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.
- The complete product of the packing operation consisting of the packaging and the contents prepared for transport.
- 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…
The Cat Came Back – WHMIS 1988 Lives!
More Than Just a Date
As reported in Karrie Monette-Ishmael’s May 19 Blog, an order-in-council resulted in an extension to the Supplier deadlines for compliance with the GHS-based Hazardous Products Act/Regulation (WHMIS 2015). Canada Gazette II (CGII), published on May 31, provided some insight into the delay in the supplementary Regulatory Impact Analysis Statement (RIAS) associated with the extension.
The transition extension itself (from June 1, 2017 to June 1, 2018 for manufacturers/importers; and from June 1, 2018 to September 1, 2018 for distributors) was cut and dried. However, the details in the RIAS are a reminder that despite the harmonization focus, there are still some unresolved issues in implementing the new hazard communication system.
Confidential business information (CBI) in the context of WHMIS has always focussed on masking the disclosure of ingredients on the M(SDS). Officially, Canadian suppliers were expected to rely on the somewhat costly and administratively burdensome Hazardous Materials Information Review Act (HMIRA) process to obtain exemptions from disclosing CBI. Practically the provisions in the Controlled Products Regulations (CPR or WHMIS 1988) were used by most suppliers as a simpler alternate to protect CBI.
Although this was the practise almost from the start of WHMIS 1988, it appears to be news to the current organisation- to wit, in the “Background” section of the RIAS: “Health Canada officials have learned that Continue Reading…
Lithium battery shipping is still a very hot topic. Do you ever ship equipment powered by lithium batteries to other locations? Lithium batteries are included in almost all electronics like mobile phones, laptops, cameras, etc.
Are lithium batteries considered dangerous goods?
The answer is yes, because those batteries present both chemical and electrical hazards. Dangers associated with lithium batteries include chemical burn, fire, and electrical shock. They can overheat and ignite under certain conditions. Once ignited lithium batteries can be difficult to extinguish. Therefore, batteries and battery-powered devices can be a safety risk when transported by air.
Lithium batteries are divided into two types:
Lithium metal batteries are primary non-rechargeable batteries used to power devices such as cameras, calculators, watches, etc.
Lithium-ion batteries are secondary rechargeable batteries, which are generally found in laptop computers, mobile phones, audiovisual equipment, etc. Lithium polymer batteries are also included within “lithium-ion batteries”.
You can safely and easily ship most lithium batteries. As long as certain precautions are taken to prevent short circuits, overheating, and inadvertent operations. The IATA Dangerous Goods Regulations based on the ICAO Technical Instructions are intended to facilitate transport while giving a level of safety such that dangerous goods can be carried without placing the aircraft or its occupants at risk.
Lithium metal batteries will be restricted to Cargo Aircraft Only as of January 1, 2015. The prohibition on the Continue Reading…
We’ve turned our clocks backwards, started our holiday preparations, and maybe even bought new calendars for 2013. But there’s one other thing that should be on our minds for the New Year, at least for shippers in the United States. We must make sure that our shipping descriptions are in order.
In 2006, a Final Rule, Docket No. PHMSA–06–25476, known as HM-215I, was issued by the Pipelines and Hazardous Materials Safety Administration (PHMSA). The goal of this rule was to bring the US Hazardous Materials Regulations (HMR) of Title 49 of the Code of Federal Regulations (49 CFR) into line with the current UN Recommendations for Transport of Dangerous Goods. One major change was that the shipping description order, as described in 49 CFR section 172.202(a), would be rearranged to reflect the international standard.
Originally, the shipping description order was prescribed as:
- Shipping name, hazard class, identification number and packing group (if applicable)
However, HM-215I changed this order to:
- Identification number, shipping name, hazard class, and packing group (if applicable)
PHMSA recognized that making this change would take some time, and granted a six-year transition period. After all, making this change would include retraining workers who prepare or read shipping papers, reprogramming computerized document systems, and rewriting standard operating procedures regarding shipping papers. However, the transition period is reaching its end. Starting on January 1, 2013, shipping papers must be in the “identification Continue Reading…
A question we are often asked at ICC Compliance Center is “how small does a dangerous goods shipment have to be to not be regulated?” Not just limited quantity, not just excepted quantity – totally not regulated. Common sense tells us that, at a certain level, tiny amounts of dangerous goods do not pose a hazard during transport. Unfortunately, until recently, this question was not really addressed directly, other than by using other small quantity provisions, such as limited quantities.
However, the UN Subcommittee on the Transportation of Dangerous Goods has been working on this issue, and the question has started to be answered by various regulations based on the UN Recommendations. For example, starting in 2013, shippers by air who use the ICAO Technical Instructions for the Safe Transport of Dangerous Goods (TIs), and the IATA Dangerous Goods Regulations (DGR), will be able to ship very small amounts of dangerous goods as non-regulated under the so-called “de minimis” provisions.
The 54th Edition (2013) of the DGR has a new section, 2.6.10, which establishes the procedures for shipping as a de minimis quantity. The procedure is as follows:
- Look up the goods being shipped on the List of Dangerous Goods (Table 4.2), and check the Excepted Quantity code given in column F. If the code is E1, E2, E4 or E5, the goods can be shipped as de minimis, Continue Reading…
With the changing seasons, comes a change in weather that may affect your area with storms and natural disasters.
According to The American Red Cross, the internet – including online news sites and social media platforms – is the third most popular way for Americans to gather emergency information and let their loved ones know they are safe.
Through the use of everyday technology; individuals, families, responders and organizations can successfully prepare for, adapt to, and recover from disruptions brought on by emergencies and/or disasters.
If your cell phone is an indispensable part of your daily routine, then you may find emergency information text messages from FEMA (Federal Emergency Management Agency) to be a valuable asset. Use your cell phone’s text messaging capability to receive text message updates from FEMA (standard message and data rates apply).
Here are basic commands to get started:
- To signup to receive monthly preparedness tips: text PREPARE to 43362 (4FEMA)
- To unsubscribe (at any time): text STOP to 43362 (4FEMA)
For more information on getting the most out of using the internet/cellphone capabilities during the next emergency, visit http://www.ready.gov/get-tech-ready.
August 15, 2012
This Notice of Proposed Rulemaking (NPRM) by the Pipeline and Hazardous Materials Safety Administration (PHMSA) is part of a continuing effort to maintain alignment with international regulations and standards through a biennial process to harmonize the Hazardous Materials Regulations (HMR; 49 CFR parts 171 to 180) with international regulations and standards.
The following are some of the more noteworthy proposals in this NPRM:
• Incorporate Revised Standards: PHMSA proposes to incorporate by reference the newest versions of various international hazardous materials standards including the 2013–2014 International Civil Aviation
Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions), Amendment 36–12 to the International Maritime Dangerous Goods Code (IMDG Code), and the 17th Revised Edition of the United Nations Recommendations on the Transport of Dangerous Goods (UN Model Regulations).
Additionally, PHMSA is proposing to update the incorporation by reference of the Canadian Transportation of Dangerous Goods Regulations to include Amendment 8 (SOR/2011–239) issued November 9, 2011, Amendment 9 (SOR/2011–60) issued March 16, 2011, and Amendment 10 (SOR/2011–210) issued October 12, 2011. Finally, in this NPRM PHMSA is proposing the adoption of updated International Standards Organization (ISO) standards.
This proposed rule is necessary to incorporate revisions to the international standards and, if adopted in the HMR, most of which become effective January 1, 2013.
• Expand Packaging Authorizations: Consistent with the amendments adopted by the UN Model Continue Reading…
On July 6, 2012 President Obama signed into law the ‘‘Moving Ahead for Progress in the 21st Century Act’’. The current highway bill was on its ninth temporary extension and set to expire on June 30. The law reauthorizes the federal-aid highway and transit programs through September 30, 2014.
In addition to ensuring urgently needed road, bridge, transit, and rail improvements will get underway; the Act has provisions applicable to a broad range of programs and issues.
Some of the issues and concerns addressed:
- The law initiates improvements to port infrastructure by permitting the full spending of the more than $6 billion surplus in the Harbor Maintenance Fund. The Army Corps of Engineers estimates that needed port channel repairs run in the billions, and that our busiest ports can only use 50 percent of their capacity 95 percent of the time.
- The law calls for a National Freight Strategy that can develop an integrated improvement strategy to reduce congestion and fuel costs by ensuring more port containers travel to markets on freight rail.
- For highway safety (among others) includes a requirement that commercial trucks use electronic logging devices to record drivers’ compliance with federal hours of service limits, a new clearinghouse to track drug and alcohol test results, and a study of crashworthiness standards for large trucks.
- For hazmat, the bill reauthorizes the DOT hazardous materials safety program, and bans a DOT-proposed wetlines Continue Reading…
Ergonomic conditions are disorders of the soft tissues often caused by factors such as overexertion while lifting, lowering, pushing, pulling or reaching, among other causes.
Each June, the National Safety Council encourages others to get involved and participate in National Safety Month. NSM is an annual observance to educate and influence behaviors around the leading causes of preventable injuries and deaths. Each week of the month carries a theme to bring attention to critical safety issues. This week, NSC is releasing helpful information and materials on preventing ergonomic conditions, such as overexertion.
According to the Injury Facts 2012 Edition, overexertion is the third leading cause of unintentional injuries in the United States, accounting for about 3.2 million emergency department visits.
Ergonomic conditions are disorders of the soft tissues often caused by factors such as overexertion while lifting, lowering, pushing, pulling or reaching, among other causes. Ergonomic conditions are best dealt with when caught early.
The signs of ergonomic conditions include:
- loss of grip strength
If you are experiencing any of these symptoms, make sure to see your physician or an occupational physician as soon as possible to determine the cause of your pain.
Visit the National Safety Council’s website this June at nsc.org/nsm for a factsheet and quiz on ergonomics.
I always cringe when someone asks me what I do for work. Not because I dislike my job (in fact, I’m one of the few people I know who truly enjoys their work) but because it’s so complicated to explain what I do! Sure, I could simply say I’m a Regulatory Specialist and let them stare at me blankly and try to figure out what that means, but they usually expect more of an explanation.
After going through the explanation for a new acquaintance yesterday, I got to thinking that many of our customers may not know exactly what ICC’s Regulatory Specialists do either. Some of my “regular” customers only deal with one aspect of my expertise, and are often surprised when they learn how many hats I really wear on a regular basis. After 8 years on the job, I have collected many responsibilities to keep me on my toes.
- Training – One of the main duties of the Regulatory Specialist (RS) at ICC is to deliver training classes to our customers. For me, this includes the US 49CFR Hazmat regulations, the IATA Dangerous Goods Regulations and the IMDG Code. These classes can take place at our training centers, the customer’s facility, a hotel, or even via an online webinar. Not only do we conduct the training, but we also develop the presentations and quizzes that are Continue Reading…