We Repack All Types of Dangerous Goods … Including Dead Bats!
I received a call from a local veterinarian who was looking to buy 2 labels, yes only 2 individual labels. We sell them in rolls of 500 so it is surprising when someone asks for 1 or 2 labels. She was advised by a carrier that all she needs is to put two “UN3373” labels and a label with the words “Biological Substance, Category B” on a package and send it out. The veterinarian called us to get two “UN3373” labels and a label with the words “Biological Substance, Category B” as told to her by the carrier. I advised her that she can simply write the words on the package as long as it’s legible and indelible but she said she was told it must be a label.
TDG Training to Ship a Dead Bat?
Of course this is when my brain starts thinking outside of the box (more than the conversation that is currently taking place). Then I asked if she was trained to ship dangerous goods and she said no. She was only doing what the carrier advised her to do. That’s when the regulatory specialist in me stepped up. I advised her she must have TDG training to be able to ship dangerous goods. I gave her a 5 minute crash course Continue Reading…
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#2. Certifier’s Signature (Canada)
Q: Can the 49 CFR certification statement be used on Canadian TDG shipping documents for shipments between two points in Canada, having only a signature for the certifier’s name?
A: TDGR 3.6.1(1)(a) does not restrict the use of the 49 CFR statement to US bound/origin shipments. TDGR 3.6.1(2), in conjunction with Transport Canada (TC) Safety Awareness Guidance Bulletin RDIMS#11829346 (August 2017), does not require that the individual’s name be a signature; but if a signature is used it must be clearly legible, identifying the individual, to be compliant.
#1. Refrigeration Regulation (USA)
Q: We need to ship a refrigeration unit (UN2857) that contains a small amount of non-flammable, non-toxic gas. How is this regulated?
A: In general, REFRIGERATING MACHINES, UN2857 are regulated as Division 2.2 dangerous goods, with no packing group. However, small units can usually be shipped as exempted dangerous goods, with no significant requirements, if they contain no more than 12 kg of non-flammable, non-toxic gas as a coolant, or no more than 12 Litres of ammonia solution.
For Canadian shipments under the Transportation of Dangerous Goods Regulations, this provision can be found in Part Continue Reading…
One aspect of the International Harmonization amendment (SOR/2017-137) of the Canadian Transportation of Dangerous Goods Regulations (TDGR) that did not receive a lot of attention is the change in Special Provision 23. This special provision (SP) deals with the assignment of markings on containers and descriptions on shipping documents for entries related to goods which exhibit inhalation toxicity. Although the basic concept for classification remains the same- i.e. gases in Class 2.3 and Class 6.1 with associated inhalation toxicity. The majority of the latter are in PG I, but there are several PG II entries invoking SP23).
Marking – Keep It Simple?
A significant difference is the change in wording applied to means of containment (MoC). Following the transition period, markings required under SP23 must read “inhalation hazard” for all entries except UN 1005 (anhydrous ammonia). This eliminates the previous options of either “toxic by inhalation” or “toxic-inhalation hazard” (TBI or TIH).
UN1005 retains the previous wording “Anhydrous Ammonia, Inhalation Hazard” when the option of using the ammonia placard (rather than Class 2.3) is chosen. However small MoC of UN1005 will use the standard Class 2.3 label and “inhalation hazard” wording.
The new SP23 simplifies things somewhat by referencing the specific sections of Part 4 that apply- i.e. 4.18.2 for UN1005 and 4.23 for the rest. These sections include specifications for the height and Continue Reading…
An iconic show from the 1980’s was “The A-Team”. It was about a group of former military men who worked to help those in need by using their former skill set. A famous line from it was often said by John “Hannibal” Smith, played by George Peppard. At the end of many episodes he would say, “I love it when a plan comes together”. With the publication of Transport Canada’s Amendment TDGR SOR2017 – 137, we finally have a plan coming together for the transportation of Lithium Batteries.
Finally, all transport regulations – 49 CFR, TDG, IATA .and IMDG – are on the same page regarding the necessary marks and labels needed for transporting Lithium Batteries. All of the regulations even have the same transition times for when the new Class 9 Lithium Battery Hazard Class Label and new Lithium Battery Mark will be mandatory.
It’s Here, It’s Here! Feast Your Eyes on TDG International Harmonization 2017
(with apologies to “Genie” – aka the late Jim Backus …)
As predicted in last week’s blog on adoption of 2016 editions of CGSB standards, and reviewed in the Canada Gazette I (CG I) blog referenced therein, today’s Canada Gazette II (CG II) formalizes a variety of changes to the Transportation of Dangerous Goods Regulations (TDGR).
The amendment, despite the “International Harmonization” working title is officially referenced as SOR/2017-137 and essentially follows the CG I proposal reviewed in earlier blogs. However, as expected, there have been some changes.
An observation on the contents of this amendment – it appears that a rumoured dropping of italicized “guidance” text has begun in SOR/2017-137. The TDGR have been somewhat unique in this approach, but the word is that it is not in keeping with justice department philosophy that guidance material should be separate from the mandatory regulatory text – e.g. in an FAQ or other separate guidance document. This amendment incorporates several instances into the regulatory text and removes several others. Fortunately, the very useful listing of UN numbers pertaining to SP are retained at the end of each SP.
Transport Canada (TC) published information on some significant changes to the latest editions of standards for design/manufacture/use of packaging for bio/infectious substances and Intermediate bulk containers (IBC); CGSB-43.125-2016 and CGSB-43.146-2016 respectively.
The notices are presumably to give advance warning of changes to ambulatory (“dynamic”) references as indicated in the CG (Canada Gazette) I “International Harmonization Amendment” to the Transportation of Dangerous Goods Regulations (TDGR) expected, according to usually reliable sources, to be formalized by publication in the July 12 edition of CGII.
These will replace the currently references, in TDGR Part 1.3.1, to the 2002 and 1999 editions respectively. TDGR 5.16 will also be amended as the information appears in the 2016 edition of CGSB-43.125.
Transport Canada qualifies their information, cautioning the regulated community to carefully read the standards themselves to ensure they are aware of all changes as some may not be covered in the TC summaries. Although not mentioned directly in this TC material, rumour (again the “usually reliable sources”) has it that there will be a 6-month transition to comply with new editions of revised standards that have ambulatory references in the July 12 amendment.
Transport Canada, in what has become a series of proposed amendments, has issued a consultation White Paper on updates to the Transportation of Dangerous Goods (TDG) Regulations (TDGR) Part 12 Air.
This part references the International Civil Aviation Organization (ICAO) Technical Instructions (TI) along with TDG-specific supplemental requirements and exemptions. Some ICAO references date back to 2002 and changes to the TI have made some TDG provisions redundant or in need of updating. Also, there are some clarifications proposed to better align with the Canadian Aviation Regulations under the Aeronautics Act.
In the interest of clarification, Transport Canada hopes to increase the “one window” approach, wherein material is incorporated into the Part 12 TDGR rather than simply referencing an external document. This self-contained approach will still have to consider that changes to external documents might make references a more practical approach in some areas. The objective is also to harmonize this proposal with the “dynamic” (aka “ambulatory”) approach taken with the TDG International Harmonization Amendment.
Transport Canada has added a new item to the various informative offerings on the TDG home page. A link was added to an “Enforcement Action Summaries” listing to supplement existing guidance pages on topic-specific publications, orders, equivalency certificates, safety awareness material, etc.
This new page is intended to give the regulated community a better understanding of the types of offences that could subject them to penalties or orders to take corrective action. The objective is to provide an incentive to “deter wrongdoing” by demonstrating consequences to those who might choose to ignore the regulations; or, on a more positive note, provide an illustration of the advantages of understanding the regulations before an enforcement situation is encountered.
“I Fought the Law …” – or Ignorance is (Usually) No Excuse
Sections 22(3) and 40 of the TDG Act do provide for a defense of having taken “all reasonable measures” to comply with the Act. “Reasonable measures” would normally include acquiring and maintaining knowledge of the applicable regulations.
Although current enforcement activities are unlikely to result in the incarceration experienced by the misguided soul in Bobby Fuller’s 1966 classic hit, the TDG Act does provide for a range of consequences.
These consequences are represented in the published summaries under the following categories:
Are you a birdwatcher who’s spotted every owl and thrush, and wants to move on to a new field of study? Are you a model train hobbyist who wants to make sure your HO scale equipment accurately reflects modern regulations? Or are you a safety professional who deals with bulk dangerous goods in tank cars? If your answer to any of those questions is “yes,” the American Association of Railways (AAR) has published something that will make identifying a TC-111A100W5 or DOT-117R100W as easy as telling a Mourning Warbler from a Laughing Gull.
AAR’s Field Guide to Tank Cars, by Andy Elkins, is a resource for rail workers and particularly for emergency responders. Tank cars come in many varieties, and handling them safely or responding to spills means that you must know what type of car is involved. The Field Guide has been updated for its third edition to reflect current regulations and standards, which have changed over the past decade due to incidents such as the Lac-Mégantic explosion in Quebec.
Types of Tank Cars
The Field Guide starts with a discussion of the basic types of tank cars – non-pressurized tank cars (also known as “general service” or “low-pressure” cars), pressure tank cars for products such as liquid propane and cryogenic liquid tank cars, used for gases that are liquefied at low Continue Reading…
Transport Canada’s Standard TP14850, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8, and 9”
Transport Canada is well into the process of producing the 3rd Edition of TP14850. The current 2nd Edition (2010) has been in effect since it replaced the CGSB 43.150-97 standard in 2014. Changes to TP14850 are required to reflect current harmonization with the UN Recommendations, changes in the TDG regulations, improvements to ensure the integrity of standardized packaging, addition/clarification of Part 14 special cases, and simplify use of the standard.
Comments are welcomed until May 31, 2017.
An initial draft update was prepared for discussion in January 2016 and a committee of 30-40 stakeholders has been reviewing, discussing and proposing modifications between the initial draft and the May 2017 draft version of the 3rd Edition (by way of disclosure, the author of this Blog is one of the stakeholder representatives). The May 2017 draft follows these reviews and feedback from an initial 2016 public consultation.
Manufacturer’s Periodic Re-Test Obligation
A new requirement (Clause 7.1.7) requires the registered manufacturer to periodically, at least every 5 years, repeat performance tests on a representative sample. Typically, registration certificates are issued for 5 year periods.
One thing to note is that although TP14850 as currently written/proposed does not define “manufacturer” with respect to obligations under the standard, the application form for registration clarifies, in section 4 and Continue Reading…