TDG training, the eternal problem that has been going on for so many years. I began my career in 1999 and even then the regulations did not really help to define training requirements regarding the Transportation of Dangerous Goods Regulations (TDGR). It is fair to say that we are no further ahead today.
It is important to understand the training requirements for your company, including:
Who? Which employees require training?
What? What training do they need?
When? How often do they need to be trained?
How long? Do they need a 4-hour course, 1 day, 2 days?
Regulations? What parts of the Transportation of Dangerous Goods Regulations should be addressed?
This blog is one in a series that I hope will help you establish the training requirements for your employees.
We will start by asking questions and we will find the answers in regulatory articles. I will interpret them to guide you as best as I can.
Before I begin, I would like to clarify the term ”Transportation”. When Transport Canada uses the term transportation includes any activity that relates to the request for transportation by all modes of transport (contacting a carrier for a shipment either by ground, air, or sea), transportation (e.g. truck driver), handling (employees who prepare shipments and/or receive dangerous goods (DG), and also includes the import of DG by all modes of transport (air, sea, or transborder).
One of the most frustrating issues with shipping dangerous goods is finding a carrier that will transport the goods. When a client contacts us for repackaging services, besides the DG information, I always ask if they have arranged a carrier to transport their goods. Most of the time it’s a “no”. Then I get started with what their options are; ground or air.
For shipments going from Canada to the US, believe it or not, it is easier to ship by air than ground. Of course, it does depend on the quantity being shipped and whether the DG is allowed for air transport. It is definitely more cost-effective to send anything via ground than air; however, that is not always true especially for small DG shipments. I have been told that sending a small, e.g., 20 lbs, DG package by air will cost about the same as sending it via ground.
Carriers such as FedEx and Purolator do not haul DG packages from Canada to the US via ground service. They do offer air but not ground. UPS which offers both air and ground does transport certain dangerous goods (just check for limitations on the UN# being shipped on UPS’s website under “UPS Dangerous Goods Acceptance Tool” prior to shipping) from Canada to the US but you must have a DG account set up with them.
Sometimes no matter how many precautions you take, there is no way to stop the inevitable. Football players with helmets designed to protect their brains still get concussions. You cross every “t” and dot every “i” on your federal income tax return and you still get audited. And sometimes even if you follow all of the safety tips for lithium ion batteries in my previous blog, they still can explode. http://blog.thecompliancecenter.com/safety-tips-for-lithium-ion-batteries/
However, by not taking the proper preventative measures in all of the cases listed above, the chances of a negative outcome can be greatly increased. With the travel season looking to pick-up in the coming months and many of us looking to hop on a plane and head out to our idea of paradise, I think it is safe to say that none of us want to end up in a situation like the story below.
Just like any other domestic flight, passengers on a Delta flight in New York City were stowing their carry on items in the overhead storage bins and preparing for take-off for a scheduled departure to Houston, Texas. Suddenly, passengers started to smell something burning, similar to the smell of a camp-fire. It was at that point that passengers started to see smoke in the cabin and begin panicking. The panic was caused by a vape pen that started smoldering Continue Reading…
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.
Q. Customer called and asked if their company name was required to be printed on the new lithium battery mark when shipping by ground within the U.S.
A. No, that is not a requirement. Per 173.185 (c) (3) (i), it states the following must be printed on the label: The “*” must be replaced by the appropriate UN number(s) and the “**” must be replaced by a telephone number for additional information.
Q. Regarding Canadian address/phone number, do you know how a wholesaler company can market in Canada without a Canadian address? For obvious reasons, there will be multiple suppliers that could be selling our products.
A. This situation could be covered by the Hazardous Products Regulation (HPR) s. 5.9(2) or 5.15(1).</ br>
The requirement for having a label with the (Canadian) initial supplier identifier is invoked by the Act (HPA) s. 14b).</ br>
HPR s. 5.9(2) allows an employer to import with only the foreign supplier identifier on an otherwise compliant label if it’s for use in their own workplace.</ br>
HPR s. 5.15(1) exempts importers from having a compliant label as long as they can prove (5.15(2)) that they will ensure it’s labeled Continue Reading…
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 BX-24DU
The clear tape required for closure of this packaging has changed from 2 strips of 3M #305 48mm wide clear tape to 1 strip of 3M #375 48mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.
If you have any questions or concerns, please
contact our customer relations center in the US at 888-442-9628 or in Canada at
With another government shutdown possibly looming again in the United States in mid-February, many are wondering how this affects the hazardous materials world, specifically those looking to ship domestically or shipments that are entering the U.S. Whether or not you agree or disagree with the shutdown, I think it is safe to say we can all agree on the importance of the continuing enforcement of the hazardous materials regulations. So the million dollar question here is, will the government shutdown have an effect on PHMSA? The short answer here, for the time being, is yes, but not in all cases. While activities like program developments, research, and HMR permits have generally been suspended, enforcement of the regulations and investigations have continued. Below is a list of continuing operations and suspended activities while this government shutdown continues to take place.
Summary of Continuing Operations
• Investigations of pipeline accidents to determine the causes and circumstances of failure, the need for corrective action, and any non-compliance that might have contributed to the accident.
• Inspections of pipeline operators and systems to detect and remediate safety concerns and determine compliance with the pipeline safety regulations.
• Enforcement of the pipeline safety regulations through corrective action orders, notices of probable violations, letters of warning and other authorized enforcement activities.
• Investigations of hazardous materials accidents to determine the causes and circumstances of failure, the need Continue Reading…
If your business is like most, you don’t usually deal with shipping explosives in Class 1. However, this class sometimes shows up in places you’d least expect it. While it’s expected to deal with explosives in construction, mining, and the military, you can also find explosives in unexpected products such as toys (caps for cap guns), pyrotechnics for stage and movie productions, and animal tracking collars (some use explosive bolts to free the animal so it doesn’t have to make a permanent fashion statement).
Shipping explosives can be more complex than many other classes of dangerous goods. They are subject to other regulations, such as the Explosives Act, and may require special licensing depending on what type they are. In addition, they are often excluded from some of the common exemptions found in Canada’s Transportation of Dangerous Goods Regulations (TDGR). For example, explosives can’t use the Limited Quantity exemption of section 1.17, or the Excepted Quantity exception found in section 1.17.1. Some low-level explosives may qualify for the 150 Kilogram Gross Mass Exemption in section 1.15 and the 500 Kilogram Gross Mass Exemption in section 1.16, but only if they fall into certain divisions, compatibility groups or UN numbers. You’ll need to read each exemption closely to ensure that your particular explosive will qualify.
To balance things out, TDGR does contain some provisions for shipping small amounts of low-level Continue Reading…
In-transit, manufactured for export, and editorial/transportation changes
IN-TRANSIT OR “FOR EXPORT” PMRA-UNREGISTERED PESTICIDES & WHMIS-STYLE HAZARD COMMUNICATION
Those involved in manufacture, import, storage or transportation of pesticides, which are not registered for use in Canada may soon see reference to GHS-style documentation accompanying foreign products while they are in Canada. This amendment is partly as a result of a relaxation of the “in-transit” prohibition on pesticides (“pest control products” or PCP) that are not registered for use in Canada (required as a result of the government’s support of the 2017 World Trade Organization’s ratification of the 2014 Trade Facilitation Agreement – TFA).
Until recently, there was a general prohibition in the Canadian PCP legislation that, in general, prohibited the: manufacture, possession, handling, storage, transportation, import, distribution, or use of unregistered pest control products. An amendment to the PCPR adopted in Canada Gazette II (CG II) on December 26, 2018 includes authorization of import/export for “Products not Intended for the Canadian Market”.
WHMIS 2015, as specified in the Hazardous Products Act (HPA) s. 12/Schedule 1, excludes “pest control products”, as defined in the PCP Act (PCPA), from the WHMIS regulations. This wasn’t perceived to be a safety issue since, up until the recognition of the TFA only registered PCP were authorized for general manufacture, possession, handling, storage, transportation, import, distribution, or use. There are limited exceptions, but only under specified circumstances, Continue Reading…
Last month I wrote a blog regarding penalty fees Amazon was looking to implement for packages that fail to comply with safety requirements when shipping dangerous goods. Amazon ultimately decided to take this a step further adding storage, and fulfillment fees for products they deem asdangerous goods.
Who does this affect?
For sellers that utilize Amazon’s FBA program (Fulfillment By Amazon) in which third-party sellers send their goods to be stored, picked, packed, and shipped in Amazon warehouses before they are sold on Amazon, some of the new fees will go into effect on February 19, 2019, according to a note on Amazon’s forum for sellers.
Specifically, Amazon announced that it will be introducing a new fee for “dangerous” items like aerosol cans, and lithium-ion batteries that sellers send to Amazon warehouses. The fees will be higher than the regular fees Amazon charges for using Fulfillment By Amazon.
What are the fees?
The table below shows the new monthly inventory storage fees for dangerous goods containing flammable or pressurized aerosol substances. This change will first be reflected in April 2019 charges for storage that occurs in March 2019.
January – September
$0.99 per cubic foot
$0.78 per cubic foot
October – December
$3.63 per cubic foot
$2.43 per cubic foot
Other fees include an introduction of separate fulfillment fees for dangerous goods that contain flammable or pressurized aerosol substances, and items that contain lithium-ion batteries.
The Canadian Transportation of Dangerous Goods Regulations (TDGR) were uncharacteristically quiet in 2018. This represents the first year in a 5-year stretch where stakeholders didn’t see at least one amendment to the TDGR.
That doesn’t mean, however, that there was no activity within this very active government department. For example, in keeping with the move to adopting ambulatory references to cited standards, the responsibility for several standards (e.g., TP14850 small container performance packaging, and TP14877 rail containers) began their return to the Canadian General Standards Board. In addition, there were various consultations on topics such as ERAPs (TDGR Part 7), and discussion of training requirements (TDGR Part 6) – the latter in conjunction with establishing a CGSB committee.
NEW & ONGOING RESEARCH
Various research projects were explored in 2018 including collaboration on examining crude oil flammability, properties of produced water in oil and gas activities, as well as validation testing of a proposed SAE standard for lithium battery packaging. These activities a
Various topics referenced above and others undertaken in the 2016-2018 period were given status updates, including proposed Canada Gazette (CG) I (final consultation) or II (final amendment) at a late November GPAC (General Policy Advisory Council) session: