TDG Standards on the Move – Explosives Plus TP14850 & TP14877

TDG Update - Red and white semi truck on the highway

CGSB.43-151 Class 1 Explosives Draft Update

There have been some recent developments in 2 of the packaging standards of potential interest to the DG community involved with Canadian transportation.

  • TP14850- Class 3-6.1, 8 and 9 Small Packaging pre-publication 3rd Edition-Transition to CGSB
  • TP14877- Rail Transition to CGSB

CGSB-43.151 Explosives Packaging Standard

Transport Canada has provided notice of a consultation on a proposed update of the Canadian General Standards Board (CGSB) standard “Packaging, Handling, Offering for Transport and Transport of Explosives (Class 1),” CAN/CGSB.43-151.

The new edition, to replace the current 2012 edition, will update the list of UN numbers and packing instructions to align with the UN Recommendations 20th edition; and update references to other dangerous goods container standards.

Also proposed in the draft are packing instructions for UN large packaging (ELP) to supplement the existing standards for IBC and portable tanks.

New Canadian domestic packing instructions (CEP 01) for jet perforating guns, used in oil well completion, are also included in the draft. Previously packaging of these (UN0124 and UN0494) had to be authorized on a case-by-case basis as referenced in EP 01.

CEP 02 replaces the previous EP 17 for highway and portable tank transport.

In common with the recent approach in other Canadian standards, changes to the organization of information, as well as regulatory requirement updates and additional definitions are part of the draft.

New or clarified definitions are provided for “IM” and “IMO-type” Continue Reading…

OSHA Labeling
Can you ship DG and non-DG Together in One Package?

Can you ship DG and non-DG Together in One Package?

Surprisingly this is pretty common. Normally the answer is, “Sure.”

However, that’s not always the case. Sometimes a dangerous goods commodity can react with a non-dangerous goods commodity. I do come across this type of situation occasionally.

Shipping from Canada to USA via Air

Earlier this week a client dropped off 2 different product samples going to USA via air transport. He provided the SDS for both products, one was DG and the other not. He asked if both samples can go together in one package. I told him, “Maybe.” Without consulting the SDSs and gathering more information I couldn’t be sure. If they are compatible, then I can package them together.

I used to work in the carrier industry so I know it’s better to consolidate than to have a multiple piece shipment. Most times all the pieces will arrive together, but there is a chance they may not. So for me, personally, I prefer to minimize the number of packages, which means using a bigger box if I need to.

Determining Compatibility

So back to this. I checked the SDS for both and the one that was DG was a corrosive material.

The non-DG product requires a more thorough read-through to see which material this material was incompatible with and in Section 10: Stability and Reactivity it said incompatible with oxidizing materials Continue Reading…

DOT 49 CFR USA
Updates to PHMSA HM-218H – New Compliance Dates

Winston Churchill and the 49 CFR

As a former high school science teacher, I had a few choice quotes posted around my classroom.  Some were motivational while others were thought provoking. One of my favorites was by Winston Churchill.

“All men make mistakes, but only wise men learn from their mistakes.”
-Winston Churchill

Granted I tweaked it from “men” to “people” so as not to exclude the other genders in my class. My purpose for that one was to prevent frustrations over calculations, lab results, or high school in general.

On June 2, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule on Docket No. HM-218H. That docket number had some as miscellaneous amendments to Hazardous Materials Regulations. Now, two years later we have a corrective rulemaking to HM-218H. Published on June 18, 2018 with an effective date of July 18 and compliance date of September 17, it addresses some appeals and comments to that previous rulemaking. Let’s see what changed or was corrected.

Updated/Changed Sections

  • 604 Emergency Response. Emergency response telephone numbers must be displayed in numerical format only. A shipper is no longer allowed to use alphanumeric phone numbers for the emergency response number. For example, 1-800 CLEAN IT is no longer an acceptable emergency response phone number. It must be listed as 1-800-253-2648 going forward. No enforcement actions will be taken from July 5, 2016 to Continue Reading…
TDG
Transport Canada Moves to Update ERAP Requirements

TDG Update - Man Staring in to warehouse

TDG Emergency Response Assistance Plans (ERAP) Update

On June 30, 2018, Transport Canada issued a proposed amendment to Part 7 of the Transportation of Dangerous Goods Regulations (TDG). This part covers the requirements for Emergency Response Assistance Plans, or ERAPs. Details can be found on Government of Canada’s website.

Canada’s ERAP requirements are unique, not being adopted from the UN Recommendations on the Transport of Dangerous Goods. Essentially, they require consignor of significant amounts of high risk dangerous goods to establish a specific protocol, often involving an on-call response team, that can assist local responders in case of a release. Transport Canada must review and approve the plan before the consignor can offer or import affected shipments (although the approval only has to be issued once.) Since the Lac-Mégantic disaster in 2013, improving ERAP requirements has been a particular concern of Transport Canada’s.

The June amendment has four main goals:

  1. To clarify how an ERAP should be implemented;
  2. To enhance emergency preparedness and response;
  3. To reduce the regulatory burden for those affected by the requirement; and
  4. To make some general “housekeeping” changes to keep all parts of the regulations harmonized.

Clarifying Implementation of ERAPs

Currently, the regulations are unclear as to how exactly an ERAP would be implemented – presumably it would be by emergency responders or by the person with control of the released material, but it’s never been Continue Reading…

bathroom scale
Our Boxes Keep Getting Better

ICC Has Gained Weight – In a Good Way!

In a society where oftentimes less is more, diet trends have come in many forms. Whether it’s the ketogenic diet, South Beach, or Atkins, many of us are looking to drop a few pounds and go lighter. But in the dangerous goods packaging world, the higher the weight allowance, the better. A higher weight allowance on the UN certification marking means that you can ship more of your dangerous goods in the outer packaging.

An example of this is the UN marking from our BX-8SP variation box below. As you can see it carries a 5.4 KG weight rating, meaning that is the maximum gross weight limit allowed when shipping dangerous goods in this box.

BX-8SP UN Number

New Gross Weights for ICC Packaging

Here at ICC Compliance Center we are in the process of increasing the weight limits on our boxes. As you can see in the chart below, we are already off to a great start.

Part Code Old Weight New Weight
BX-8SP 4.2 KG 5.4 KG
BX-10SP 16 KG 18.5 KG
BX-11SP 2.8 KG 3.5 KG
BX-19SP 10.1 KG 15 KG
BX-21SP 12.8 KG 16 KG
BX-79 7.7 KG 8.6 KG
BX-12QT20PT 22 KG 23.7 KG
Weights accurate as of the date of publication and are subject to change

Stay tuned … there will be more to come in the coming year!

Friday the 13th square icon
Superstitions in Reference to Safety

Black cat on a beach

We have another Friday the 13th in July. Let’s take a look at a few more superstitions to see how they might impact safety in the workplace and home. As a reminder, a superstition for the purpose of this blog is a belief or notion that while irrational and not scientific seem to persist in society.

Superstition #1:
A black cat crossing your path brings bad luck

While many ancient civilizations held cats in high esteem like the Egyptians, there are others who feared them. In the Middle Ages people were very afraid of witches and magic. Throughout that craze, the belief was a witch could disguise or transform herself into a cat. The cat could then move more easily around a town causing mischief and mayhem. Cats were often blamed for disease outbreaks such as the plague.

Many sites have certain cleanliness standards. Those standards could include washing hands before and after work or leaving contaminated clothing at the facility. Now those rules don’t speak specifically to black cats, but you get my meaning. There is certainly nothing in any regulations in regards to having animals at home where they are often kept as pets. Certain city rules may limit the number of animals you can have or bans against certain breeds. I won’t go into my personal opinion on that topic. Animals at home just need to be taken care Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 25

Carrier Variations, WHMIS vs. OSHA, Placarding, Lithium Batteries and More Lithium Batteries

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. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.

Carrier Variations

Q. Can you help me understand what I did wrong or how to respond to them?

DHL is the carrier for my product. It is UN3077 and it is packaged 25 kg per fiberboard box. They sent me the following comments regarding my shipment.

They told me the country of USA must be a part of my address on the shipper’s declaration. They also said I had to use PI 956 even though it is marked and labeled as a limited quantity shipment. Finally, they told me I had to include the place and title on the shipper’s declaration.

A. First of all, carriers can ask for things beyond what is in the regulations. Sadly, you must comply with their requests if you want your shipment to proceed. Having said that there are a few things about your points that I can provide some regulatory framework for should you choose to push the issue with them. As to the country of USA being required, the IATA regulations never Continue Reading…
Radioactive
Class 7 IAEA Regulatory Update – SSR-6 Rev. 1, June 2018

Radioactive material warning sign at the package

Regulations for the Safe Transport of Radioactive Material

– Specific Safety Requirements No. SSR-6 (Rev. 1)

As expected, the IAEA has published the 2018 amendment to SSR-6 as Revision 1 (SSR-6).

This Revision removes the term “radiation level” from Section 2 “Definitions,” replacing it by “dose rate” to designate the dose equivalent per unit time (e.g. mSv/h). The associated changes to sections referencing the term throughout the document account for many of the other paragraph (para.) changes.

Also deleted from this edition are the requirements for testing LSA-III material for residual water activity below 0.1 A2 in the 7-day leachate test.

Table 2 “Basic Radionuclide Values” has been updated to include entries for:
Ba-135m, Ge-69, Ir-193m, Ni-57, Sr-83, Tb-149 and Tb-161.

Enter SCO-III

Perhaps the most significant change is the expansion of surface contaminated objects (SCO – “a solid object that is not itself radioactive but which has radioactive material distributed on its surface”) to add SCO-III provisions in the regulation. The Table 1 list of UN numbers, proper shipping names and descriptions now includes SCO-III to SCO-I and SCO-II for UN2913.

In addition to meeting the general requirements for the SCO designation, SCO-III objects are defined in para. 413(c) as a large solid object that is too large to be transported in the type of package described in SSR-6. There are other criteria to be met regarding sealing of openings, insides being as dry Continue Reading…

Environmental Update
EPA e-Manifests Open to Waste Generators

Using computer near truck

Are You Ready for e-Manifests?

Paperwork – it’s one of the worst parts of dealing with hazardous waste shipments. In both Canada and the United States, hazardous wastes require a special document, the Waste Manifest that will not only serve as the transportation document for the dangerous goods/hazardous materials transportation regulations, but also allow environmental authorities to track the waste from the generator, who sends it for disposal, through the hands of the carrier, to the end receiver (in the US referred to as a TSDF, for Hazardous Waste Treatment, Storage and Disposal Facility).

In Canada, some jurisdictions have eased the burden by allowing the waste manifest to be created electronically. For example, in Ontario, the HWIN system has been used for years. However, until now, the United States has not had a system for electronic documentation, called e-Manifests. On June 30, 2018, that has changed.

The change has been a long time coming. Although the initial proposal by the Environmental Protection Agency (EPA) was made in 2001, it was not until 2012 that Congress passed the “Hazardous Waste Electronic Manifest Establishment Act.” Under the Act, a final rule was published in 2014 that approved the use of such manifests. Since then, the EPA has been working to create an online system that will allow the e-manifest to eliminate substantial chunks of the burden of manifests, as well as Continue Reading…

Lithium
Detained Battery Shipment – Fixed!

AA sized lithium battery cells

What Happens When Watt-Hour is not Marked on Each Battery?

Well a few things – beginning with the shipment being stopped until the error is corrected by trained personnel like us.

It is mandatory to have the watt-hour marked on a lithium ion battery (unless it’s manufactured before January 1, 2009), and batteries that don’t display this mark are considered non-compliant for transport. To bring it in to compliance each battery must be marked with the watt-hour.

Doesn’t seem too bad, right? Wrong.

Imagine individually marking 11,600 little batteries.

These batteries were the size of AA batteries. Each individual battery was packaged in its own little box. Like a lipstick box. Then these little boxes (20 in total) were placed in a larger box. Then the larger boxes were placed inside a bigger cardboard box. Never had I done a job this tedious. Add to this trying not to break the small flap on the little boxes when opening these boxes.

The first day was a disaster as we weren’t prepared with the right tools. Finger nails were hurting from opening the little boxes. That night ideas were rolling in everyone’s head on how to efficiently do this job as it took 7 hours, and 2 people to finish 800 batteries. At this rate it would take 2 weeks to do this job.

The next day a tool was brought to speed up Continue Reading…