Anyone that has taken a training class with me discovers my secret love of superheroes. There is just something about them that makes life fun. They show up in all sorts of places during training. From signatures on shipping documents to addresses on packages, it is just a little something to make training a little less boring. I bring this up because the National Fire Protection Association (NFPA) has designated the week of October 6th-12th as Fire Prevention Week. This year’s theme is – Not every hero wears a cape. Plan and Practice Your Escape.
According to the NFPA website, some home fires can limit a family to only one or two minutes of time to get out and reach safety. Let that sink in for just a little bit. Two minutes is not a lot of time to make life saving decisions. This is why the goal of this year’s week is to have people make their own home escape plans AND to practice them.
Since Canada first created regulations on the transportation of dangerous goods, those who “handle, offer for transport or transport” dangerous goods must be adequately trained. The question, of course, is what does “adequately” mean? Section 6.2 of the Transportation of Dangerous Goods Regulations (TDGR) says that it means “the person has a sound knowledge of all the topics … that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport,” but that still doesn’t clarify how the employer should verify that the knowledge is “sound.” Now Transport Canada, in consultation with the Canadian General Standards Board (CGSB), has attempted to answer that question.
The proposed standard would establish two levels of training. First, a “general awareness” segment, that should be approximately 2 hours long, which would cover the basics of how the TDGR works. Then, when employees are familiar with those concepts, they would receive “job specific” training, which would specifically address the job functions they do in that organization.
The Labor Day Holiday generally symbolizes the end of summer for many people. For many businesses it is the end of their fiscal year. For parents in many areas it means back to school. For the Pipeline and Hazardous Materials Safety Administration (PHMSA) it means releasing notices of proposed rulemakings. We also have OSHA publishing their Top Ten Violations. Finally, it is time for IATA to publish the list of significant changes for their upcoming edition.
Keep in mind, these changes are in the 61st edition of the IATA. It goes into force January 1, 2020. The other thing to remember is these are just a list of “significant” changes. Some of the changes always seem a bit cryptic to me. Plus, I’m one of those folks that takes the old one and compares it to the new one to better understand exactly how it changed. Guess it comes from being a visual learner.
If you should want to read the list of changes, it can be found here. A brief overview of some of the changes are shown below for quick reference. There is a little something for everyone in the industry. As you read through, there are some times where I added some information to supplement the change as it is stated on the publication.
Brief Summary of Some Proposed Changes by Section:
Another Friday the 13th is upon us. This is the third time we will look at a few superstitions to see if there is any benefit to us in regards to safety. Keep in mind I am using superstition in a broad sense. For this blog, a superstition is any idea or belief that may not be entirely rational or scientific but is still used today.
Superstition #1: Holding Your Breath While Passing a Cemetery
Death is always an odd subject that triggers varied reactions in people. For many it is a sad time due to the loss of a loved one or friend. A wake and funeral are held to honor their passing. For others it is a chance to celebrate someone’s life, like the Second Line Parades in New Orleans. For this particular superstition, you are supposed to hold your breath to prevent recently passed or evil spirits from possessing you to live life again.
From a transport point of view, this probably isn’t too great of an idea and should never be done. In fact, there are several published articles in medical journals stating the negative effects of holding your breath for too long. Some of the negative impacts are issues with blood sugar, coordination and even neurological damage. Imagine a truck driver holding his breath as he passes a cemetery, especially a large one that Continue Reading…
In the vast world called the dangerous goods community, it can sometimes feel like we are specks in the universe, simply just faces in the crowd. The regulations exist, and we follow them. However in certain cases like in the latest NPRM, we do have a voice. What is a NPRM you may ask? It stands for a notice of proposed rulemaking, which derives directly from requests from within the dangerous goods regulatory community to address a variety of provisions within the regulations. That’s right, we can make a difference! The purpose of this is to help clarify, improve, and provide relief from the various regulatory requirements when shipping dangerous goods. As a result of the requests, PHMSA addressed a wide variety of provisions including those addressing packaging, hazardous communication, and incorporation by reference documents. Some of the proposed amendments include revising the basis weight tolerance provided in § 178.521 from ±5% to ±10% from the nominal basis weight reported in the initial design qualification test report for paper shipping sacks, incorporating by reference updated versions of multiple Compressed Gas Association (CGA) publications, and removing the words “manufactured before September 1, 1995” from § 180.417(a) (3) to allow for an alternative report for cargo tanks manufactured after September 1, 1985.
Per PHMSA, these revisions proposed therein are intended to reduce regulatory burdens while maintaining, or enhancing, the existing level of safety. In this NPRM, Continue Reading…
Health Canada recently issued a series of 6 new or updated guidance documents to assist stakeholders in maintaining compliance with various aspects of the Hazardous Products Act/Regulation (“WHMIS 2015”) and assist importers/exporters in comparing the Canadian requirements to those of the US 29CFR OSHA (“HCS 2012”). These documents are reviewed briefly below with the link to the Health Canada site where the full document is available.
a) Joint HC & OSHA Guidance
This 15-page document compares key features between WHMIS 2015 and HCS 2012 from the perspective of jurisdiction and responsibilities. A summary table is included that highlights the areas of: authority (Federal v. Provincial/Territorial or State); and responsibilities (Supplier v. Employer v. Worker) in each country.
The document was published July 31, 2019 and is available in PDF/HTML at:
Following the April 2018 amendment to re-introduce use of concentration ranges for confidentiality purposes, this 20-page document has been issued to provide guidance on how to apply the HPR s. 4.4 and 4.5. This document replaces the information in the Dec. 2016 Technical Guidance document. A table in the document provides a comparison of this aspect between WHMIS 1988, WHMIS 2015 (pre-April 2018 amendment), WHMIS 2015 as amended in 2018 and the US HCS 2012.
The document was published August 2, 2019 and is available in PDF/HTML at:
Effective July 31, 2019 the fines for civil penalties within the Department of Transportation are increased. This increase impacts the Federal Aviation Administration (FAA), the Pipeline of Hazardous Materials Safety Administration (PHMSA), the Federal Railroad Administration (FRA), the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA).
The fines are increased as a result of the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. This happens every year, so you would think it would have an abbreviation at this point. This act basically requires federal agencies to adjust civil penalties each year to account for inflation. A list of the increases for 49CFR is shown below. These are found in 49CFR Part 107. A definition for “Penalties of non-compliance” is found in 171.1. To see the full ruling with the changes to the other agencies, go here.
Maximum penalty for a hazardous materials violation is $81,1993.
Maximum penalty for hazardous materials violation that results in death, serious illness, or severe injury to any person or substantial destruction of property is $191,316
Minimum penalty for hazardous materials training violations is $493.
Maximum penalty for each pipeline safety violation is $218,647
Maximum penalty for a related series of pipeline safety violations is $2,186,465
Maximum penalty for liquefied natural gas pipeline safety violation $79,875
Maximum penalty for discrimination against employees providing pipeline safety information = $1,270
From time to time the Universe aligns and changes in the dangerous goods shipping regulations actually make our lives a bit easier. That is the case now that The United States Postal Service (USPS) has published new options for hazardous materials markings in their June 20th Postal Bulletin. USPS is now piloting the use of smaller Excepted Quantity and Limited Quantity marks incorporated into or applied adjacent to the address label which allows a minimum size of no less than 50 millimeters (1.97 inches) in height and width. For use of the smaller marks, you must first request authorization through the USPS Product Classification Group. Additionally The DOT has recently issued a special permit to allow a Limited Quantity mark of a minimum of 50 millimeters on each side when placed adjacent to the package tracking label. The Postal Service temporary authorizations are expected to align with DOT’s special permit process.
Limited Quantity Mark Excepted Quantity Mark
If you are interested you should request authorization through the USPS Product Classification group at the address below:
Manager, Product Classification 475 L’Enfant Plaza SW Rm 4446 Washington DC 20260
The request for authorization should include:
A description of the general products you are shipping;
Your company name and address;
The requestor contact information (name, email, phone, etc.); and
A picture of the proposed marking (size) on the postage label/address side of the package
Since 2010, World Hepatitis Day is observed on July 28th. The goal is to raise awareness of hepatitis as well as the prevention and treatment of the disease. According to the World Health Organization (WHO), hepatitis cause two in every three liver cancer deaths and overall 1.34 million deaths a year. We all need to be educated. This is not a disease found in just one country, a particular ethnicity or age. Here is the chance to educate ourselves.
Hepatitis is the inflammation of liver tissue. It is most commonly caused by a virus and there are five main ones commonly referred to as Types A, B, C, D and E. Types A and E are usually short-term (acute) diseases. Types B, C, and D are likely to become chronic. Type A is contracted by direct contact with fecal matter or drinking water contaminated with fecal matter. that has the virus in it. Type E is the result of indirect contact with fecal contaminated food and water. This is why many people are under the misconception that you can only get hepatitis in 3rd world countries where sanitation is not the best. Types B and C are caused by contact with an infected person’s bodily fluids such as blood. Type D can only happen if someone is currently infected with Type B.
Every year when teaching the concept of density to high schoolers, I would use the story of Archimedes and the king’s crown. They really enjoyed the part of him running naked through the streets shouting, “Eureka, I have found it.” Since that time, the concept of “eureka moments” has become a thing. The moment you finally realize, understand, or discover something is a “eureka moment”.
My most recent one occurred while updating ICC’s lithium battery courses. You see, I’ve always struggled with a few paragraphs in 49CFR 173.185. The paragraphs in question are (c)(1)(iii) and (c)(1)(iv) for those smaller or “excepted” cells and batteries. My brain just couldn’t comprehend or truly understand what they were telling me. Add to that the changes brought in by the interim final rule HM-224I and my brain was just fried. Both paragraphs are shown below for your reference.
173.185(c)(1)(iii) Except when lithium cells or batteries are packed with or contained in equipment in quantities not exceeding 5 kg net weight, the outer package that contains lithium cells or batteries must be appropriately marked: “PRIMARY LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”, “LITHIUM METAL BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”, “LITHIUM ION BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT” or labeled with a “CARGO AIRCRAFT ONLY” label specified in §172.448 of this subchapter.
173.185(c)(1)(iv) For transportation by highway or rail only, the lithium content of the cell Continue Reading…