ICC's Regulatory Helpdesk
Regulatory Helpdesk: July 30

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…

Compressed Gas
CSA Cylinder Standards – June 2018 Update

compressed gas cylinders

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.

Details

Although the 2 Continue Reading…

TDG Standards on the Move – Explosives Plus TP14850 & TP14877

TDG Update - Red and white semi truck on the highway

CGSB.43-151 Class 1 Explosives Draft Update

There have been some recent developments in 2 of the packaging standards of potential interest to the DG community involved with Canadian transportation.

  • TP14850- Class 3-6.1, 8 and 9 Small Packaging pre-publication 3rd Edition-Transition to CGSB
  • TP14877- Rail Transition to CGSB

CGSB-43.151 Explosives Packaging Standard

Transport Canada has provided notice of a consultation on a proposed update of the Canadian General Standards Board (CGSB) standard “Packaging, Handling, Offering for Transport and Transport of Explosives (Class 1),” CAN/CGSB.43-151.

The new edition, to replace the current 2012 edition, will update the list of UN numbers and packing instructions to align with the UN Recommendations 20th edition; and update references to other dangerous goods container standards.

Also proposed in the draft are packing instructions for UN large packaging (ELP) to supplement the existing standards for IBC and portable tanks.

New Canadian domestic packing instructions (CEP 01) for jet perforating guns, used in oil well completion, are also included in the draft. Previously packaging of these (UN0124 and UN0494) had to be authorized on a case-by-case basis as referenced in EP 01.

CEP 02 replaces the previous EP 17 for highway and portable tank transport.

In common with the recent approach in other Canadian standards, changes to the organization of information, as well as regulatory requirement updates and additional definitions are part of the draft.

New or clarified definitions are provided for “IM” and “IMO-type” Continue Reading…

TDG
Transport Canada Moves to Update ERAP Requirements

TDG Update - Man Staring in to warehouse

TDG Emergency Response Assistance Plans (ERAP) Update

On June 30, 2018, Transport Canada issued a proposed amendment to Part 7 of the Transportation of Dangerous Goods Regulations (TDG). This part covers the requirements for Emergency Response Assistance Plans, or ERAPs. Details can be found on Government of Canada’s website.

Canada’s ERAP requirements are unique, not being adopted from the UN Recommendations on the Transport of Dangerous Goods. 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.) Since the Lac-Mégantic disaster in 2013, improving ERAP requirements has been a particular concern of Transport Canada’s.

The June amendment has four main goals:

  1. To clarify how an ERAP should be implemented;
  2. To enhance emergency preparedness and response;
  3. To reduce the regulatory burden for those affected by the requirement; and
  4. To make some general “housekeeping” changes to keep all parts of the regulations harmonized.

Clarifying Implementation of ERAPs

Currently, the regulations are unclear as to how exactly 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 Continue Reading…

Lithium
Detained Battery Shipment – Fixed!

AA sized lithium battery cells

What Happens When Watt-Hour is not Marked on Each Battery?

Well a few things – beginning with the shipment being stopped until the error is corrected by trained personnel like us.

It is mandatory to have the watt-hour marked on a lithium ion battery (unless it’s manufactured before January 1, 2009), and batteries that don’t display this mark are considered non-compliant for transport. To bring it in to compliance each battery must be marked with the watt-hour.

Doesn’t seem too bad, right? Wrong.

Imagine individually marking 11,600 little batteries.

These batteries were the size of AA batteries. Each individual battery was packaged in its own little box. Like a lipstick box. Then these little boxes (20 in total) were placed in a larger box. Then the larger boxes were placed inside a bigger cardboard box. Never had I done a job this tedious. Add to this trying not to break the small flap on the little boxes when opening these boxes.

The first day was a disaster as we weren’t prepared with the right tools. Finger nails were hurting from opening the little boxes. That night ideas were rolling in everyone’s head on how to efficiently do this job as it took 7 hours, and 2 people to finish 800 batteries. At this rate it would take 2 weeks to do this job.

The next day a tool was brought to speed up Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 4

Variation packaging cushioning material, excepted quantity packaging, UN packaging testing, distributor deadlines for WHMIS 2015, Mexico GHS, and compatibility

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.

Variation Packaging (4GV) Cushioning Material

Q. Can I substitute a different cushioning material in a variation box?
A. In general: “No.” When a UN-standardized package is specified. The various regulations (49 CFR, IATA DGR, IMDG Code, and TDGR), or the standards referenced within them, restrict the user to assembling the package according to the manufacturer’s instructions. These instructions are based on the components used in the submitted test/design reports on which the approval is based. 49 CFR §178.601(g)(4)(iv) even goes to the point of specifically requiring the same type of cushioning as was used in the submission.

Excepted Quantity Packaging

Q. Is it always necessary for the shipper to have performance test results on packaging used to ship “excepted quantities”?
A. This depends on the mode or jurisdiction of transport. 49 CFR [§173.4a(f)], IATA DGR (§2.6.6) and IMDG Code (§3.5.3) all require that the shipper ensure that testing has been done and documented. This doesn’t need to be externally certified or approved. TDGR [§1.17.1(3)] does not require specific testing, only that packaging is “… designed, constructed, filled, Continue Reading…
Lithium
How to Ship Damaged or Defective Lithium Batteries

Swollen lithium polymer batteries. Dangerous and harmful electronic waste

Regular Damaged or Defective or Dangerous Damaged or Defective?

There is a fair amount of interest in the topic of preparing Damaged or Defective (DoD) lithium batteries for transport and how to make a determination of the degree of hazard they present.

The current (20th) 2017 Edition of the Recommendations on the Transport of Dangerous Goods (UN Model) Regulations have addressed the former (packaging for transport) aspect, but the documents currently posted have not yet established firm protocols for the latter.

The situations involving recalls of defective, unsafe batteries and incidents during transportation has sustained the efforts to find better ways of dealing with them. The topic has been under discussion at the United Nations Sub-Committee of Experts on the Transportation of Dangerous Goods (TDG) in most sessions over the last several years.

For this discussion we’ll refer to cells/batteries that do not meet the UN Manual of Test criteria due to damage or defect, without specific safety hazards, as “regular” DoD; and those that “are liable to disassemble rapidly, react dangerously, produce a flame or a dangerous evolution of heat, or produce a dangerous emission of toxic, corrosive or flammable gases or vapours” as “dangerous” DoD.

This distinction is proposed for clarification in the next version (21st Edition) of the UN Model. See, for example, working document ST/SG/AC.10C.3/2018/51:
http://www.unece.org/fileadmin/DAM/trans/doc/2018/dgac10c3/ST-SG-AC.10-C.3-2018-51e.pdf

Batteries or Reactive Substances?

As a technicality, we should pause to consider the basic Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: May 21

Limited quantities, manufacture expiry dates, regulated or not regulated, and reclassifying flammables to combustibles.

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.

Limited Quantity Limits (TDG)

Q. Customer called and asked if he can ship a box with 16 liters of UN1219 in inner containers as a limited quantity through ground in Canada.
A. The max according to the TDG is 1 L for limited quantity, so they can’t ship limited quantity.

Manufacture Expiry Dates

Q. Can you tell me if both the manufacturer and expiration dates are required to be on each label? Or if we have the option of just stating the manufacture date and verbiage that states the product is good for two years after the manufacture date? Also, would you happen to know which regulatory agency monitors these types of things?
A. The expiration date or manufactured date are not requirements of a GHS label. OSHA and The Globally Harmonized System of Classification and Labelling of Chemicals considers this supplementary Information, which is permissible as long as it doesn’t contradict any other information on the label, but they are not required components of the label.

Combustible materials (49 CFR)

Q. We have some drums of a material classified as NA1993 Combustible Liquid and only ever Continue Reading…

TDG
New Draft: CGSB Standard 43.145

Man preparing shipment

TDG Large Packaging

Still Time to Review the draft “Design, Manufacture and Use of Large Packaging for Transportation of Dangerous Goods in Classes 3, 4, 5, 6.1, 8 and 9

Transport Canada provided notice last month of the availability of a draft Canadian General Standards Board (CGSB) standard for large packagings for specified classes of dangerous goods (DG). The contents of the draft are largely based on the UN “Recommendations on the Transport of Dangerous Goods Model Regulations” (UN TDG Model) 20th Edition.

The draft is open for comment by interested parties until June 8, 2018.

Similar, but Not Identical

Although the current draft is based on the 20th edition of the UN Model, there are some differences – for example: the Canadian TDG regulations (TDGR) have not yet updated Schedule 1 to the current UN numbers above UN3534; TDGR cite Class-specific standards for certain DG (Classes 1, 2, 6); and not all of the lithium battery packaging has been incorporated.

The CGSB-43.145 proposal does, however, contain a supplementary instruction for UN2794 and UN2795 permitting these batteries to be shipped unpackaged on shelving that is permanently fixed within a vehicle. This LP801 standard presumably replaces equivalency certificates providing the option to battery distributers and members of automotive industry associations.

The UN Model and CGSB 43.145 are similar in restricting the use of large packaging to the lesser hazardous Classes/Divisions, typically at the packing Continue Reading…

Repacking Dangerous Goods
Can I Ship Dangerous Goods to Brazil with my TDG Training Certificate?

Calcium Oxide UN1910 UN Packaging

The answer is: No.

Shipping Dangerous Goods from Canada to Brazil

Now the Background Story

I was forwarded an email from a very nice lady (let’s call her Jane), who is registered to take our public TDG training coming up in a couple of weeks at our Delta, B.C. office.

She said she has some product that needs to be shipped to Brazil, which she was told was dangerous goods. Jane wanted to know if we sell corrosive labels and if we can do up the dangerous goods document or if she would be able to do it herself after she takes her training. I asked Jane to call me; sometimes it is just easier to talk on the phone.

Training or Repacking?

While on a call I asked her if she is taking our public air (IATA) training and she said, “No. Just the TDG“. I explained to Jane that by completing the TDG training she will be certified to ship, handle, transport, and import dangerous goods within Canada via road, rail, and domestic marine; therefore, even after she takes her TDG training she can’t ship dangerous goods to Brazil.

After clarifying this with her I advised that if she wants to ship this product to Brazil she will need to either take an air training course or use our repackaging service.

I provided her with a repackaging quote and explained, “this is Continue Reading…