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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…
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 “symbol” along 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’ (ie. not a ‘pictogram’), or, just the name of the symbol, on the SDS [Hazcom 2012, Appendix D, Table D.1, Item 2(b); WHMIS 2015 Hazardous Continue Reading…
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.
According to the revised standard the required information regarding chemical hazards must be communicated on labels using visual cues for awareness to the users. Labels, defined in the HCS, are Continue Reading…
It appears that the Globally Harmonized System in the US is still not quite ready.
The Office of Information and Regulatory Affairs (OIRA), under the Office of Management and Budget (OMB), began a review on October 25, 2011, of a Notice of Proposed Rulemaking, Docket No. OSHA–H022K–2006–0062, from the Occupational Safety and Health Administration (OSHA). This amendment would adapt the hazard communication requirements of Title 29 of the Code of Federal Regulations (29 CFR) to reflect the international standard known as the Globally Harmonized System, or GHS.
As its name implies, the OMB’s mission is to assist the President in overseeing the preparation of the federal budget, and review and oversee financial implications of new regulations. The office must review regulations before they can proceed to final publication.
The review of the proposed rulemaking was extended for a month in January, with the OMB issuing their completed report on February 21, 2012. The report indicates that the amendment is accepted “consistent with change”. This indicates that the agency, though accepting the amendment in general, will require some changes before being finalized. However, the report from the OMB does not indicate if these changes will be minor or much more substantial.
The phrase "consistent with Continue Reading…