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.
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…
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…