Single Packaging
ICC’s UN Approved Boxes Now Meet ASTM D5118 Standards

Going Above and Beyond

ICC Compliance Center’s line of UN approved boxes now meet ASTM D5118 Standard Practice for Fabrication of Fiberboard Shipping Boxes. ASTM D5118 boxes meet manufacturing requirements that are written for corrugated and solid fiberboard boxes by ASTM International, an international standards organization that develops and publishes voluntary technical standards for a wide range of products including packaging.

This standard ensures factors and components such as adhesive or fasteners at the manufactures joint of the corrugated box are controlled during the manufacturing process. The ASTM-D5118 Standard provides a first-rate practice for manufacturing criteria of commercial fiberboard styles and packaging ensuring a consistent manufacturing process across the board for our Hazmat boxes. For more information please visit ASTM International’s website below.

https://www.astm.org/

ICC's Regulatory Helpdesk
Regulatory Helpdesk: May 14

Classification, Personal Electronic Devices, Consumer Commodities, and Preparing Hazardous Materials for Transport

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.

Classification Question

Q. I’m trying to verify how to ship a drum that has a flashpoint of 170° F and is a marine pollutant to Japan. My company has to get it to the port and then it will go on a boat. The SDS says it is a combustible liquid NA1993 but Japan doesn’t have that designation.

Do I ship this product as UN1993?

A. No. The flashpoint of 170° F puts you well beyond the limits of any packing group for a Class 3 flammable liquid, n.o.s. under UN1993. The flashpoint does qualify as a combustible liquid but it would only be regulated in a bulk packaging.

Your drum is not bulk. Technically the “flammability” aspect of this is now a moot point. Since you know the material is a marine pollutant, shipping it as UN3082 would be the best bet.

Personal Electronic Devices

Q. I have an employee flying from the US to Greece with a satellite phone so he can have access to the office and home while he is on vacation. Does he need to do anything different or follow any regulations?
A. No. Continue Reading…
Single Packaging
Change Notice: BX-33

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 BX-33 (PK-N6QTC/PK-N6QTCA).

  1. The clear tape required for closure of this packaging has changed from 3M #305 48mm wide clear tape to 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.
  2. The amount of clips that attach to each can is changing from 4 to 6.

Click here to view our packing instructions and certificate downloads »

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

Thank you,
Michael S. Zendano
Packaging Specialist

ICC's Regulatory Helpdesk
Regulatory Helpdesk: May 7

IATA declaration, limited quantity labels, training requirements, and placarding

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.

Listing Overpack on a Declaration (IATA)

Q. Caller needed to clarify what should be listed on an IATA declaration for an overpack.  I have 2 overpacks of the exact same thing. The overpack is 2 drums inside an outer overpack box. Each drum holds 18.9 L. I have it listed as “Overpack Used x 2”. For the alphanumeric identifier for each it is “Box 1” and “Box 2”. How do I list the “total quantity per overpack”?
A. Take a look at Figure 8.1.L. It shows multiple identical overpacks. The example shows 200 boxes each with a weight of 0.2 kg in each overpack. It then lists the total quantity per overpack as 40 kg, which is the result of the 200 boxes multiplied by the 0.2 kg.

For her question then it would be 2 drums multiplied by the volume of 18.9 L. The total quantity per overpack is then 37.8 L.

Limited Quantity Labels

Q. Caller was on our website and had a question about LQ marks/labels. He has a distributor in Canada that will be shipping fire extinguishers to a location in the US from Canada. They use the LQ label in Canada Continue Reading…
PHMSA/DOT Update: Label Border Line Thickness

HM-215N Update: Clarification on 2mm label border line thickness

2mm Label Border Requirement Changed

As most hazardous goods professionals know, HM-215N was intended to harmonize the 49 CFR regulations with the United Nations Recommendations on the Transport of Dangerous Goods—Model Regulations (UN Model Regulations), International Maritime Dangerous Goods Code (IMDG Code), and the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions).

Among many other mandates, the final ruling ultimately revised §172.407 (c)(1)(iii), which changed the required width of the solid line forming the inner border of hazard class labels to a minimum of 2mm thick allowing for a transition period for domestic transportation to be in effect until December 31, 2018 in a final rule published in March of 2017.

“Approximately” vs “At Least”

Although this ruling intended to improve consistency in labeling specifications worldwide, the language has caused confusion at the international level, and The United Nations Subcommittee of Experts recently adopted new language to clarify the width of the line may be “approximately” 2 mm instead of “at least” 2mm.

As a result, earlier this year in response to the industry’s request for clarification, the International Civil Aviation Organization (ICAO) and the International Maritime Organization (IMO) rescinded the requirement for label borders to be at least 2mm in thickness.

This action will officially take effect on January 1, 2019. However, US enforcement inspectors currently still have been referring to the Continue Reading…

Countdown to WHMIS Deadline: Safety Data Sheets

WHMIS Update Man reaching across table with SDS

WHMIS 2015 SDS Requirements

Next in our WHMIS 2015 series we’ll discuss the Safety Data Sheet (SDS), formerly known as the Material Safety Data sheet or MSDS.

There were significant changes to the Safety Data Sheet (SDS) when WHMIS 2015 was adopted including the WHMIS 2015 classification and label elements in section 2. In addition, the SDS must be provided in English and French.

The required elements on a WHMIS 2015 SDS are outlined on Government Canada’s Website

Note that when preparing the SDS, each section, heading and specific information element is mandatory, even if you do not have the information to go into that section. When that is the case, “not available” or “not applicable” can be used in place of the data.

The SDS must be available and accurate at the time of sale. The good news, is under the federal rule, the SDS no longer expires. However, provincial rules may require that the SDS is updated every 3 years; this is true for British Columbia and the Yukon territory.

However, there is a requirement to update the SDS when new significant information becomes available. The question becomes, how do you know if new information is available, if you don’t review your SDS on a regular basis.

A few other points of interest regarding the SDS include:

  • The SDS must have the identity of the Canadian supplier. The exception to this Continue Reading…
OSHA Electrical Shock
May is National Electrical Safety Month

National Electrical Code infographic

Here are three new acronyms for you to keep in mind during the month of May. There is NEC which is for the National Electric Code.  Next is ESFI an acronym representing the Electrical Safety Foundation International (ESFI). Finally, there is NESM used for National Electrical Safety Month which just so happens to be in May.  Now that we know what they stand for, let’s talk about what they do or mean.

The NEC is a standard used for safely installing wiring and equipment. Many people know it as NFPA 70 – a part of the National Fire Protection Association. While not a legally binding standard it is used by many to set safe practices for those using or working with electricity. The NEC is updated every 3 years and is usually adopted by a state or city.

ESFI is a foundation that was created in 1994 to promote electrical safety in all areas of life including the home and workplace.  They work with corporations and the public to prevent electrical fires and injuries.  This is done by providing educational tools, materials and resources.  They have information on general electrical safety, electric shock drowning and overhead power lines.

Check out their website at https://www.esfi.org/.
There is even a kid’s page at http://kids.esfi.org/

National Electrical Safety Month – NESM is observed every year in May. This year’s theme is “Understanding the Code that Keeps Us Continue Reading…

TDG
New Draft: CGSB Standard 43.145

Man preparing shipment

TDG Large Packaging

Still Time to Review the draft “Design, Manufacture and Use of Large Packaging for Transportation of Dangerous Goods in Classes 3, 4, 5, 6.1, 8 and 9

Transport Canada provided notice last month of the availability of a draft Canadian General Standards Board (CGSB) standard for large packagings for specified classes of dangerous goods (DG). The contents of the draft are largely based on the UN “Recommendations on the Transport of Dangerous Goods Model Regulations” (UN TDG Model) 20th Edition.

The draft is open for comment by interested parties until June 8, 2018.

Similar, but Not Identical

Although the current draft is based on the 20th edition of the UN Model, there are some differences – for example: the Canadian TDG regulations (TDGR) have not yet updated Schedule 1 to the current UN numbers above UN3534; TDGR cite Class-specific standards for certain DG (Classes 1, 2, 6); and not all of the lithium battery packaging has been incorporated.

The CGSB-43.145 proposal does, however, contain a supplementary instruction for UN2794 and UN2795 permitting these batteries to be shipped unpackaged on shelving that is permanently fixed within a vehicle. This LP801 standard presumably replaces equivalency certificates providing the option to battery distributers and members of automotive industry associations.

The UN Model and CGSB 43.145 are similar in restricting the use of large packaging to the lesser hazardous Classes/Divisions, typically at the packing Continue Reading…

IATA
IATA 800 Series of Special Provisions

Learning New Regulations

Learning a new transport regulation is tough. Even if you are familiar with other modes, learning the intricacies of a new one is difficult. In our courses, we spend a good deal of time going over a basic shipping description (ISHP) and breaking down each part of it.

Time is also spent on UN versus ID numbers, proper shipping names, hazard classes, and packing groups. We also bring in the Dangerous Goods List (DGL) and talk about where to find the ISHP. This leads to a discussion on technical names, aircraft types, and other symbols shown in the DGL. Eventually we land on the topic of Special Provisions in Column M.

We explain these are additional requirements for any given entry or as I like to call it – the curve balls. Some are helpful and relieve parts of the regulation while others complicate it.

Note – If you ship dangerous goods and are having some trouble with the terms used above, you may need training.

New Special Provisions

IATA added some new Special Provisions a few years ago that cause additional stress for new shippers. I am referring to the A800 series. There are 5 special provisions there starting with A801 and going up to A805. So, what is the big deal with these and new shippers? If we take a moment to look at each one, you’ll see why Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 23

Using absorbents with variation packaging, UN marking height, limited quantity, and de minimis quantities

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.

Absorbent Materials in Variation Packaging

Q. Can I use absorbent padding instead of the vermiculite as the absorbent in a 4GV package that was tested with vermiculite?
A. Per the 49 CFR §178.601, the packaging must meet the standard to which it is certified and the material must be of the same type or design as used in the tested design type, in this case vermiculite. Therefore vermiculite would have to be used to comply with the regulations.

UN Number Height

Q. Is there a minimum size requirement for the UN number on a lithium battery mark?
A. The only place that a specific size requirement is referenced regarding the UN number on a lithium battery mark is in the IATA DGR – §7.1.5.5.2(b)- which states that the UN number “should be” at least 12 mm high.

None of the other common (49 CFR §173.185(c)(3)(i); IMDG §5.2.1.10; TDG §4.24; or UN Model §5.2.1.9) regulations quote a minimum UN number size specifically for the lithium battery mark. All of the regulations referenced allow for proportional reduction, of features without specified dimensions, when the authorized Continue Reading…