Regulatory Helpdesk: November 13, 2017

Top 4 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

WHMIS Label Size Requirements

Q. Is there were size requirements for WHMIS labels?

A. No, the HPR does not mandate a size requirement other than saying it has to be legible. But, what does legible mean? As a general rule of thumb, which we have developed from reviewing many different labeling regulations is 10 mm for one side of the pictogram, and 2 mm for the font size (1.6 mm for a worst-case scenario).

IATA Special Provision

Q. What does  IATA’s Special Provision A191 mean?

A. It was determined that SP A191 means if you have a manufactured article with less than 5 kg of mercury in it (like a thermometer) then you don’t need the Class 6.1 label for mercury’s subsidiary hazard and you don’t have to list the 6.1 subsidiary hazard on the shipper’s declaration.   From what we can tell that only applies to UN3506 which is Mercury contained in manufactured articles.

Quantity Limits – TDG (Canada)

Q: What does the quantity limit in TDG Columns 8 & 9 represent in terms of Passenger conveyance restrictions- package, consignment, …?

A: Good point which many find confusing. The answer is in the often-overlooked Continue Reading…

Repacking Dangerous Goods
When the Finished Package Resembles Christmas Lights

A lot of Labels!

A Lot of Labels

It’s not often that you’ll see more than 2 hazard labels on a DG package, but the one I did this week had 5 hazard labels plus 3 handling labels. So a total of 8 labels on a package. Yes, that is a lot.

I received a panic call from a freight forwarder who picked up a rejected package from a passenger airline and didn’t know what to do with it. It was a rush shipment to get to Australia. I asked him what was being shipped and he said, “a fire extinguisher and some cans of glue”. I advised him to bring the package and all accompanying documents over to our office and I will get it packaged up properly for air transport. He showed up an hour later.

This is what the box looked like when it came in:

A lot of labels 2

I reviewed the shipper’s declaration which the shipper did complete and the markings/labels on the box and it was incorrect for numerous reasons. I told the freight forwarder that the person who prepared this shipment is not certified to ship via air. An air certified individual may make an error or two, but not 10. It was evident this person did not know what they were doing. I asked for the MSDS/SDS for the products. The fire extinguisher was obvious, but there were 4 small Continue Reading…

Birthday truck
Happy Birthday DOT!

Truck Driving on highway at sunset

Happy 50th Birthday DOT!

Birthdays are important milestones and should be celebrated. One important one for parents is a baby’s first birthday. This is often followed by apprehension when a child reaches their teenage years. Many people in the United States enjoy turning 21 because that means alcohol is legal for us to consume. After that there are the “round” birthdays – those dreaded ones that have a zero after them. You know, turning 30, 40, 50, etc. We also celebrate the birth of nations. In the US it is every July 4th. For Canada the celebration is on July 1st. Many religions celebrate birthdays too. Christmas in the Christian faith is the birth of Jesus. Buddhists celebrate Buddha’s birthday on the 8th day of the 4th month in the Chinese lunar calendar.  Companies also follow this same practice. In fact, ICC Compliance Center just turned 30 last month.

What does all of this birthday talk have to do with the transport of hazardous materials? January 12, 1966 saw then President Lyndon B. Johnson declare in his State of the Union address his plans to create a Department of Transportation (DOT). It was on April 1, 1967 the DOT was open for business. Think about that for a moment. That means in the 1940s when the first atomic bomb was created, there were no regulations around the transport of Class 7 radioactive materials. Other materials such Continue Reading…

ICC Trade Shows and Events
Speaking at DGAC Summit in DC

Trade Shows and Events

DGAC Summit 2017

One of the highlights of the year, at least for those of us involved in dangerous goods regulations, is the annual summit meeting of the Dangerous Goods Advisory Council (DGAC). This year, it was held in Crystal City, just outside of Washington, DC, and as always had many speakers from both government and industry. Of course ICC attended, and I was graciously invited to give a couple of talks on the Canadian Transportation of Dangerous Goods (TDG) Regulations, and to take part in a fun closing activity known as “speed-dating the regulators”.

Speakers

The introductory talk was given by Brigham McCown, former deputy administrator of the Pipeline and Hazardous Materials Safety Administration (PHMSA). As a longtime political insider, he discussed the state of the department under the new administration, and how the once “sleepy little agency” was moving forward. He identified top trends in transportation such as infrastructure investment, autonomous (self-driving) vehicles, drones, and of course reducing unnecessary regulatory burden while still ensuring public safety. He mentioned that the new Secretary of Transportation, Elaine Chao, was experienced and would help the department adapt.

Other speakers representing PHMSA included Shane Kelly, who provided an overview of upcoming changes to hazardous materials regulations, and a report on the United Nations Transport of Dangerous Goods Sub‐Committee by Steven Webb, Aaron Wiener, and Lindsey Constantino. Amy Parker of the U.S. Coast Continue Reading…

Single Packaging
Change Notice: BX-30CA

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-30CA (PK-N2QTC/N2QTCA)

  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.

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

Repacking Dangerous Goods
Shipping Funky Looking Fire Extinguishers

Shipping aircraft fire extinguishers

Aircraft Fire Extinguishers

Have you ever seen an aircraft fire extinguisher? If not, they don’t look anything like a regular fire extinguisher. For most of us when someone says, “fire extinguisher”, we imagine some kind of red cylinder with a pin, nozzle, and trigger. But an aircraft fire extinguisher looks like a ball with antennas sticking out. That’s why I call them “funky looking fire extinguishers”.

I was asked if I can assist with shipping out an aircraft fire extinguisher via air for a client. Absolutely I can. The client dropped off the fire extinguisher which was wrapped in bubble wrap. As per the SDS it was classified as UN1956 but for those with equivalency certificates/special permits it can be classified as UN1044. Now since these funky fire extinguishers don’t exactly have the surface area to place the markings and labels, I used a strong tag to affix the label and markings as per Section 7.2.6.1 (d) of the IATA Regulations. I wrapped the fire extinguisher in more bubble wrap in such a way to prevent any accidental activation during transport. I used a strong outer packaging and filled the void space with packing peanuts. Placed all the labels and markings on the outside of the package and send it out the same day with FedEx. The package arrived at its destination nice and early at Continue Reading…

Hazmat Personal Protection Equipment
Warehouse Fire in St. Louis – Still Burning

Hazmat Incident

A warehouse in South St. Louis caught fire on Wednesday and is still burning today.

Listed as a five-alarm fire by some media outlets has caused major problems for the St. Louis area for several reasons. First, multiple-alarm fires are ones where multiple fire stations, firetrucks and firefighters are called in to battle the fire. This number can increase or decrease depending on just how much equipment and manpower is needed to contain the situation. The scale general ranges from one to ten, so a five-alarm fire is of definite concern. The next concern is over the decay of the building as the fire continues to burn. Yesterday, the roof collapsed forcing the fire higher and spreading debris. Following that collapse a section of wall came down damaging one of the trucks. Most alarming is the need for a HazMat Team.

Why a HazMat Team?

Check out these links to see pictures and videos showing the extent of the fire:

http://fox2now.com/2017/11/15/crews-battle-3-alarm-fire-at-south-st-louis-warehouse/

http://www.kmov.com/story/36851034/fire-crews-battling-3-alarm-warehouse-fire-in-botanical-heights-neighborhood

http://www.ksdk.com/article/news/st-louis-warehouse-continues-to-burn-24-hours-later-smoke-considered-hazardous/63-492028403

Tweets from St. Louis Fire Department

Hazmat Personal Protection Equipment
HazMat Incident in Niagara Falls, NY – Liquid Hydrogen

Hazmat team

HazMat in Action!

As you may have heard, a major hazmat incident occurred in Niagara Falls, not far from ICC Compliance Center’s location. On a late Monday night in October, a tanker truck carrying nearly 13,000 gallons of liquid hydrogen (UN1966) hit the base of a light pole in the parking lot of a local grocery store as the driver was attempting to turn around. This resulted in a valve on the truck to become damaged and could have caused the highly flammable liquid hydrogen to be released from the truck triggering a very serious situation for nearby residents and businesses. Although the driver received a traffic violation, nobody was physically harmed by the incident. Watching this news story unfold made me think about how this incident could have turned out much differently if hazmat protocol wasn’t followed.

Initial Response:

As the tanker truck crashed into the pole, local officials on hand realized the dangers of what was inside the truck because it was properly placarded with a UN1966 placard. Had the truck not been placarded correctly, officials would not have known what was inside the truck and what dangers could come from exposure to the highly flammable liquid hydrogen. As a result, officials were able to respond quickly and evacuated all local businesses and roads leading to the grocery store parking lot the accident took place in. Officials Continue Reading…

Regulatory Helpdesk: November 6, 2017

Top 4 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

Equivalent Exemption (Canada & US)

Q. What is the  US “equivalent” to TDGR Part 1 Special Case 1.33?

A. The reference is found in 49 CFR§173.150. Essentially the US says that, with conditions, a low risk flammable liquid may be “reclassified” as a combustible liquid; & combustible liquids may be exempted when in non-bulk packaging. Before using the exemption, also check the following:

  1. Verify that the actual ingredients don’t trigger the (US only) “RQ” requirement to classify as “hazardous substance” or “marine pollutant” designation which will negate the exemption under (f)(2).
  2. Verify that there is no subsidiary hazard class which would negate the exemption (US (f)(1) & TDG 1.33(a)).

Organic Peroxide Shipped by Ocean

Q. Can you confirm the packing group for UN3104 with Dibenzoyl Peroxide for IMDG?

A. UN3104 is Organic Peroxide Type C, solid. This is a class 5.2 material that does not have a packing group. However, Chapter 2.5 should be reviewed as well as Packing Instruction P520 and packing methods OP6.

A Spill Involving a Limited Quantity

Q. If I have a product being shipped in Limited Quantity, it’s not considered as being dangerous any more? So if there is Continue Reading…

WHMIS 2015
Health Canada Notice of Intent for Possible Amendments to the HPA and HMIRA

Warehouse with chemicals

The Issues with Exclusions and Confidential Business Information (CBI) Keep Coming

Health Canada recently published a proposed amendment to the HPR (Hazardous Product Regulations), which included an option to use specified concentration ranges for ingredients rather than the exact or actual chemical concentration on their SDSs (safety data sheets) (October 21, 2017). The proposed amendment to allow these ranges, would offer industry some CBI protection of formulations without having to go through a potentially costly CBI application claim under the Hazardous Materials Information Review Act (HMIRA).

The “Why” of the Notice

After receiving comments and questions on the proposed amendment, Health Canada brought forward two additional bigger issues, the full exclusion of consumer products from the Hazardous Products Act (HPA) and HPR (or WHMIS 2015), and whether to allow CBI protections of substances with special health hazards (particularly carcinogens, mutagens, reproductive toxicants and respiratory sensitizers, or “CMRRs”).

The “What” of the Notice

With regard to the full exclusion of consumer products from the HPA and HPR, stakeholders felt that since the Consumer Chemicals and Containers Regulations 2001 (CCCR 2001) did not include hazard criteria for special health hazards like the CMRR’s, a worker that might purchase a consumer product from a retail store to use in their workplace, will not have the same full hazard information on the product (and will therefore not protect themselves appropriately) that they would have if the Continue Reading…