So, you want to bend the rules? What happens when you have a scenario where following the regulations to ship your dangerous goods becomes impractical to the point of impossibility?
This blog entry will speak to what the process is for applying for an Equivalency Certificate in Canada as per the Transportation of Dangerous Goods Clear Language Regulations.
Generally when people ship dangerous goods, the process becomes a matter of reading and complying with everything the regulations state. However, below are some scenarios where following exactly what the regulations state is… shall we say… less than ideal.
Al wants to ship some large batteries for equipment within Canada with classification:
UN 2794, Batteries, Wet, Filled With Acid, Class 8, P.G. III
His dilemma is that when a new battery is commissioned, the outer package is generally discarded due to space limitations. In many cases these batteries were installed prior to the packaging requirements of Part 5 of the TDG Regulations.
Al wants to ship this without UN approved packaging.
Bill wants to ship a MRI machine that contains liquid helium, classification:
UN 1963, Helium, refrigerated liquid, Class 2.2
His dilemma is that his MRI machine is what contains the Helium and it is not in an approved means of containment. He requires the helium to remain in his equipment during transport in order to keep the magnet cool.
Bill wants to ship this Continue Reading…
Just like the rest of society, the transportation industry is not immune to scammers trying to help themselves to some unearned cash. And in the days of e-commerce, it’s getting even easier.
Recently, our attention was brought to some scammers fraudulently representing themselves as the International Air Transport Association (IATA). These fraudsters have concocted an e-mail scolding the recipients for not paying for their “Annual Review of Codes,” and threatening that if the deadline for payment is missed, recipients will lose their “assigned IATA airline codes.” They then instruct recipients to obtain a repeat copy of the invoice (which, of course, the targets never received in the first place) from an e-mail address that looks similar, but not quite identical, to the official IATA one.
Of course, if you do not actually run an airline, you may quickly recognize that something is wrong. But the scammers obviously hope that such official-looking invoices may fool some recipients into paying first, and asking questions afterwards.
Here’s what the current scam text looks like. Note, of course, that scammers will frequently change the wording slightly to avoid being pegged as spam.
“Dear IATA Code Holder,
Your company have exceeded the deadline for the Annual Review of Codes. As of this time we still have not received payment for your 2013 Annual Review fees. Please be advised that failure to pay the invoice for your Continue Reading…
What information do you need on a shipping paper or an emergency response situation? Depending on the country you are shipping from, the answer can vary.
The Transportation of Dangerous Goods Regulations, Part 3, (1) 3.5(f) and (2) outlines the requirements for the shipping document. These requirements include:
Having the words “24 hour number” followed by an active 10-digit telephone number xxx.xxx.xxxx,
- Being able to reach the consignor immediately, and
- Providing technical assistance without breaking the connection. An outside agency that is registered with the emergency response provider may be used.
The requirements outlined in the 49 CFR [172.201(d) and 172.604(b)(1)&/or(2)] states that if the shipper is using an Emergency Response Information provider or an agency on their behalf, a 24-hour telephone number and name of the person or contract number must be added to the Emergency Response Shipping paper.
Recently, an FAA inspector visited a customer of ours and the Emergency Response information on the shipping document was something they checked. As part of their audit, they called the number listed on the form to verify that the contract number was indeed valid.
Remember, during a transport emergency, first responders rely on this information to react to the situation quickly and to react with the correct protective and fire-fighting measures.
Do you need a 24-hour emergency response service?
ICC has a 24-hour phone number available in the USA, Canada and internationally.
Call us today: Continue Reading…
Here at ICC Compliance Center and depending on your application, we may ask you for a CAS number. When we create labels on demand for your exports, among other services, we will ask you to provide us with the chemical name and CAS number and then we are able to provide as few as 100 GHS compliant labels and/or a compliant SDS.
Compliant GHS Chemical Label:
A CAS number or CAS Registry number is a unique identifier for every chemical substance dating back to 1957. The Chemical Abstracts Service (CAS) is the responsible entity that is responsible for assigning a unique number to every chemical described in scientific literature.
A CAS number itself has no meaning. Its primary use is to avoid confusion between chemicals with similar names, or individual chemicals that may have multiple names. It is also used to identify the chemical when a generic or trade name is used.
A CAS Registry Number is separated by hyphens into three parts, the first consisting of up to seven digits, the second consisting of two digits and the third consisting of a single digit.
In short, the CAS number can be particularly useful in database searches because it allows you to search a database and easily pull every record for that particular substance or chemical. For example, “Methanol” is known by multiple names such as methyl alcohol, methyl hydrate, hydroxymethane and Continue Reading…
As everyone gathers to enjoy time with friends and family for the 4th of July, it is important to remember that one of our favorite traditions can be dangerous. There are hundreds of injuries and fatalities each year due to fireworks.
“Fireworks on the Fourth of July are an American tradition,” said U.S. Transportation Secretary Ray LaHood. “We want to make sure the traveling public and commercial operators know how to safely transport fireworks so we can all enjoy these colorful displays, both small and large.”
Fireworks are regulated under the hazardous materials regulations. They are a class 1.4G explosive. When transporting fireworks, you must follow the rules as outlined in the regulations including: shipping papers, loading/blocking/bracing, placarding, security plans and you must be a trained person. Workplaces must also meet the requirements under the OSHA regulations, including personal protective equipment and the use of fire extinguishers.
There is a variety of guidance documents available to keep you, your family and your employees safe. Keep safety in mind so everyone has an enjoyable holiday.
OSHA’s Guidelines for the Pyrotechnics Industry – Fireworks Display
Industry Alert for Fireworks Shippers, Distributors, and Carriers
ICC Compliance Center is thrilled to announce that Toni-Ann McLean, Regulatory Specialist has successfully completed the requirements for registration in the SDS and Label Authoring Registry Program. As such, Toni-Ann has demonstrated that she has the knowledge and skills to create SDS and labels, specifically relating the Globally Harmonized System. Toni-Ann will now be Registered Specialist , SDS and Label Authoring,# 206738. Toni-Ann took the exam while attending the Society for Hazard Communication semi-annual conference in Nashville in April.
The SDS and Label Authoring registry program recognizes chemical hazard communication and environmental health professionals who specialize in authoring safety data sheets (SDS) and labels. This registry program was developed through a partnership with the Society for Chemical Hazard Communication (SCHC) to assure the recognition of competent professionals. To gain the Registered Specialist: SDS and Label Author credential, an individual must meet the established qualifications and must demonstrate competency in the skills and knowledge defined by the program’s Body of Knowledge. This AIHA Registry Program is the first EHS Specialty Credential that provides recognition for individuals who have expertise in this area.
ICC Compliance Center offers services relating to SDS and labels for North America and Europe. Contact us for more details on how we can help.
I admit it. I am a hazmat nerd. I’m not sure exactly when I realized it. Maybe it was the first time I recited a section of 49CFR from memory during a class. Maybe it was when I decided to keep a copy of the ERG in my car so I could identify the UN numbers on placarded trucks. Regardless of when it happened, I now embrace my hazmat nerdiness… even my Facebook profile lists my occupation as “Hazmat Nerd”. Obviously, this is a great benefit when I’m on the job. I have a knack for remembering obscure requirements and knowing where to find them in the appropriate regulation. I enjoy hunting down the answer to tough questions or unusual situations. I like having customers who think of me as their go-to source for their questions.
One aspect of being a hazmat nerd is that I am always noticing things that relate to my job, even when I’m not at work (hence the ERG in my glove compartment). There was the time that I was doing some geocaching (my obsession…I mean hobby) in Buffalo. I had parked the car and jumped out to go find a cache. On my way, I had to dodge some large puddles due to a recent downpour. As I approached one of the puddles, I noticed something odd. There was a Flammable Continue Reading…
Online shopping – whether from large internet companies such as Amazon, to individual vendors on sites such as eBay – has grown, well, explosively, in the past few years. But with this growth has come a headache for shippers, receivers and regulators. How do you handle online purchases of product that may actually be classified as dangerous goods (or, in the US, as hazardous materials)?
Often, people are not aware that common consumer products may be considered hazardous for transportation. These include:
- Aerosol sprays
- Cosmetics, such as nail polish remover or perfumes
- Flammable liquids, such as paints and adhesives
- Smoke detectors containing radioactive sources
- Refrigerants (including those in equipment)
- Fire extinguishers
- Goods with internal combustion engines
- Lithium batteries, including batteries packed in or with electronic equipment
There are, of course, provisions in various regulations such as the US Hazardous Materials Regulations of 49 CFR (Title 49 of the Code of Federal Regulations), and Canada’s Transportation of Dangerous Goods (TDG) Regulations. Small packages of dangerous goods can often be shipped more easily under the provisions for Limited Quantities or Consumer Commodities. These provisions, however, do vary from country to country.
In addition, the regulations for shipment by air are much more stringent. Shipments by carriers who specialize in fast delivery may need to comply with the system for air transportation from ICAO (International Civil Aviation Organization), and IATA (International Air Transport Association). These may require additional packaging, labeling Continue Reading…
Most people have seen, at one time or another, ads for new children’s products or household/personal use products on the television, or online, with what appears to be an ‘amazing’ deal… those famous ‘limited time offers’ with the amazing deal to ‘purchase now and you’ll get two products for the price of one’.Shoppers need to keep in mind that it’s not always just about the ‘deal’.
When shopping online or via mail, shoppers need to keep in mind that some products may be prohibited in your home country and others still may have special safety requirements that are actually more strict than the safety requirements for the same product in other countries. The more you know about the health, environmental and user risks of the product you are about to purchase, the better you can protect the health and stability of both you and your family. If you do not practice responsible shopping, you can end up putting yourself and your family into some sticky situations.
One example of the consequences of not practicing responsible shopping is during the purchase of a children’s car seat in Canada. Perhaps you’ve seen an ad online for a really good deal on a car seat that is coming from the United States and you happen to live in Canada. Car seats for children are regulated by both Health Canada and Transport Canada, and must pass Continue Reading…
Did you know that if you are shipping your dangerous goods in bags or sacks, you may not be compliant with TDG Regulations?
In Part 4 of TDG, section 4.10(3) states that a label must be displayed on any side of the means of containment other than the side on which it is to rest or be stacked. Most bags of fertilizer etc. that I have seen have the safety marks on the “front” side of the bag. When these bags are loaded onto a skid, the side that has the safety marks now supports a bag that has been placed on it, or in other words, the bags are stacked on the skid. Or if the bags are placed “face” down on the skid, then this side is the side intended to rest. This now means that the safety marks are on the wrong side of the bag.
In order to be compliant with this section, it would mean affixing your dangerous goods safety marks to the narrow edge of the bag. If you feel that this cannot be done on your bags, you may want to consider applying for a Certificate of Equivalency from Transport Canada or discussing this further with a Transport Canada inspector.