Regulatory Helpdesk: October 30, 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 Labeling

Q. If a product is manufactured in Canada strictly for export into the US, does it require the French on the GHS label?

A. HPR (Hazard Products Regulations) section 5.14, subsection 3. These exemptions from labeling and SDS (safety data sheet) requirements apply to importation (subsection 5.14(2) of the HPR) and sale, for the purposes of exportation (subsection 5.14(3) of the HPR), of hazardous products that are not meant to be used in a work place in Canada. Such hazardous products do not require an HPR compliant label or SDS.

Lithium Battery Labels

Q. When does the 12 mm UN number height requirement start?

A. The IATA 59th edition states the UN number height should be 12 mm. Since IATA 59th edition becomes mandatory on January 1, 2018, the UN height change is effective then. Keep in mind however that IATA defines “should” as a recommendation, it is not mandatory.

Q. I have a question on the red slash marks all the way around the label – what is the requirement on that?

  • Do they have to be so many of the red slash marks? – is there a specific number of slashes there has to be to be compliant?
  • What is the length measurements of the slash mark – and is there a specific size it has to be to be compliant?

A. In terms of the red hatchings, neither IATA nor 49 CFR mention specifically how many there needs to be on the label.  The specifications that are mentioned are that it must be red per 49 CFR 173.185 (c) (3) (i)[b] and in IATA it states per 7.1.5.5.3 that it must be red and the minimum width of the red hatchings must be 5mm.

Marking on a Package (Canada)

Q. Customer called to ask if the ISHP (Identification number, Proper shipping name, Hazard class, Packing group) format was mandatory on product package labels.

A. The TDGR sections 4.8, 4.10 & 4.11 were reviewed. ISHP order is mandatory on a document but not on a package – only required that “I” & “S” be next to “H”. PG (“P”) is not required, but it can appear if desired.

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