I was scrolling through my news feed this morning when a post from the local Fire Department info page caught my eye. I read the statements “Suspicious Package. Niagara County Hazmat Team and US Airforce Hazmat Team from Niagara Falls Air Base requested to scene.” and I immediately started to look for more information. The location of the scene is not only within a few hundred feet of Niagara Falls and the Canadian border, but it is approximately 8 miles from my office and only 1.5 miles from my daughter’s elementary school. In this industry, I hear about hazmat incidents every day, but this one hit close to home.
Thanks to social media, I was able to get real time updates on the situation from the Facebook pages of The Niagara Gazette, Niagara County Fire Wire and Niagara Falls Fire Department Calls and Info. These sources were reporting information broadcast over public scanners. Local news stations hadn’t yet started to report the story. An envelope with a suspicious material was discovered in the human resources department. Employees were evacuated as a precaution. The Air Reserve team was on site first, with the county team in route to assist them. The hazmat team was directed to take samples, check the package for any additional suspicious content and to photograph the package. Initial data lead the Hazmat Command to Continue Reading…
Labels, Markings, Placards, and more (OH MY!)
All in “Consolidation Bin” and “Overpack” amendments
As promised late last month, Transport Canada has published the Dangerous Goods Safety Marks (commonly referred to as the “12th”) Amendment to the Transportation of Dangerous Goods regulations (TDGR). The stated purpose of this amendment is to bring the TDGR a little closer to accepted international (UN Model, ICAO, IMDG) and US 49 CFR practices as well as improved communication of hazards to emergency responders. In addition the November 2013 & January 2014 proposed amendments have been issued under the title “Update of Standards”.
These regulations are “in force” on July 14 and 15 (respectively), 2014 – but the regulations existing on the day prior to these dates may continue to be used for 6 months following the “in force” dates.
These changes are arguably the most significant since Amendment 6 – if not since the basic “Clear Language” TDGR.
The TDGR now recognize the 17th (2011) edition of the UN Recommendations (“Orange Book” – despite the existence of the 18th – 2013 Ed.)
The current Parts 4.15 & 4.16 have been completely re-written with separate sections added to highlight areas that used to be in the Table to Part 4.15. The new Part 4.16 deals with the revised requirements for Danger placards and the previous “500 kg placarding exemption” is expanded Continue Reading…
Updated Safety Marks
Reliable sources have indicated that the December 2012 proposal to overhaul placarding and other safety markings is expected to be published in the Canada Gazette Part II on Wednesday, July 2, 2014.
This amendment is intended to improve the harmonization between the marking requirements in the Canadian TDGR (Transportation of Dangerous Goods Regulations) and the various current international (UN Recommendations, 49CFR, ICAO, and IMDG) regulations.
Although not an exhaustive list, significant changes, based on the original Gazette I notice, include: introduction of defined “overpacks” and their markings, implications in the LQ (“Limited Quantity”) provisions, etc.; phasing out of the older Class 5.2, LQ, Marine Pollutant, Fumigation marks in favor of the international versions; relaxation of the need to remove safety marks while any quantity of DG remain; completely re-working the Part 4.15 placarding requirements, including severely restricting the use of the “Danger” placard (e.g. only for loads of “small means of containment”), limiting the 500 kg exemption options; allowing the use of 2 placards or 4 labels (with UN #s) on IBC (“intermediate bulk containers”) totes; adding a requirement to mark “toxic-inhalation hazard” on Special Provision 23 DG packages; and other changes.
Word has it that the amendment will take effect July 14, although (again based on the original proposal) there may be transitional provisions for some aspects.
ICC is always up to date with current workplace Continue Reading…
Is everything in your workplace safe? Have you complied with all the regulations that apply? Are workers following safe procedures at all times? If you can’t say, “yes” to these questions, you may need an audit.
A safety audit is more than a quick look around. It’s defined as a planned and documented observation and evaluation of the workplace, looking at a specific set of behaviours or information. Audits can be targeted at many different safety issues.
- General workplace safety, such as eliminating clutter;
- Technical aspects, such as fire or electrical safety;
- Procedures such as machine guarding or lockout; and
- Regulatory compliance, such as occupational health and safety, or transportation regulations.
Keeping track of your observations is important. Auditors will use a checklist of things to look for, and to evaluate them in an objective format. An example of a checklist for office safety can be found on CCOHS’s website. Note that checklists should identify specific issues, and either judge them on a pass/fail scale, or a more detailed format that may grade performance as excellent/satisfactory/poor/unacceptable.
While there are many resources available, your checklist should be customized for your specific workplace. The safety concerns in an office setting are quite different from those in a manufacturing area. Also, generic checklists may not address the regulations that apply to your workplace. For example, a checklist designed for the United States will include Continue Reading…
Many people these days are calling themselves regulatory specialists, dangerous goods experts, or health and safety experts. The dangerous goods/hazardous materials field is a detailed, comprehensive topic requiring hands-on experience and a strong technical understanding of topics directly related to the industries we serve.
Finding the right training company is critical to ensuring that the processes and procedures you need to continue operating remain uninterrupted. Here are some questions you should consider when looking for trainers with the ‘right stuff’:
We’ve got the right stuff. Contact us today and find out more!
Download our Regulatory Specialists Bio (PDF) and learn about our team
1) What are their qualifications?
- What education and knowledge do your instructors have?
Meet our regulatory staff »
2) What experience do they have?
- How many Fortune 500 or multi-national companies have they helped train?
- How many satisfied customers have they trained over the years?
- What associations do they belong to?
- How do they find out about pending regulatory changes?
3) What other avenues do they offer?
- Can they provide the products and services that they are teaching you to use properly?
4) What is their approach to training?
- Are they offering the same course to everyone?
- Where can they train?
- Are they educated in training adults?
- Do they have an online option?
View our training locations and accommodations »
5) Are they the only person that will be working with you?
- Are Continue Reading…
If you work outdoors or are exposed to extreme heat you could be at risk for heat stress. Everybody can handle a little stress, but too much stress, in regards to heated working environments, can quickly turn into much more serious conditions such as, heat stroke, heat exhaustion, heat cramps, rashes, and dehydration. Prevention of heat stress in workers is important. Recognition of potential elevated temperatures in the working environment is the responsibility of both employer and employee.
It doesn’t have to be really hot outside for heat stress to occur. Losing the opportunity to periodically cool down, rehydrate and rest allows the body’s temperature to keep rising. A person can get heat stress even when working in 70 degree weather. Air circulation, hydration, and frequent rest periods (or lack of all three) have the ability to amplify or diminish heat related symptoms. Employers should provide training to workers so they understand what heat stress is, how it affects their health and safety, and how it can be prevented.
Each year organizations like OSHA, and CDC publish warnings and potential health risks regarding the upcoming seasons. Below is the annual refresher on heat stress types and management provided by the CDC. Stay cool!
Heat stroke is the most serious heat-related disorder. It occurs when the body becomes unable to control its temperature: the body’s temperature rises rapidly, the Continue Reading…
Transport Canada Proposes Changes Requiring Classification Records, Shipper’s Certification for all DG in Addition to Rail/Crude Standards
The fall-out from the Lac Mégantic disaster, as well as earlier and subsequent incidents, has lead Transport Canada to propose changes to the TDGR (Transportation of Dangerous Goods regulations) that go beyond rail car design/evaluation and testing of crude oil.
Despite the titling of the January 11, 2014 Canada Gazette I “Proposed Regulations Section” – i.e. “Regulations … (Safety Standard TP14877: Containers for Transport of Dangerous Goods by Rail) …” – the proposal also includes 2 items applicable to all DG and modes of transport.
Proof of Classification: Part 2.2.1 would be added requiring all consignors offering or importing any DG to maintain records establishing proof of classification (& just an MSDS won’t do). The records (e.g.: test reports, documentation of how the information on an MSDS was used, etc.) would have to be maintained for each technical name for two years. See sections 2 through 4 of the Gazette notice.
Consignor’s Certification: Part 3.6.1 would be added, requiring a shipper (individual acting on behalf of the consignor) to sign one of 3 prescribed (as applicable to the shipment) statements on the shipping document, for any DG shipment, verifying that the consignment complies with the regulations in all respects. See sections 5 through 7 of the Gazette notice.
Crude Oil/Petroleum Distillates-Products: Special Provision 90 Continue Reading…
What does one do when the need to ship something outside the realm of “ordinary” arises?
Last month I had to ship a couple of small bottles of bromine for a client. It was more involved than I originally expected. Before even getting close to the bottle, I wanted to know what was so bad about it. Why is bromine hazardous?
I read through the MSDS to get an idea of what I was about to work with. This shipment was going by ocean so I also had a look at the IMDG code. According to IMDG, it has an extremely irritating odour, is a powerful oxidant, and is highly corrosive to most metals. Also, it is toxic if swallowed, by skin contact or by inhalation. Furthermore, it can cause burns to skin, eyes and mucous membranes. To say the least, it is pretty nasty stuff.
Here is the classification:
UN 1744, BROMINE, CLASS 8(6.1), PG I
As you can see, it is Packing Group I material. I went to IMDG packing instruction P804 to see what was required for packaging and found that it read completely different than the normal P001 and P002 that one frequently sees. This instruction lists four possible ways that this material can be packaged, all varying depending on what type of inner package is used to contain the actual liquid. To give you an idea, Part 1 refers to using Continue Reading…
Transport Canada on October 17, 2013 has issued a Protective Direction that requires any person engaged in importing or offering crude oil for transport to immediately test the classification of the crude oil and to provide those test results to Transport Canada on demand. Following testing, any person who imports or offers for transport UN 1267 or UN 1993 crude oil must immediately provide an SDS for the tested product via Canutec. Any crude oil moved under those UN entries that has not yet been tested must be carried as a Class 3, Packing Group I cargo. The Protective Direction has been issued following concern that the crude oil cargo involved in the fatal derailment in Lac-Mégantic in July was wrongly classified.
The receptionist brings you the business cards of two PHMSA auditors and tells you they are waiting to speak to you. What do you do?
Well, after taking a deep breath, you go introduce yourself and find out why they are there. A “surprise audit” is how they respond, and you think, “OMG, how can this be happening?” Once you regain your senses, you ask them more about the process and what they wish to see. When they ask you questions, be honest; don’t try to hide things – that will only get you in trouble.
First question: Where are the training records?
If PHMSA feels that you are a hazmat employer, you will have hazmat employees. Under 49 CFR 172.700 you are required to train employees in general awareness, function specific, security and safety training. You are required to have documentation of that training. It is required every 3 years.
There are several possible violations: failure to train and/or failure to document the training.
A violation for training is easy to avoid. Keep good records, and ensure all employees who could be considered hazmat employees are retrained every three years – without question!
Second question: Where are your packaging records?
What packaging are you using? Do you have a packing instruction sheet for that package on file? Are you preparing it as the manufacture said you should? Did the manufacture Continue Reading…