Regulatory Helpdesk: October 2, 2017

Top 4 Questions From the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

#4. Shipping Sodium (UN1428) by Air (USA)

Q. The Customer asked if Sodium (UN1428) can be shipped by air using a plastic bag as an inner container inside of a 4GV box.

A. Per the 49 CFR 172.102 Special Provision A20, Plastic Bags are not allowed to be used as inner receptacles in combination packaging by aircraft.


#3. When to Use Bilingual Packaging (Canada)

Q. Does every word on [my] packaging need to be in French and English to sell in retail stores in Canada?

A. Canada has the federal Consumer Packaging and Labelling Act and the Consumer Packaging and Labelling Regulations. That Act and Regulation requires 2 mandatory items to be bilingual. Those items are the product identity, and the net quantity. The dealers name and place of business can be in either English or French according to those laws.

However, the guide specifically states: Subsection 6(2) of the Consumer Packaging and Labelling Regulations requires that “all” mandatory label information be shown in English and French Continue Reading…

Single Packaging
What About Cobb … Testing?

Splash drops of water on cardboard

What is Cobb Testing?

If you previously read my blog Anatomy of A box, you learned about the various components that make up a corrugated box. The construction of a box can become even more complicated for dangerous goods. Not only do you need to provide strong, durable corrugated boxes that can withstand drops and movement during transportation, but they must also be able to withstand various weather conditions including snow and rain.

How can box manufacturers and test labs ensure that dangerous goods packaging is safe to use when it gets wet? This is where the Cobb test comes in handy. This test helps determine the quantity of water that can be absorbed by the surface of paper or board in a given time. In this case, the less water that absorbs into the corrugated, the better. In fact as per § 178.516 of CFR 49 as well as TP 14850 7.8 this test is a requirement.

Cobb Testing

Why Cobb Testing?

Cobb tests are performed, because paper and fiberboard tend to attract and hold water molecules from the surrounding environment. The Cobb test is essential as it tests the ability of the paper to resist the penetration of water and quantity of water absorbed by Continue Reading…

Single Packaging
Anatomy of a Box

Anatomy of a Box - UN Packaging

Fiberboard’s Organs

As we know, the human body is made up of many essential components, from the smallest microscopic cell to the largest of organs. The same goes for corrugated boxes, but instead of cells, there are tiny fibers, and instead of organs, there is inner fluting. All components are necessary to have strong and sound structure. Let’s take a look at the anatomy of a box.

The Corrugated Fiberboard

What exactly is a box mostly made of? Corrugated fiberboard. The corrugated fiberboard is essentially the skeleton of the box. Made up by thousands of tiny fibers, it is created by a corrugator. A corrugator is a large machine that combines two different kinds of paper to create cut sheets of corrugated fiberboard. The flat, facing sheets are referred to as the linerboard. Linerboard is a thin fiberboard that makes up the outer layer. Flutes are inner arches attached in between the linerboards with a starch based adhesive. They are designed to resist pressure and bending in all directions.

corrugated cardboard linerboard
Linerboard

corrugated cardboard Fluting
Fluting

Together makes Corrugated Fiberboard

Fiberboard box

Corrugated Fiberboard can come with various amount of flutes within the linerboard, usually ranging from single wall to triple wall.

Single Face: Consists of 1 linerboard and 1 flute

Single Continue Reading…

PHMSA Update
A Small Victory for Harmonization … For Now (HM-215N)

PHMSA Withdraws Final Rule

—PHMSA Update HM-215N

The Pipelines and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) has withdrawn a Final Rule that was intended to be published in the Federal Register on January 26.

The Final Rule, HM-215N, would have updated the U.S. “Hazardous Materials Regulations” to reflect international standards. This was due to the new administration’s Regulatory Freeze executive memorandum, issued January 20, 2017.

Harmonization

HM-215N would have harmonized the 49 CFR regulations to the latest version of the UN Recommendations on the Transport of Dangerous Goods, the ICAO Technical Instruction’s on the Safe Transport of Dangerous Goods, the International Maritime Dangerous Goods Code.

New lithium battery label     New Lithium Battery Mark and Pictogram
New marks and labels introduced in the upcoming international regulations.

 

This delay has made it particularly confusing for shippers of lithium batteries, who have transitioned to the new handling mark, and hazard class 9 label, shown in these international regulations.

Usage

Last week, PHMSA issued a Notice that allows offerors and carriers to use the 2017-2018 versions of the international regulations without fear of enforcement. In addition, it is allowing users to mark and label packages in accordance with either the 2015-2016 or 2017-2018 IATA/ICAO and IMDG regulations.

This notice is limited to 49 CFR Parts 171.4(t) and (v). This Continue Reading…

UN Packaging New Labels
Test Your Dangerous Goods Packaging Knowledge

Test what you know about dangerous goods packaging regulations.

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Single Packaging
Benefits and Rules of Variation Packaging

Standard 4G UN combination packaging is tested in a specific configuration with specific inner packaging and components. When using standard 4G UN combination packaging, you must use very similar components that match the configuration of the way the package was tested in the lab. This can make it rather difficult at times to find a packaging solution to meet your specific needs. In comes variation packaging to save the day! Variation packaging allows you to use various types of inner packaging, such as bottles, cans, jars, and smaller plastic containers while using a fiberboard box that meets the UN specifications and the ISTA requirements.

This packaging is ideal when a combination of different inner components is needed, or when the party responsible for shipping has a variety of products to ship. This type of packaging carries labeling marks designated 4GV. Below is a list of some rules and regulations per 49 CFR 178.601 (g) (2) if you decide to utilize variation packaging:

  1. Articles of any type, liquid or solid, may be assembled and transported using variation packaging if the following conditions are met below:
  2. The same cushioning material must be used as what the package was tested with. If the package was Continue Reading…
Frequently Asked Questions
FAQ – GHS Symbols on SDS in Canada and the United States

Frequently Asked SDS Symbols Questions

How many times have you thought you understood a requirement, only to second guess yourself about whether you got that right or not? It could be something relatively straight forward, or something a bit more complicated. Everyone has these moments occasionally, especially with the implementation of GHS around the world. At ICC, two of the questions that seem to pop up from time to time, revolve around symbols on SDSs.

Do GHS pictograms have to appear on an SDS?

The answer: No. The ‘pictogram,’ specifically, doesn’t have to appear. This answer, in part, boils down to terminology.

In both Canada, under WHMIS 2015 Hazardous Products Regulations (HPR) requirements, and in the United States, under Hazcom 2012 requirements, Section 2 of an SDS is required to list the label ‘information elements’ that are applicable to the product. Hazard ‘symbols’ being one of the required ‘information elements’.

In both the United States and in Canada, ‘pictogram’ is defined as a “symbolalong with other “elements, such as a border or background color”. So a complete GHS ‘pictogram’ is actually two part; a graphic symbol on the inside, and a frame surrounding it. Both countries include an allowance only to show a ‘symbol’ Continue Reading…

HazCom 2012
HazCom Labeling – Are You Ready?

Deadlines Approaching

As of now we should all know or have at least heard that OSHA adopted the hazardous chemical labeling requirements in the latest revision of the Hazard Communication Standard. By aligning with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals or GHS, OSHA helps ensure uniformity in the labeling of chemicals. These updates will provide workers with better information on safe handling and usage of hazardous chemicals. Therefore, providing a systematic approach for avoidance and exposures to hazardous chemicals, reducing injuries and illness through worker awareness.

The upcoming June 1, 2015 effective date, manufacturers, importers and distributors can maintain compliance with the requirements of HazCom 1994 or the revised standard. However, manufacturers, importers, and distributors may start using the new labeling system in the revised Hazard Communication Standard (HCS) before the June 1, 2015 effective date. Hazardous chemicals shipped after June 1, 2015, are required to be labeled with the identified elements including pictograms, signal words, hazard statements and precautionary statements. Distributors have until December 1, 2015 to ship containers labeled by manufacturers or importers in compliance with the HazCom 1994, after which it is required to comply with the HazCom 2012.

Label Elements

According to the revised standard Continue Reading…