check in your motorcycle. Did you know that a motorcycle is considered to be a dangerous good? Under the IATA regulations, a motorcycle is classified as UN 3166, Vehicle flammable liquid powdered, hazard class 9; and therefore needs a shipper’s declaration form.

What does this mean to the average motorcycle enthusiast? It means that you need to seek the advice of a dangerous goods consultant, who specializes and can assist in providing instruction on the preparation of the motorcycle, and provide the proper signed shipper’s declaration.

According to Air Canada, some of the requirements at time of tender include:

  • The fuel tank must be drained as far as practical; and fuel must NOT exceed ¼ of the tank capacity
  • All batteries must be installed and securely fastened in the battery holder of the vehicle and be protected in such a manner as to prevent damage and short circuits
  • Spare key, to be left in the ignition
  • Alarm (theft-protection devices, installed radio communications equipment or navigational systems must be disabled
    Air waybill number (booking number)
  • Saddle bags may be filled with equipment, parts, etc. An itemized list of the content of the saddle bags must be provided at time of tender.
  • Personal effects such as a clothing, toiletries and luggage cannot accompany the motorbike. (Dangerous goods such as lubricants, spray paints etc. must be left behind)

ICC Compliance Center offers declaration services across Canada, and can work with you to find a consultant in other countries as well. Contact us at least 2 weeks before you plan to start your adventure.

Have fun and contrary to the opening statement, no racing! Simply stay safe enjoy the sun on your face and the wind in your hair!

Transport Canada Amends TDG Reporting Requirements

On June 1, 2016, Transport Canada issued an amendment to the “Transportation of Dangerous Goods Regulations” (TDG) under the Transportation of Dangerous Goods Act. This amendment substantially revises the requirements for reporting spills of dangerous goods during transportation. It also addresses changes to air shipment of lithium ion batteries and makes various minor corrections and changes. The “Reporting Requirements and International Restrictions on Lithium Batteries Amendment” reflects concerns that the previous requirements for reporting spills, called “accidental releases,” was inefficient and didn’t allow the reporting parties to evaluate the risk to the public when deciding if a release had to be reported.

Continue reading “Transport Canada Amends TDG Reporting Requirements”