Graduation Cap
Who is Your Trainer?

Do you know who is training you?

Help! My team and I recently attended a training session and received our certification, but we continue to struggle with shipping our products.

That is a statement we hear far too often from clients who call our helpdesk for assistance. The shame of it is that  they seemingly wasted both time and money in a training program, but did not get out what they needed. Now, they have no choice but to take another course.

Specialists & Experts

Many people these days are calling themselves regulatory specialists, dangerous goods experts, or health and safety experts. The dangerous goods/hazardous materials field is a detailed, comprehensive topic requiring hands-on experience and a strong technical understanding of topics directly related to the industries we serve. Finding the right training company is critical to ensuring that the processes and procedures you need to continue operating remain uninterrupted.

Similar to Capital One Financial’s slogan “What’s in your Wallet” (https://www.youtube.com/watch?v=T3funZeuc9Q), you need to ask yourself “Who is your Trainer”.

Here are some questions you should consider when looking for trainers with the ‘right stuff’

  1. Do they have appropriate degrees and decades of education and knowledge?
  2. Do they have their finger on the pulse of pending regulatory changes?
  3. Can they customize training to suit your needs or are they offering the same course to everyone?
  4. Are they educated/trained in teaching adults?
  5. How detailed are their courses?
  6. Do they Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: March 26

Proper shipping name, 500 kg exemption, MANCOMM symbol, and a TDG error

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.

Proper Shipping Name (49 CFR)

Q. The customer wanted to know if they can print the product name in section 1 of the SDS next to the UN number on a hazard class label instead of the proper shipping name.

A. No. The proper shipping name on the outside of the box is a requirement per 49 CFR §172.301 (a) (1) and must be marked along with the UN number in a non-bulk packaging.

500 kg Exemption (TDG)

Q. Can I apply the 500 kg exemption when I have a mixed load where part of the load is excluded from using a DANGER placard under the 1000 kg Class restriction in TDGR §4.16 but the remainder is less than 500 kg gross? An example would be a consignment offered that included 1200 kg of Class 3, 100 kg of Class 8 and 300 kg of Class 9 (no ERAP required for either)?

A. In the DANGER placard scenario in 4.16, the Class 3 is restricted from using the DANGER placard specifically, based solely on quantity. Regular placarding requirements apply to the load based on the guidance text Continue Reading…

Single Packaging
Change Notice: BX-21SP

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-21SP.

  1. The maximum gross weight allowance for this design has been increased from 12.8 kg to 16 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 at 888-442-9628 in the USA, 888-977-4834 in Canada.

Thank you,
Michael S. Zendano
Packaging Specialist

Space Craft over highway
Shipping Spaceship Batteries to Nibiru

Flying Saucer UFO with a cloudy sky

A Helpdesk Call that was Out of This World

Occasionally our Regulatory Helpline is asked a question by a customer that stretches our knowledge of the regulations. The most recent one was a call regarding shipping spaceship batteries. Apparently, they were visiting another planet in their system and got stuck due to a dilithium crystal ion battery that would no longer hold a charge. Their home planet of Nibiru wants to send some replacement spaceship batteries and asked if there were any regulations with which they should comply and any areas with which they needed to be concerned.

To show you how great our helpline is, let’s review the process we used to get them the answer they needed.

Step 1: Is the planetary nation a current customer of ICC?

It turns out they actually are a current customer.

They really like our vermiculite-free variation fiberboard packaging and had recently purchased more of them.

This means they have ready access to our helpline anytime they should need it.

Step 2: By which mode of transport will these be transported?

To start, the Area 51 CFR Ground regulations for the home planet must be reviewed.  This is necessary as the spaceship batteries would be transported by hovercraft from the home planet’s office to the intergalactic air and space launch facility.

IAATA Regulations 590 Edition
IAATA Regulations 590th Edition
UPC Manual of Testing and Criteria
UPC Manual of Testing and Criteria
[caption id=”attachment_9077″ align=”alignnone” Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: March 19

Proper Shipping Name, Hydrostatic Pressure Tests, Other Information on the Lithium Battery Mark, and an Interesting Lithium Battery Story

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.

Proper Shipping Name for Lithium Batteries (IATA)

Q. Is it acceptable to print “Lithium Ion batteries packed in equipment” on a Class 9 Miscellaneous lithium battery label for UN3481 instead of Lithium Ion Batteries Contained in Equipment?
A. Yes. In the blue pages (Section 4) of IATA, you will notice there are 2 spots for UN number “3481”, one for lithium batteries containing equipment, and one for lithium batteries packed in equipment, so either of those printed on the label is acceptable.

Hydrostatic Pressure Test by Air (IATA)

Q. I plan on shipping an F-style container as an inner container in a combination package. Per IATA  §6.3.5.1, it says the internal pressure test is not required for combination packages. Does this mean the inner container doesn’t have to meet the 95 kPa pressure rating if shipping liquids by air?
A. Although IATA §6.3.5.1 does state the internal pressure test is not a required test for inner packagings of combination packages, it also references §5.0.2.9 for further instructions, which states that packaging for retention of liquid must be capable Continue Reading…
TDG Methanol Classification
Big Change in Methanol Transport Classification (TDG)

TDG Update - Man Staring in to warehouse

New Transport Canada Update Means Big Changes for Many Companies

Recently, Transport Canada posted on their FAQ web page, a few questions regarding shipping mixtures of Methanol.

The first three FAQs are for the most part, not surprising, with one exception in Question 2. These FAQ’s appear as follows (these FAQ’s are directly from their website): (keep reading, the biggest surprise is coming).

Question: How do I classify a product that contains methanol as the only dangerous good?
Answer: As per Section 2.3 of the TDG Regulations, when the name of a dangerous good is shown in Schedule 1, that name and the corresponding data for that shipping name (class, subsidiary class(es), packing group (PG)) must be used. Therefore, when methanol is the only dangerous good in the product and it meets the criteria for Class 3, Flammable Liquids, it should be transported as UN1230, METHANOL, Class 3 (6.1), PG II. Note that PG II is the only packing group available for methanol as per Schedule 1 of the TDG Regulations. Note: Subparagraph 1.3(2)(d)(iv) of the TDG Regulations allows a person to indicate the word “SOLUTION” or “MIXTURE” and also the concentration of the solution or mixture after the shipping name, as applicable.
Question: Tests results for a solution containing methanol as the only dangerous good indicate that its packing group should be III. How do I choose the proper shipping name?
Answer: Even if a dilution would lead to a Continue Reading…
How to Ship My Motorcycle

Riding motorcycle on dirt road

I need to ship my motorcycle. What do I need to do?

Normally around this time of the year we start to get calls about shipping a motorcycle as folks are planning their vacations and motorcycle adventures.

To be honest, I enjoy receiving these motorcycle inquiry calls because it always had to do with someone either visiting our beautiful country and now returning back home or they will be traveling to a beautiful destination and need to ship their bike. It gives me a chance to chat with them about their travels, too! Which is exciting, as I am a world traveler myself. I thoroughly enjoy speaking to them about their travels and adventures before I get into discussing the “exciting” world of shipping dangerous goods.

Here’s All that is Involved with Shipping a Bike:

We can help you! It is a simple procedure and it involves very little stress.

1. You will need to complete the “Motorcycle Declaration Form”

This can be completely electronically in the comfort of your home. This form can be downloaded here (Kel-Ex Vancouver) or here (ICC Repacking). It’s a simple document which gives us the details of your bike (i.e., shipper and consignee address, how it will be packaged, weight, confirmation that the fuel tank will be drained to less than ¼ tank upon drop off). In most cases motorcycles are dropped off “as is” meaning Continue Reading…

Regulatory Helpdesk: March 12

Combustible Liquids, Using Chemtrec’s Number, Keeping Up-To-Date, and Other Paperwork

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.

DG Documentation on Overpacks

Q. If there are multiple skids of dangerous goods (overpacks) in a shipment on which one should the copies of the invoices and shipping papers be attached?
A. Neither the DOT nor IATA regulations tell you to put “paperwork” on the outer packages or overpacks. That is a carrier/driver thing. All the regulations care about is the proper marking and labeling that they require. You also have to be able to physically hand your paperwork to the carrier. Your best bet would be to talk to your carrier directly as to how they want it handled.

Combustible Liquids

Q. I have a liquid with a flashpoint of 100° F and it does not meet any other hazard classes. It is not an RQ, waste or marine pollutant. After manufacturing, it is placed in tubes and then shipped for sale in retail stores. What marks and labels are needed on the outside of the packages?
A. The flashpoint of this material is 100° F and there are no other hazards under the transport regulations. This means it technically meets the definition of a flammable liquid in Packing Group III per §173.120 Continue Reading…
TDG
March 2018 TDG TP 14877 Update

Railway Tanker Transporting Dangerous Goods

Rail TDG Standard TP 14877 Update

On March 15 Transport Canada released a notice on the intent to issue a new January 2018 edition of standard TP 14877 “Containers for Transport of Dangerous Goods by Rail” to replace the current 2013 (with Corrigendum) edition.

This is the penultimate culmination of the public process, in part arising out of the Lac Mégantic 2013 disaster, undertaken by a stakeholder Consultative Committee that began in February of 2016.

The main features of the proposed 2018 edition include:

  • Improved usability by incorporating external technical requirements, such as those in Protective Direction 34, 37 and 38.
  • Updated dangerous goods list to align with the 19th edition of the UN Model Regulations. Adjusted special provisions to reflect updated transportation requirements for Sulphuric Acid (UN1831) and Hydrogen Peroxide (UN2014 / UN2015).
  • Updated technical requirements for Class 3, Flammable Liquids and the new tank car specification known as TC 117.
  • Improved harmonization between tank car requirements in Canada and the US, including tank car approvals, tank car design requirements and a new mechanism to secure One Time Movement Approvals (OTMA) – Category 2.
  • Updated material of construction requirements for tank cars, including the addition of stainless steel, normalized steel for dangerous goods classified as a toxic inhalation hazard (TIH) and improved thickness requirements for new tank car construction.

Comparing the 2013 and 2018 Standard TP 14877

A brief comparison of the TABLE OF CONTENTS Continue Reading…

TDG
2018 TDG Registration and Fines FAQ

Red semi truck on highway

REGISTRATION and FINES and FAQs, OH MY!

February and March contain some interesting items potentially impacting the Canadian TDG landscape…

Registration-CID Consultation

Transport Canada, through a consultation notice published in late February, has solicited input from stakeholders on a plan to require those who handle/offer for transport, transport or import dangerous goods to register with Transport Canada.

The premise is that, “… public safety depends” on Transport Canada knowing who is transporting DG, including where, when, and how much. The main thrust of this proposal seems to be for targeting enforcement and consultation activities.

The proposal as currently presented does not appear to distinguish among the size, frequency, or nature of DG involved; and will require period re-registration with submission of data to the “Client Information Database” (CID).

There’s nothing in the posted information to indicate whether there will be a cost to “clients” for registration, in addition to the record-keeping burden they will bear.

(For those familiar with the 49 CFR §107 (Subpart G) requirement, intended to subsidize government response activities, this TDG version does not serve the same purpose.)

The only exemptions currently contemplated, extend to those falling under a TDGR Part 1 “special case” exemption. This contrasts with 49 CFR’s registration which has exemptions based on load sizes and hazard types.

The TC proposal and comment provisions are found at:
https://letstalktransportation.ca/cid

Contraventions Regulations

While not directly cited in the Transport Canada TDG Act or regulations, Continue Reading…