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 126.96.36.199). 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…
Those who follow the IATA DGR will have an idea of many of the changes resulting from the UN Recommendations expected to result from the changes in the 20th Edition of the commonly titled “Orange Book”.
Those who work with other modal/government regulations may not be familiar with changes that will likely follow in those regulations as all or part of the amended Model become incorporated.
Changes in Terminology
As often happens, terminology changes were introduced to this edition to clarify or technically improve concepts covered by the regulations. Throughout the document the term “risk” has been replaced by “hazard” to reflect the intent of referring to a danger.
Similarly, most references to “devices” now refer to “articles” which is defined in 188.8.131.52 as including “machinery, apparatus or other devices”.
New UN Numbers
UN3535 to UN3548 have been added to the collection:
UN3535 refers to “TOXIC SOLID, FLAMMABLE, INORGANIC, N.O.S.”
UN3536 is a new “LITHIUM BATTERIES INSTALLED IN A CARGO TRANSPORT UNIT” applicable to either ion or metal-based batteries.
UN3537 through UN3548 cover a sequence of listings for “ARTICLES CONTAINING…, N.O.S.” applicable to a variety of Class 2-5, 6.1, 8 and 9 dangerous goods.
The additional entries result in related changes to classification sections and special provisions.
As we’ve seen over the last few years regulation of lithium battery regulations continues to evolve.
Some time ago, I wrote a blog that outlined the benefits and regulations of the 4GV packaging. Often referred to as Variation 2 packaging, we discussed the main benefit of this packaging is that different types of inner containers can be used whether they are liquid in glass bottles, metal cans, plastic bottles, or different types of solids. But what about non-4GV packaging (basically any combination package that has a UN marking on it that excludes the “V”)?
Can changes be made to the inner packaging? Here are some questions below that will clear up some of the confusion.
Replacing Plastic with Metal
UN Marking: 4G/Y5.1/S
Q. So what we have here is our PK-1GRPC kit. This includes a plastic HDPE bottle and a corrugated box. Can this box also be used to ship dangerous goods with a tin plated paint cans?
A. No. This box was tested at the lab with a one gallon HDPE bottle, so in this case you would not be allowed to use this box with any other type of inner container with a different structural design. 178.601 (g) (1) (i) (a) TP14850 184.108.40.206 (a)
Substituting an Insert for Absorbent or Adding Additional Cushioning
This September, ICC was offered an interesting opportunity – presenting a class on North American hazardous materials regulations in Switzerland! So, I gathered my passport and computer, and set off for Europe.
The course was organized by SAFETY Training Plus GmbH, a well-known provider of dangerous goods training in Germany and Switzerland. However, SAFETY Training Plus found that many of its customers were looking for help with shipments to North America. Although European and North American regulations are usually based on the UN Recommendations for the Transport of Dangerous Goods (better known as the Orange Book based on its cover), a number of variations still exist between the various countries and regions.
For example, a European shipper to the United States might be puzzled about why a product not classified as an environmental hazard under the EU regulations (ADR/RID) or the International Maritime Dangerous Goods Code (IMDG) for ocean would have to be treated as such for entry into the U.S. Surprise! It’s the Hazardous Substance rule, involving a list of over a thousand chemicals that are classified as environmentally hazardous in Title 49, U.S. Code of Regulations (49 CFR). Another shipment may hit a snag entering Canada due to Canada’s requirement for an Emergency Response Assistance Plan. This requirement usually applies to high-risk goods in large means of containment, but may sometimes affect smaller materials Continue Reading…
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 dealer‘s 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 except the dealer’s name and address which can appear in either language.
Any label information in addition to the mandatory requirements discussed above (i.e., directions for Continue Reading…
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.
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 the surface of fiberboard. If fiberboard absorbs too much water, the box may have difficulty maintaining strength and integrity. In fact, the inner fluting can Continue Reading…
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.
Together makes Corrugated Fiberboard
Corrugated Fiberboard can come with various amount of flutes within the linerboard, usually ranging from single wall to triple wall.
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.
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 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.
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 notice is expected to be in place until HM-215N is release, or this notice is otherwise rescinded or otherwise modified.
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:
Articles of any type, liquid or solid, may be assembled and transported using variation packaging if the following conditions are met below:
The same cushioning material must be used as what the package was tested with. If the package was tested with an absorbent pouch and 2 pillows, the same must be used during the shipping process. The same goes for any fiberboard insert associated Continue Reading…