Seat belts
Grateful Dead and Truck Seat Belts?

FMCSA Final Rule

Occasionally a change to a regulation comes along and just the title of it triggers the memory of a song in my head. On June 8th the Federal Motor Carrier Safety Administration (FMCSA) published a final rule regarding passengers in commercial trucks. As soon as I saw the words “commercial trucks” the Grateful Dead’s song “Truckin’” popped into my head. For a reminder of this song, take a listen here. Throughout the song various cities are mentioned and the song itself is about the band travel exploits. The irony of this band and safety is not lost on me!

Now that the song is stuck in your head which are called “ear worms” by the way, let’s talk about the actual change to the regulation. For years commercial truck drivers have been required to wear seat belts but passengers did not. That is about to change. The revision goes into effect on August 8th and now requires all passengers riding in commercial trucks to wear a seatbelt. If a passenger fails to do so, then the driver will be held responsible.

We all know that wearing a seat belt can save your life. According to the National Highway Traffic Safety Administration in 2014, “37 passengers traveling unrestrained in the cab of a large truck were killed in roadway crashes”. Granted that’s not a large number, but any loss of life that can be prevented should be.

FMSCA periodically asks drivers to complete surveys to get a feel for what’s happening on the roads. One such survey was given on the topic of “Seat Belt Usage by Commercial Motor Vehicles (CMV) Drivers”. The results showed a difference between drivers and passengers and their seat belt usage.  Drivers wore a seat belt 84% of the time while passengers only 73%. Again the difference isn’t large but wearing a seat belt is such a simple form of protection.

The summary of the final rule in 49 CFR Part 392 is as follows:

FMCSA revises the Federal Motor Carrier Safety Regulations (FMCSRs) by requiring passengers in property-carrying commercial motor vehicles (CMVs) to use the seat belt assembly whenever the vehicles are operated on public roads in interstate commerce. This rule holds motor carriers and drivers responsible for ensuring that passengers riding in the property-carrying CMV are using the seat belts required by the Federal Motor Vehicle Safety Standards (FMVSSs).

To read the full final rule on this matter, go to here.

For all of your transportation needs, ICC Compliance Center is here.  We offer all types of training, labels, and placards. With our help you will “pick a place to go, and just keep truckin’ on.”

Motorcycles – Yes, They are Dangerous Goods

If you are feeling “Born to Be Wild” – Steppenwolf and looking to race down life’s highway on two wheels this summer, but short on time, or looking for an even better adventure across the pond, fly your bike and meet it there.

Wait! You can’t just show up at the airport and check in your motorcycle. Did you know that a motorcycle is considered to be a dangerous good? Under the IATA regulations, a motorcycle is classified as UN 3166, Vehicle flammable liquid powdered, hazard class 9; and therefore needs a shipper’s declaration form.

What does this mean to the average motorcycle enthusiast? It means that you need to seek the advice of a dangerous goods consultant, who specializes and can assist in providing instruction on the preparation of the motorcycle, and provide the proper signed shipper’s declaration.

According to Air Canada, some of the requirements at time of tender include:

  • The fuel tank must be drained as far as practical; and fuel must NOT exceed ¼ of the tank capacity
  • All batteries must be installed and securely fastened in the battery holder of the vehicle and be protected in such a manner as to prevent damage and short circuits
  • Spare key, to be left in the ignition
  • Alarm (theft-protection devices, installed radio communications equipment or navigational systems must be disabled
    Air waybill number (booking number)
  • Saddle bags may be filled with equipment, parts, etc. An itemized list of the content of the saddle bags must be provided at time of tender.
  • Personal effects such as a clothing, toiletries and luggage cannot accompany the motorbike. (Dangerous goods such as lubricants, spray paints etc. must be left behind)

ICC Compliance Center offers declaration services across Canada, and can work with you to find a consultant in other countries as well. Contact us at least 2 weeks before you plan to start your adventure.

Have fun and contrary to the opening statement, no racing! Simply stay safe enjoy the sun on your face and the wind in your hair!

PHMSA
Correction to HMT in 49CFR

On Monday, April 25, 2016 the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a correction to the 49CFR Hazardous Materials regulations in the Federal Register.

The correction states:

“In Title 49 of the Code of Federal Regulations, parts 100 to 177, revised as of October 1, 2015, on page 269, in § 172.101, in the Hazardous Materials Table, for the entry ‘‘Phenylmercuric compounds, n.o.s.’’ add ‘‘G’’ in the first column.”

The federal register notice can be viewed here: https://www.gpo.gov/fdsys/pkg/FR-2016-04-25/pdf/2016-09615.pdf

The “G” in the first column of the Hazardous Materials Table (HMT) identifies proper shipping names for which one or more technical names of the hazardous material must be entered in parentheses, in association with the basic description. The technical name(s) must be shown on package marking and shipping papers. Failure to comply with the corrected information can result in non-compliant shipments.

Toxic
The Zika Virus — Public Health Crisis and Regulatory Puzzle

Zika virus – the name itself sounds exotic and dangerous. It is believed to be a serious risk for pregnant women. And it’s due to arrive in North America. Just how great a danger is this virus, and how should research and medical facilities prepare for the regulatory burden?

First of all, Zika is not a new virus. It has been known since the 1950s in equatorial Africa and Asia, but only recently has it appeared to migrate to new territories, including South and Central America, the Caribbean and Mexico. It is primarily a mosquito-borne illness, transmitted by the Aedes genus of mosquitos. Possibly climate change has increased the populations of these mosquitos in the areas where Zika is spreading. Aedes mosquitos are found in some parts of the U.S., and although they are not currently believed to be in Canada, they may spread as the climate warms. Person-to-person transmission by body fluids is possible, but this would be relatively rare compared to the mosquito vector.

Zika is classed in the Flaviviridae family of viruses, along with dengue fever, West Nile virus and the notoriously dangerous yellow fever. However, compared to these, Zika is usually a mild affliction. According to the Centers for Disease Control (CDC), only one in five persons infected with the virus shows any symptoms at all. For those who do fall ill, the symptoms are described as flu-like: fever, joint and muscle pain, inflammation of the eyes (conjunctivitis) and a rash. Although there is no cure, and the virus does not respond to antibiotics, the infection normally resolves without treatment within a week. Fatalities are extremely rare. In other words, Zika is, for most people, a mildly unpleasant illness that they recover from quickly. Even better, exposure to Zika usually results in lasting immunity.

So, why has Zika become such a big issue in public health? While most people only become mildly ill when infected with Zika, the infection appears to be correlated to increases in two much more serious conditions: the neurological condition called Guillain-Barré syndrome (which can be triggered by a number of infections), and most tragically, the birth defect called microcephaly.

Microcephaly is a condition where a baby’s head is smaller than normal, and often includes abnormal brain development. The CDC indicates “problems can range from mild to severe and are often lifelong. In some cases, these problems can be life-threatening.

It should be noted that we don’t yet have a conclusive linking of Zika to microcephaly, but some relatively strong evidence has been gathered. There appears to be a statistical increase in microcephaly in the children of mothers infected by Zika, as well as evidence that the virus can pass the placental barrier. The virus has been found in the brains of affected infants. So, it seems at least plausible that there is connection between the condition and exposure to the virus during fetal development. We don’t yet know just how likely the condition will be if the mother is infected with the virus, and we don’t know if it can occur at any stage in fetal development, or if there is only a short window of time for the defect to arise.

It would appear, therefore, that the main public health issue is the risk to developing fetuses. This is not a new problem; pathogens such as those responsible for rubella (German measles) and toxoplasmosis are also known to cause serious birth defects. But Zika has gathered headlines due to its fast spread, its previously unknown status to the public, and the difficulty in avoiding exposure to mosquitos if you live in an area where the disease is prevalent.

Based on mosquito distribution, it’s likely that Zika will obtain at least a foothold into the United States. Canada may be at less risk due to its colder climate, but there is a possibility of spread as global temperatures warm. The CDC and Health Canada have put out advisories to help people protect themselves from exposure to the virus. But medical facilities and laboratories must also take steps to prepare for Zika’s arrival, from preparing the infrastructure to send samples for analysis and diagnosis, to disposing of contaminated linens.

The first step in transporting infectious substances is to classify it according to either the U.S. “Hazardous Materials Regulations” of 49 CFR, or Canada’s “Transportation of Dangerous Goods Regulations”. Although many disease organisms have accepted classifications established for them (such as those found in the IATA Dangerous Goods Regulations), Zika virus is so new to North America that there has not yet been an official classification assigned.

Pathogens fall under two categories. Category A is used for organisms that are “transported in a form that, when exposure to it occurs, is capable of causing permanent disability, life-threatening or fatal disease in otherwise healthy humans or animals.” Pathogens that do not meet that criteria will be classed as Category B, less hazardous.

Although it is not immediately dangerous to the person affected, Zika is capable of causing permanent disability (birth defects) or life-threatening conditions (Guillain-Barré syndrome). However, it is not likely to cause these effects simply from a spill in transportation – it appears that direct blood contact is necessary to contract the disease. Unless the Department of Transportation or Transport Canada make an official determination of the appropriate category, as they did in the SARS outbreak, the decision will be the shipper’s, and should be guided by medical or scientific personnel. It may be noted that many other viruses in the Flaviviridae family have a split classification; they are placed in Category A when transported as a culture (artificially propagated to increase the virus concentration), but Category B when transported in samples in their natural state, such as blood or other body fluids.

Once the classification has been determined, packaging must be selected for Category A or B as appropriate. Obviously, the highly dangerous Category A organisms will require a much more secure packaging, one which must be approved to a standard created by the United Nations. Category B packages do not have to meet UN specification, but they must follow the regulations for construction and use. Note that ICC Compliance Center can provide packagings for various needs, from shipping small samples to disposing of contaminated linens as hazardous waste.

Once assembled, you must identify the package as containing Category A or B substances with the appropriate safety marks and labels. Note that Category B substances do not have to show the Class 6.2 label, but must show a diamond with the applicable UN number, UN3373, in the center. Category A pathogens will require full dangerous goods shipping papers. Most regulations exempt Category B from some or all of the shipping paper requirements. While placards are not required for Class 6.2 materials under the “Hazardous Materials Regulations” in the U.S., Canada does require placards if the shipment exceeds 500 kilograms or is subject to an Emergency Response Assistance Plan (ERAP). And, of course, personnel performing dangerous goods functions must be trained and certified in the appropriate regulations.

If you intend to ship pathogens outside your own country (for example, for international research efforts), remember that exporting and importing of infectious substances will involve additional regulations, such as the CDC’s Import Permit Program.

For more information on protecting yourself and your family from Zika, consult the Centers for Disease Control, or Health Canada.

 

Do you have questions about how to transport infectious substances? Need labels, packaging or other supplies for such shipments? Contact ICC Compliance Center here at 888-442-9628 (U.S.) or 888-977-4834 (Canada), and ask for one of our regulatory specialists.

Special Permits
Adoption of Special Permits into the HMR (HM-233F)

There was a Legislative act signed by US president Barack Obama in July of 2013 called Moving Ahead for Progress in the 21st Century Act or MAP-21. As a result, the Pipeline and Hazardous Materials Safety Administration (PHMSA) is making changes to the Hazardous Materials Regulations (HMR). These changes will incorporate some provisions from some of the special permits that have a proven safety record and have been widely used over an extended period of time. The intent in doing this is to provide widespread access to regulatory flexibility normally offered in special permits and removing the need for abundant renewal requests. The adopted amendments will also reduce paperwork burdens and help commerce while sustaining an appropriate level of safety.

Special permits set out variances to the requirements found in the regulations, but still has a level of safety that is equal to the safety level required otherwise in the regulations. The MAP-21 legislation required PHMSA to take a look at the special permits that have been in effect for 10-years. PHMSA conducted an investigation of all active special permits and categorized them, as appropriate, as suitable for inclusion into this rulemaking.

The result is PHMSA amending the regulations, 49 CFR Parts 171–180, by accepting requirements within 96 existing special permits. These amendments are based on the review they did of all active special permits as of January 1, 2013. There were 1,070 Special Permits that were not suggested for inclusion in the HMR due to these special permits having requirements that do not have a wide range for applicability, have already been implemented into the HMR, are being addressed in other rulemakings, or were removed after receiving comments in response to the notice of proposed rulemaking (NPRM) under this HM-233F.

In doing this PHMSA was to determine which ones may be implemented into the HMR. This also required PHMSA to adopt any special permits identified for inclusion in a final rule by October 1, 2015.

The factors to be considered during the examination to determine suitability for implementation into the HMR are as follows:

  1. The safety record of the hazardous materials (hazmat) transported under the SP;
  2. The application of a SP;
  3. The suitability of the provisions in the SP for incorporation into the hazmat regulations; and
  4. Rulemaking activity in related areas. [i]

Before the MAP-21 was put into legislation, PHMSA had already completed a number of rulemakings to adopt some special permits that had a proven safety record into the HMR. Some of these can be found on Table 1[ii] in this final rule.

After the passing of the MAP-21, PHMSA had to change its approach to fulfill the requirements set forth in this legislation. They established terms for reviewing, set up criteria and categories, and put tools in place to help track and facilitate in analyzing current special permits in timely and efficient manner.

In the MAP-21 Legislation the Federal Hazardous Materials Transportation Law was revised to address the “SP and exclusions,” section under paragraph (f).

It states:

(f) Incorporation into regulations.

(1) IN GENERAL-Not later than 1 year after the date on which a SP has been in continuous effect for a 10-year period, the Secretary shall conduct a review and analysis of that SP to determine whether it may be converted into the hazardous materials regulations.

(2) FACTORS-In conducting the review and analysis under paragraph (1), the Secretary may consider-

(A) the safety record for hazardous materials transported under the special permit;

(B) the application of a special permit

(C) the suitability of provisions in the special permit for incorporation into the hazardous materials regulations; and

(D) rulemaking activity in related areas.

(3) RULEMAKING- After completing the review and analysis under paragraph (1) and after providing notice and opportunity for public comment, the Secretary shall either institute a rulemaking to incorporate the special permit into the hazardous materials regulations or publish in the Federal Register the Secretary’s justification for why the special permit is not appropriate for incorporation into the regulations[iii]

PHMSA was also required to implement standard operating procedures (See my previous blog on SOP) to assist with the special permit review and approval processes.

PHMSA has requested comments from holders of special permits that were not implemented. “We stated that we were particularly interested in comments that confirm or refute the suitability, safety, and general applicability of the Special Permit. We asked that if you are a holder of a SP that was not proposed to be adopted but believe it should be, you should submit material to support such an argument.”

They requested that special permit holders submit information and supporting arguments along with technical/scientific data as well as the cost, benefits and frequency of shipments made under said special provision. Information regarding any incidents during transport with said special provision and how often the incidences occurred is also to be provided. PHMSA also asked for commenters to include suggested regulatory text.

The final rule includes much more detailed information like a special permit conversion project chart, where the method is shown on how they staged the analysis and decision process. This includes the specific Special Permits proposed for inclusion, also includes many comments from industry that give a good look into what others are thinking, which brings in different useful perspectives. For more on this final ruling please follow the HM-233 links within this blog.

[i] Pg. 4 of the HM-233F Final Rule

[ii] Pg. 6 of the HM-233F Final Rule

[iii] Pg. 7-8 of the HM-233 Final rule

OSHA Flammable
“Light My Fire” – Calculating Flash Points for Flammable Liquids

One of the most common tests for determining hazard classification is the flash point. This humble piece of physical information is defined in various ways in various regulations, but generally is the lowest temperature at which the vapours from a flammable liquid will ignite near the surface of the liquid, or in a test vessel. This can be critical for safety, because this temperature will be the lowest possible for the liquid to cause a flash fire if released or spilled. If the material can be handled and transported at temperatures lower than the flash point, the fire risk will be much smaller.

The flash point has become the standard test for classifying flammable liquids. It’s used by the U.S. OSHA (Occupational Health and Safety Act) and HMR (Hazardous Materials Regulations) classification systems, as well as Canada’s WHMIS (Workplace Hazardous Materials Information System) and TDG (Transportation of Dangerous Goods Regulations).

Obtaining a flash point on a new product is usually easy enough. Many laboratories, particularly those that deal with petrochemicals, can perform the test for a reasonable charge. If your company has too many products to make outsourcing practicable, a flash point tester itself is comparatively low cost (as scientific apparatus goes), and a trained person can obtain data quickly and efficiently. However, both of these options do cost money. Wouldn’t it be nice if there were a way to avoid the expense?

For example, toxic materials are usually classified by a test called the LD50 (the lethal dose to 50% of test subjects). This is a more expensive, complicated test, but there’s one beautiful feature for mixtures. You don’t have to do the test if you can calculate it. This calculation basically prorates the LD50s of the ingredients based on their concentrations. While there is debate about how accurate this system is, it’s directly mentioned in the above regulations as an option if testing of the actual product has not been done.

Unfortunately, the same regulations do not directly provide us with a method for calculating a flash point. But OSHA and WHMIS are based on the Globally Harmonized System of Classification and Labelling, and TDG and the HMR are based on the UN Recommendations on the Transport of Dangerous Goods. Both of these documents do include a reference to calculating flash points if directly measured ones are not available.

That’s the good news. The bad news starts when we discover that both the Globally Harmonized System and the UN Recommendations don’t give the specific formula for the calculation. The GHS reference can be found in sub-section 2.6.4.2.2, while the UN Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria places the reference to a calculation in Appendix 6, paragraph 4. At least both of them refer to the same method, one reported by Gmehling and Rasmussen in the journal Industrial & Engineering Chemistry Fundamentals 21, 86, (1982) titled “Flash points of flammable liquid mixtures using UNIFAC”.

When we look up this article, we encounter another road block – like many scientific journals, this one is not free, and the article is behind a paywall. We have a choice; either pay up to read the full article, or see if the formula appears somewhere else.

Oh, and it helps if we know what UNIFAC is. Apparently the acronym stands for “UNIQUAC Functional-group Activity Coefficients” (making it an acronym containing an acronym), and is “a semi-empirical system for the prediction of non-electrolyte activity in non-ideal mixtures.”

A little more digging on the internet comes up with an article summarizing how to calculate various flammability measurements, published by M. Hristova and S. Tchaoushev in the Journal of the University of Chemical Technology and Metallurgy, 41, 3, 2006, 291-296, titled “Calculation of Flash Points and Flammability Limits of Substances and Mixtures.” This can be accessed, with no paywall, at http://dl.uctm.edu/journal/node/j2006-3/04-Hristova-291-296.pdf .

So, we finally have our method to calculate our flash points. Except it’s nothing like the relatively simple method for calculating LD50s. Hristova and Tschaoushev tell us the calculation will take four steps:

  1. Determine the flash point which satisfies an equation relating “the actual partial pressure of component i in a vapor-air mixture” with “the partial pressure in a gas-air mixture with a composition corresponding to the LFL (lower flammable limit) of pure component i”.
  2. Determine the flammability limits at the temperature under study using the Zebatekis equation. (This equation is helpfully included.)
  3. Determine the partial pressure of each component, using the Antoine equation, and
  4. Determine the activity coefficients using the UNIFAC method.

Easy, right?

At this point, it becomes obvious that these calculations are currently of use, perhaps, to physical chemists, but are not yet a workable solution for companies simply trying to determine if their product is in Packing Group II or III. It turns out that the molecular forces in flammable liquids are far too complex to reduce to a simple equation such as can be used for toxic mixtures. Even computer systems that model these mixtures must be taken as provisional, and certainly not nearly as reliable as measured data.

So, the day when we can toss aside our flash point testers and classify flammable liquids based only on the composition is yet to come. To comply with the classification rules for workplace safety or transportation, a measured flash point is still the simplest and most accurate solution.

Do you have any questions about classifying hazardous materials? Contact ICC Compliance Center here at 888-442-9628 (U.S.) or 888-977-4834 (Canada), and ask for one of our regulatory specialists.

When an Ordinary Box Isn’t so Ordinary After All (HazMat Box)

We have all used a fiberboard (or cardboard as most people call it) box to ship something. It may have been a box of gifts for a friend or family member, or a package of merchandise for a client at work. Most of the time, you probably didn’t give much thought to the box other than to make sure it was sturdy enough and big enough to contain what you were shipping. For these typical kinds of shipments, that ordinary box will do just fine. HazMat (or dangerous goods) shipments, however, aren’t ordinary and neither is the box that they need to be shipped in.

The packaging industry is a science in itself, with ever evolving processes, techniques, materials, treatments, and regulations. HazMat packaging is a specialized area of packaging technology, and it has some very specific requirements that must be followed. Even though a HazMat box may look identical to a standard shipping carton, there are some significant “behind the scenes” differences between them!

  1. Material matters! When dealing with HazMat boxes, there are specific tolerances for manufacturing. The combination of materials used to make up the fiberboard has very little wiggle room once the design has been approved and certified. Changes in the material may invalidate the certification and make the boxes non-compliant.
  2. Proven performance! HazMat boxes have to be put to the test before they can be certified for use. These boxes go through drop, stack, vibration, pressure, and other tests to simulate conditions they may encounter during transportation. Additionally, the design has to be re-tested every 2 years to ensure everything is still performing properly. While all packaging should protect its contents, it is extra important for boxes that contain HazMat to be up to the task.
  3. Recordkeeping! The manufacturer of a hazmat box must keep meticulous records regarding the construction, use, testing and any changes made to the packaging. These records are subject to inspection by government officials and can result in fines if violations are discovered.

These are just a few examples of what makes a HazMat box far from ordinary! Keep this in mind when you are selecting packaging for your HazMat shipments. If you need HazMat packaging, or to find out more information, call one of our customer relations centers today at 888-442-9628 in the US or 888-977-4834 in Canada.

Overpack Label
“OVERPACK” Markings – Overdone?

The Issue

The formalization of the overpack concept into the Canadian TDG regulations has been the subject of concern for domestic shippers of dangerous goods due to the wording for fully regulated (TDGR 4.10.1) products. The wording implies that even when the DG safety marks for packages within the overpack are visible, the overpack must still have an “OVERPACK” mark displayed. This leads to some additional labelling requirements, particularly for shippers of stretch-wrapped pallet loads.

Definition

We’ll pause to review the concept of an overpack, consistent among the various regulations (e.g. TDG, UN Model Recommendations, IMDG, IATA, & 49 CFR).
An overpack is non-standardized packaging that:

  1. Is used for handling convenience (e.g. to reduce multiple handling- I.e. 4 drums on a skid, allowing loading 4 at once rather than 4 trips, or 6 small containers in a “non-spec” master carton, or 48 small boxes stretch wrapped on a skid; a keg (small drum) in a non-spec box for stability, etc. )
  2. Cannot be used as a replacement for inadequate, required “standardized” packaging
  3. Is to be unopened between consignor and receiver
  4. Cannot interfere with the integrity of the standardized packaging (e.g. banding cutting into boxes on a pallet)

The common principle requires that the description of DG that cannot be seen once the overpack is in place will be reproduced on the outside of the overpack.

However, this could be misleading in that someone seeing the DG markings may assume “non-compliance” when there is no package certification mark on the overpack. Although the situation should be fairly obvious with, for example, a stretch wrapped pallet; a master carton situation could be confusing.

Thus we have the application of the “overpack” mark to signal that the specification package is inside.

Different Strokes

The system starts to get sticky when the wording used in the different regulations is phrased differently.

TDGR speaks of “the marks on the small means of containment”- which implies that each package’s markings must be visible to avoid the need to reproduce them on the overpack.

Other regulations (49 CFR, IATA, IMDG, UN Recommendations) insert the words “representative of…” (all DG or each HazMat) in the overpack. Thus, as long as safety marks representing the individual packages can be seen at least once, there should be no need to reproduce any on the outside of the overpack.

Furthermore, the sequence of the clauses in TDGR 4.10.1 requires the use of an “overpack” mark whenever an overpack is used, regardless of the visibility of the standard safety marks.

Part 4.10.1 says that (1) (b) & (c) “do not apply if the safety mark… is visible through the overpack”; but the overpack mark requirement is in 1(a) which isn’t included in the exemption. This is in the spirit of the UN Recommendations where the placement of commas in 5.1.2.1 implies that the lead-in requirement for an “overpack” mark applies even when the DG marks are visible.*

Neither IATA, DGR, nor the IMDG Code requires the word “overpack” to be applied if the DG safety marks are not required on the outside.

49 CFR puts a slightly different spin on things and requires an overpack mark only when packages in the overpack which require UN specification packaging do not have the UN specification marks visible.

Size Matters – Sometimes

The TDGR and 49 CFR both require safety marks on 2 opposite sides if the overpack volume is 1.8 cubic metres (approximately 64 cu.ft.) or more. IATA ans IMDG are silent on this aspect.

All except TDGR recommend “overpack” letters to be at least 12 mm high, warning that this will be mandatory January 1, 2016. Transport Canada has not yet commented on size of lettering.

Other Markings

Orientation arrows, as required by all but TDGR, must also be included for liquids.

IATA adds a requirement to assign a unique number to each overpack in a consignment when there is more than one. This numbering system is at the shipper’s discretion, but must be referenced on the Shipper’s Declaration for the consignment.

Limited/Excepted Quantities

All agree on waiving the need for any mark on an overpack consisting only of “limited” or “excepted” quantities when the DG marks are visible.

This would seem to be in accord with the concept that an “overpack” mark signals that, despite the safety marks on the outside, these materials by their classification do not require UN specification packaging.

Thus an observer/inspector trained to handle dangerous goods should not be confused when presented with these safety marks without the UN packaging markings.

*The UN Committee of experts was (as reported in the May edition of HCB) asked by Spain & Sweden to consider simplifying the wording of the model regulations. The CACD (Canadian Association of Chemical Distributers) has recommended that its members take a conservative approach to overpack labeling. The latter are hoping for a possible clarifying amendment to the TDGR later this year.

The “overpack” marking may be facilitated by the use of tape with repeating wording.

Danger Placard
Remembering Placards

Mnemonic Devices

How do you remember the meaning of something? Do you try to KISS it where KISS stands for – Keep It Simple Silly? Do you use mnemonics from elementary school and even through college to trigger your memory? I do, and boy how they make things easier. I bet you can remember ROY G BIV, the colors of the rainbow from art class. Music class they gave us easy ways to remember the treble clef with Every Good Boy Does Fine for the lines on the staff and FACE for the spaces. One of my favorites however, is PEMDAS to help remember the order of operations in math!

I am always looking for a fun way to help reinforce my memory. In the hazardous transportation industry there are so many things to remember or define. Oh and the acronyms!
Continue reading “Remembering Placards”

Why You Need the Most Updated Regulatory Texts

The Bible, Shakespeare and Transport Regulations

“Woe is me” is a phrase heard by many. It basically means someone is unhappy or distressed. The Bible uses this phrase in several locations including Job 10:15, Isaiah 6:5 and Psalms 120:5. Shakespeare later used this same expression when writing for his tragic character Ophelia in “Hamlet”. Existing and operating in the world of regulations can also bring on this feeling. It is difficult enough learning the basics of any regulation, but to truly “know” it takes time, patience and work. This process is complicated by the fact that many regulations change. Is it really necessary to have the newest, latest regulation? To answer that question it is time to look to the regulations.

International Air Transport Association (IATA):

For many, these are the Air Regulations. In this instance, the regulation is updated YEARLY. A new edition goes into effect on January 1st of any given year and ends on December 31st of that same year. The Regulation is currently on its 56th Edition. To showcase some of the changes that could apply to a variety of shippers, please read the following:

  1. The List of Dangerous Goods has new entries and/or updates to existing substances
  2. Packing Instructions for Lithium Batteries was updated to include not only a change but also a new addition
  3. Section 7 – Marking and Labeling for Limited Quantities has new information

Buy the most recent IATA publications from ICC »

International Maritime Dangerous Goods Code (IMDG):

For many, these are the Ocean Regulations.  In this instance, the regulation is updated every two years, but there is overlap between editions that can be confusing. The Regulation is currently on its 37th edition. This edition was published in 2014 and overlaps the previous 36th edition. The 37th edition is optional for use starting on January 1, 2015 and during this time compliance with either edition is allowed (View this transition chart for a visual representation of how this works). The 37th Edition is truly in force starting on January 1, 2016. To showcase some of the changes that could apply to a variety of shippers, please read the following:

  1. The Dangerous Goods List, special provisions and exceptions table has new entries and/or updates to existing substances
  2. The Classifications have at least one new/updated subsection

Buy the most recent IMDG publications from ICC »

49 CFR Parts 100-185 Hazardous Materials Regulations:

Here is the United States Department of Transportation Regulations (DOT). This regulation is different from the rest. It has NO schedule for updates.  It could be updated every day. To stay current, ICC carries updated versions of these regulations twice a year in March and October. Some changes within the past six months include the following:

  1. The Reference Materials has updated/revised text
  2. The Hazardous Materials Table has new entries and/or updates to existing substances
  3. Lithium Batteries have a specific section in Subpart E

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Given these update schedules and the changes within each regulation, be sure the most recent copies of the regulations are on hand. Some of the changes mentioned here can have a big impact on daily transport operations. It is a good practice to be “in the know” in order to avoid the “woe”.

As always, ICC Compliance Center is here for all of your hazard communication needs.

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