ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 29

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.

VOC/SDS

Q. We have a customer that is asking why the VOC content is “N/Av” on their SDS. It is required under OSHA or WHMIS?
A. According to US federal OSHA Hazcom 2012, and Canadian WHMIS 2015 rules, VOC information is not actually a mandatory item to appear in any section of a 16 Section SDS. It is commonly requested as a sub-item in Section 9, which is why ICC automatically includes the subheading. ICC does not calculate VOC levels, so the data would have to be provided by you. VOC information is common info to have for coatings, and has become important for coatings manufacturers due to Environmental regulations.

Lithium Battery Mark

Q. Customer called and asked if they ship UN3480 lithium batteries ground within the US, can they use the lithium battery mark instead of the class 9 lithium battery label, or do both have to be on the package. He also wanted to know what packing group lithium battery packaging had to be?
A. When shipping ground within the US, you are required to use a lithium battery mark OR a Class 9 lithium battery label. So just the lithium battery mark is fine in Continue Reading…
Securepacc Paint Cans packaging
Solving the Damaged Paint Can Riddle
Simulation of damaged paint cans during transport

As we all know, when shipping dangerous goods the shipper has the following responsibilities

  • Proper packaging.
  • Proper markings on the packaging.
  • Proper description on the shipping papers.

All 3 require training in hazardous materials.  However, what if the proper packaging isn’t available? After all, it is also our responsibility to prevent loss and damage during normal transportation and handling according to FedEx. In the last several years here at ICC, the need for paint can shippers that don’t leak and dent has gone through the roof. I have been contacted by several different large paint distributors all looking to solve the same riddle; how do I get my paint cans from point A to point B without damage and leaking? Challenge accepted! The first step is to decide what metric to use to determine if the packaging will damage or leak during normal transit.  Well a while back I wrote a blog on ISTA 6-FEDEX-A testing, http://blog.thecompliancecenter.com/ista-series-6-6-fedex-a-testing-vs-standard-un-testing/, which helps determine how well a package will perform out in the field. So I figured that would be a good starting point. Basically, our goal was to create paint can shippers that not only would survive the 10 drops from 30 inches up that the FedEx testing requires, but also have minimal to no damage on the paint cans at all.

Quart/Liter Shippers

Securepacc™ quart/liter shipper

During the testing Continue Reading…

Single Packaging
UN Packaging Need Forecasted to Grow!!!

Although the various regulations continue to change year by year, the need for UN packaging continues to be a necessity for dangerous goods shippers. In fact, a recent report predicts the need for UN packaging will continue to grow over the next decade. The growth of the UN packaging market is expected to be mainly driven by the need for safe and secure packaging for dangerous goods that need special handling. The report is based on a compilation of first-hand information, assessments by industry analysts, and input from industry experts and participants across the value chain. A request for a sample copy of the report can be made here.

Why is Growth Expected?

Customization of UN packaging for specific designs is expected to lead to new market avenues of growth for the global hazmat packaging market. For example, a wide variety of sizes of lithium batteries and other solid articles are out there on the market, and oftentimes stock items aren’t available that meet the specific dimensions that are needed. With reliance on items containing lithium batteries expecting to increase, so will the need to package them.

In addition, since non-compliance within the various regulations of hazardous materials can be costly due to fines and rejections, shippers and end users simply prefer UN packaging in order to comply with the regulations and maintain an element of safety within Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 22

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.

Lithium Battery Contained in Equipment

Q. We need to ship a lithium ion battery installed in a scooter. The battery is 36 volts and 14.5 ampere-hours which makes it 522 watt-hours. We are in California and need to get it to Seattle, Washington. We believe the box needs a class 9 label but aren’t sure about the other requirements.
A. Since it is an ion battery installed in equipment with a watt-hour rating of 522 that makes this a fully regulated shipment. Transport will likely be by ground which would fall under US 49 CFR. This makes it UN3481 Lithium ion batteries contained in equipment Class 9 with no packing group. Hopefully the battery doesn’t weigh more than 26 pounds. If it does, then we will need to have a slightly different conversation. So, following 173.185 of the 49 CFR you don’t need UN Specification packaging. As for the outside you will need the UN number, proper shipping name, and the Class 9 hazard class label (preferably the one dedicated to batteries). You will need a shipping paper completed for this as outlined in 172.200. No placards would be needed unless you ship 8820 pounds Continue Reading…
ICC Top 10 List
OSHA’s Top Ten Most-Cited Standards for 2018

It is the end of October. This is the signal for many exciting things. First, autumn is well under way; no more temperatures in the high 90’s. Second, pumpkin spice everything is available. My personal favorite though is plain old pumpkin pie. Finally, OSHA publishes their list of top ten most-cited standards for the previous fiscal year. This is always announced at the National Safety Council’s Congress and Expo. The timing fits with OSHA’s fiscal year that runs from October 1 through September 30. So, without further delay….

Most-Cited OSHA Standards for Fiscal Year 2018

  1. Fall Protection – General Requirements: Standard 1926.501 with 7,720 violations
  2. Hazard Communications: Standard 1910.1200 with 4,552 violations
  3. Scaffolds/Scaffolding: Standard 1926.451 with 3,336 violations
  4. Respiratory Protection: Standard 1910.134 with 3,118 violations
  5. Lockout/Tagout: Standard 1910.147 with 2,944 violations
  6. Ladders: Standard 1926.1053 with 2,812 violations
  7. Powered Industrial Trucks: Standard 1910.178 with 2,294 violations
  8. Fall Protection: Training requirements: Standard 1926.503 with 1,982 violations
  9. Machine Guarding: Standard 1910.212 with 1,972 violations
  10. Personal Protective Equipment and Lifesaving Equipment – Eye and Face Protection: Standard 1926.102 with 1,536 violations

Here are some things I notice about this year’s list.  First of all, the top five are the exact same ones and in the exact same order as last year, and all the way back to fiscal year 2014. The next four on the list are the same as well. The only difference is the order of them going back through Continue Reading…

Single Packaging
Change Notice: BX-72 AND BX-12QT20PT

Dear Valued Customer,

In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to the BX-72 (PK-RLGALC) and BX-12QT20PT (PK-MT12QT20PT).

  1. The clear tape required for closure of the BX-72 has changed from 3M #305 48 mm wide clear tape to 3M #375 48 mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.
  2. The maximum gross weight allowance for The BX-12QT20PT has been increased from 22.0 kg to 23.7 kg. The specification marking that is printed on the boxes has been updated to reflect this change.
Click here to view our packing instructions and certificate downloads.

If you have any questions or concerns, please contact our customer relations center in the US at 888-442-9628 or in Canada at 888-977-4834.

Thank you,

Michael S. Zendano

Packaging Specialist

ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 15

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.

Hazardous Waste and DOT

Q. Do I have to have hazardous materials training if I ship out hazardous waste?
A.Yes. If a person is shipping an EPA-regulated hazardous waste and that waste is required to be shipped on a manifest, then that material is subject to the DOT Hazardous Materials Regulations. In fact, there is a specifically worded certification statement on the manifest that certifies that the shipment complies with all applicable DOT requirements.

Wording on the Battery

Q. Do the words “Lithium Battery” have to be on the actual battery?
A. No, there is no requirement in the regulations to have those words on there. However, almost all of the transport regulations have added the requirement to include the watt-hour or gram content on the outer cases of said batteries.

HMIS

Q. I have some questions about HMIS ratings. Do you know where I can find more information on that? I’m having a hard time determining what PPE is needed at my facility.
A. We offer HMIS ratings as a service at ICC. As to the PPE component, the better course of action is to use the SDS and any risk assessment data at the facility to make those determination. Continue Reading…
Repacking Dangerous Goods
Authorization column in the shipper’s declaration
Shipping by Air Declaration form authorization column

Almost always the authorization column in the shipper’s declaration is left blank, but when you need to add something in there, you must add it in there. Section 8.6.1.9.4 of the IATA Regulations provides when and what to add when required. Now sometimes we forget to read the “notes” in the Regulations.

Here’s my story

A customer called in first thing Monday morning to get help on shipping an engine. It was an urgent shipment, and he had to get it out ASAP. I said, “No problem. We can help.” It’s what we do. It was going via air, and since it was a domestic shipment he can drop the shipment off to the airline directly for it to leave later that day.

Packaging for an engine

Engines vary in size, clearly. I asked our customer if his engine was packaged, and he said no, but it was strapped on a wooden pallet with 2×4 lumber on corners of the pallet for support. So, I asked him to email me a picture to understand what he meant by that. The picture showed the engine was visible, and the corners with the lumber in upright position did not affect the identification of the engine. I told our customer that all he needed was the shipper’s declaration. We created the declaration, he picked up the colored copies from our office and dropped Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 1

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.

Placarding Bulk Truckloads

Q. My truck has 4000kgs of drums of Class 3 UN1993 in it. Truck has Class 3 UN1993 placard on it . We pick up 1 empty tote (IBC) which is Class 3 UN1993 also. Can we keep the same placard on the truck or do we need to add Class 3 only? Same with empty drums. We just need to add primary CLASS card? All transported via ground within Canada.
A.Well the drums don’t need UN numbered placards since drums are considered small means of containment. A plain class 3 placard will do to represent the drums. It used to be in the Regulations that over 4000kg from one shipper could display UN numbered placard but it was repealed recently. Totes, even empty with residue, requires UN numbered placards for liquids in direct contact with the means of containment. You don’t need to add plain class 3 placard for the drums as both the drum and tote content is hazard class 3. So technically the truck displayed the correct placard (UN1993). If the drums were empty and less than 500kg gross mass then no placard will be required; however, if you Continue Reading…
dangerous goods forms, IATA, IMDG, 49 CFR, TDG documentation
How to Document Weights on DG/HazMat Transport Paperwork

Dangerous goods and hazmat forms

IATA, IMO, 49 CFR, & TDG Documentation

No one wants to talk about their weight. Ever. In the world of transport though, you have no choice. You are required to list on your transport paperwork some sort of weight, mass, or volume. The trick is to know which regulation requires what. Should be the net weight or gross weight? Is it per package or per packaging? Sadly, depending on the regulation, the answers to those questions may differ.

Before getting started, be sure you understand what all of those terms mean. I tend to default to the IATA regulations when it comes to definitions. These are found in Appendix A. Take note that these terms are also defined in the other regulations, too. In 49 CFR check in §171.9. For IMDG they are in 2 places – Volume 1, Chapter 1.2 and Volume 2, Appendix B. TDG defines them Part 1.4.

Definitions:

Package
The complete product of the packing operation consisting of the packaging and the contents prepared for transport.
Packaging
A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.
Means of containment
(in TDG) a container or packaging or any part of a means of transport that is or may be used to contain goods.
Means of transport
(in TDG) a road or railway vehicle, aircraft, vessel, pipeline or any other contrivance that is or may be used Continue Reading…