Square on point with x marked out
Symbols in Transportation Regulations

Symbols in the IATA, IMDG, and 49 CFR

Solving the Mystery of the Regulation Symbols

As an avid reader and science nerd, the author Dan Brown is a different type of read. His lead character, Dr. Robert Langdon, is a professor of symbology. This means he studies and understands various symbols found in history and codes. Sometimes in transportation, we must be our own Dr. Langdon to decipher what the regulations are trying to tell us.

Here are some of the common symbols you could see with their meanings. Also included is where in each regulation you can find further information. By the way, have you purchased the March 2018 version of 49 CFR?

Symbols in IATA and IMDG:

  1. ■ The square: This symbol tells us new material has been added to the regulation or edition.
  2. ▲ The triangle: Here it indicates some part of that section of the regulation changed in some way.  It could be as simple as one word, sentence, or entire section that was reworked or clarified.
  3. ∅ The crossed-out circle: This one is a space holder showing some part or section has been removed, deleted or cancelled from the current edition. A very useful symbol, because it will keep you from looking for something that you knew was there but now can’t find.
  4. ☛ The pointing finger: Here is a symbol found only in IATA. It signifies this section or statement is more Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: March 26

Proper shipping name, 500 kg exemption, MANCOMM symbol, and a TDG error

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.

Proper Shipping Name (49 CFR)

Q. The customer wanted to know if they can print the product name in section 1 of the SDS next to the UN number on a hazard class label instead of the proper shipping name.

A. No. The proper shipping name on the outside of the box is a requirement per 49 CFR §172.301 (a) (1) and must be marked along with the UN number in a non-bulk packaging.

500 kg Exemption (TDG)

Q. Can I apply the 500 kg exemption when I have a mixed load where part of the load is excluded from using a DANGER placard under the 1000 kg Class restriction in TDGR §4.16 but the remainder is less than 500 kg gross? An example would be a consignment offered that included 1200 kg of Class 3, 100 kg of Class 8 and 300 kg of Class 9 (no ERAP required for either)?

A. In the DANGER placard scenario in 4.16, the Class 3 is restricted from using the DANGER placard specifically, based solely on quantity. Regular placarding requirements apply to the load based on the guidance text Continue Reading…

TDG Methanol Classification
Big Change in Methanol Transport Classification (TDG)

TDG Update - Man Staring in to warehouse

New Transport Canada Update Means Big Changes for Many Companies

Recently, Transport Canada posted on their FAQ web page, a few questions regarding shipping mixtures of Methanol.

The first three FAQs are for the most part, not surprising, with one exception in Question 2. These FAQ’s appear as follows (these FAQ’s are directly from their website): (keep reading, the biggest surprise is coming).

Question: How do I classify a product that contains methanol as the only dangerous good?
Answer: As per Section 2.3 of the TDG Regulations, when the name of a dangerous good is shown in Schedule 1, that name and the corresponding data for that shipping name (class, subsidiary class(es), packing group (PG)) must be used. Therefore, when methanol is the only dangerous good in the product and it meets the criteria for Class 3, Flammable Liquids, it should be transported as UN1230, METHANOL, Class 3 (6.1), PG II. Note that PG II is the only packing group available for methanol as per Schedule 1 of the TDG Regulations. Note: Subparagraph 1.3(2)(d)(iv) of the TDG Regulations allows a person to indicate the word “SOLUTION” or “MIXTURE” and also the concentration of the solution or mixture after the shipping name, as applicable.
Question: Tests results for a solution containing methanol as the only dangerous good indicate that its packing group should be III. How do I choose the proper shipping name?
Answer: Even if a dilution would lead to a Continue Reading…
TDG
March 2018 TDG TP 14877 Update

Railway Tanker Transporting Dangerous Goods

Rail TDG Standard TP 14877 Update

On March 15 Transport Canada released a notice on the intent to issue a new January 2018 edition of standard TP 14877 “Containers for Transport of Dangerous Goods by Rail” to replace the current 2013 (with Corrigendum) edition.

This is the penultimate culmination of the public process, in part arising out of the Lac Mégantic 2013 disaster, undertaken by a stakeholder Consultative Committee that began in February of 2016.

The main features of the proposed 2018 edition include:

  • Improved usability by incorporating external technical requirements, such as those in Protective Direction 34, 37 and 38.
  • Updated dangerous goods list to align with the 19th edition of the UN Model Regulations. Adjusted special provisions to reflect updated transportation requirements for Sulphuric Acid (UN1831) and Hydrogen Peroxide (UN2014 / UN2015).
  • Updated technical requirements for Class 3, Flammable Liquids and the new tank car specification known as TC 117.
  • Improved harmonization between tank car requirements in Canada and the US, including tank car approvals, tank car design requirements and a new mechanism to secure One Time Movement Approvals (OTMA) – Category 2.
  • Updated material of construction requirements for tank cars, including the addition of stainless steel, normalized steel for dangerous goods classified as a toxic inhalation hazard (TIH) and improved thickness requirements for new tank car construction.

Comparing the 2013 and 2018 Standard TP 14877

A brief comparison of the TABLE OF CONTENTS Continue Reading…

TDG
2018 TDG Registration and Fines FAQ

Red semi truck on highway

REGISTRATION and FINES and FAQs, OH MY!

February and March contain some interesting items potentially impacting the Canadian TDG landscape…

Registration-CID Consultation

Transport Canada, through a consultation notice published in late February, has solicited input from stakeholders on a plan to require those who handle/offer for transport, transport or import dangerous goods to register with Transport Canada.

The premise is that, “… public safety depends” on Transport Canada knowing who is transporting DG, including where, when, and how much. The main thrust of this proposal seems to be for targeting enforcement and consultation activities.

The proposal as currently presented does not appear to distinguish among the size, frequency, or nature of DG involved; and will require period re-registration with submission of data to the “Client Information Database” (CID).

There’s nothing in the posted information to indicate whether there will be a cost to “clients” for registration, in addition to the record-keeping burden they will bear.

(For those familiar with the 49 CFR §107 (Subpart G) requirement, intended to subsidize government response activities, this TDG version does not serve the same purpose.)

The only exemptions currently contemplated, extend to those falling under a TDGR Part 1 “special case” exemption. This contrasts with 49 CFR’s registration which has exemptions based on load sizes and hazard types.

The TC proposal and comment provisions are found at:
https://letstalktransportation.ca/cid

Contraventions Regulations

While not directly cited in the Transport Canada TDG Act or regulations, Continue Reading…

Regulatory Helpdesk: March 5

Batteries, Batteries, and more Lithium Batteries

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.

Why do I need an SDS for a Laptop Battery?

Q. We are shipping used laptops with batteries in the units from the US to HK via air. There are multiple manufacturers and models, are (M)SDS sheets required for each model? Our forwarder is requesting them in order to provide pricing.
A. To answer your question, it would depend on why the forwarder is requesting them. They may be asking for them to meet the written emergency response requirements. However, they could be asking for them for classification purposes to prove which part of the packing instructions these meet.

The SDS could tell them the watt-hour rating which would then drive which part of the instruction to use. Forwarders and carriers have a lot of leeway. I can only speak to what the regulations say. There is nothing in 49 CFR or IATA that indicates you must use an SDS. Most people tend to default to them because they meet so many parts of the regulations in one place.

Manufacturer’s Packaging (Lithium Battery)

Q. Should I remove the manufacturer’s packaging from lithium ion batteries being shipped by air under PI 965 Continue Reading…
Repacking Dangerous Goods
Help! My DG Shipment is Delayed

Help! My dg shipment was delayed

… and I was told to call ICC

It’s very common to hear this from our first-time clients whose dangerous goods shipment is delayed somewhere and now they are panicking to get it “unstuck”. I had a similar situation couple of weeks ago.

Delayed Shipment of Dangerous Goods

A gentleman was referred to us by an air carrier. Let’s call him Jack. Jack called asking if we can assist him with his package that is held up by the air carrier at the air carrier’s location. The air carrier was local to ICC; hence, they gave Jack our contact information. In an effort to understand what happened I asked him about what he was shipping and he told me very plainly, samples.

Now we all know “samples” can mean just about anything. Jack said that they were samples from their equipment and he was shipping them to the USA for testing. I asked him if he had the SDS for these samples and if he could email it to me along with the quantity per sample.

Apparently, there were two (2) 0.5 litre bottles inside this box. Jack is based in northern B.C. so his shipment was transported via ground and then it was supposed to go air from Vancouver, B.C. Jack mentioned that supposedly his shipment started to leak and it seeped to the outside of the package. The air Continue Reading…

2016 Emergency Response Guidebook (PDF Download Available)

2016 ERG Accidents

The 2016 ERG is Valid Until 2020

The Emergency Response Guidebook published by the US Department of Transportation, developed jointly with Transport Canada and the Secretariat of Transport and Communications is used by firefighters, police, and other emergency response personnel who may be the first to arrive on the scene of a transportation incident regarding dangerous goods/hazardous materials.

The primary purpose of the Guide is to provide immediate information regarding the chemical, therefore allowing them to take appropriate action to protect themselves and the general public.

Changes and Updates You Should Know About:

Free ERG 2016 Download

  • The 2016 edition includes changes such as:
    • Expanded/Revised sections on:
    • Shipping documents
    • How to use this guidebook (flowchart)
    • Table of placards and markings
    • Rail car/road trailer identification charts
    • Pipeline transportation
    • Protective clothing
    • A glossary
    • ER telephone numbers
  • New Sections include:
    • Table of contents
    • Information on GHS (Globally Harmonized System of Classification and labeling of Chemicals)
    • Information about ERAP (Emergency Response Assistance Plans)
  • Also …
    • Updated to the 19th revised edition
    • Updated guides

Plus much more…

 

A physical copy of the ERG is required for most drivers and emergency responders.


Download the free ERG 2016 PDF

The PDF downloads of the 2016 Emergency Response Guidebook have been provided by PHMSA.

Regulatory Helpdesk: February 12

Lithium Batteries, Placards, and SDS in the Workplace

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.

Lithium Batteries (Air)

Q. For PI 967 in IATA is the weight limit the weight of the equipment and battery inside of it or just the battery.
A. For all battery packing instructions in IATA it is always the weight of the battery itself.

Lithium Batteries (IMDG)

Q. Do “excepted” batteries require segregation from limited quantity packages under IMDG?
A. Under IMDG §3.4.4.2 it tells you that segregation requirements in Chapters 7.2 – 7.7 plus any information on Stowage in column 16b of the table do not apply to goods in limited quantity packages. Lithium ion batteries do not yet need segregation under IMDG either. It is only IATA that has implemented segregation this year as part of the packing instructions for shippers. IATA has also added batteries to the segregation table for operators, but it isn’t mandatory until next year and only applies to those in Section 1A and 1B not Section II.

Placards (TDG)

Q. Customer asked if his Class 8 material (UN 1830) needed to have a UN number on the placard if shipping 1 liter per package and 7 per tote for a total of 17 Liters for the shipment in Canada. Continue Reading…
Regulatory Helpdesk: February 5

Labels, Placards, Segregation, Documentation, SDSs & Emergency Response

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.

Here are the top 6 questions from last week.

SDS and Workplace Labels

Q. If I have a product like a concentrated cleaner which is corrosive to the eyes and skin that I water down at my facility, do I need a new SDS and workplace labeling?
A. You have 2 options. You can use the SDS as provided to create your workplace labeling. This may cause concern with your workers. However, it would be better for you to develop your own and re-evaluate the product using the hazards presented in the watered-down version. It is possible, depending on how diluted it is, to move into the irritation or non-hazardous range.

Listing Canutec or Chemtrec on Lithium Battery Marks

Q. Regarding the new battery mark, am I allowed to add “in case of emergency, contact Chemtrec”?
A. The regulations are pretty clear (DOT §173.185(c)(3) and IATA 7.1.5.5). What should be listed there is a phone number for “additional information”. There should be no extra phrasing other than phone number itself. As for listing Chemtrec, Infotrac or even Canutec, those are 3rd party Emergency Response Providers and would not be appropriate to include in that section of Continue Reading…