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 Continue Reading…
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 Continue Reading…

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!

What is a Placard?

Let’s take a look at placards. What is a placard? As defined in the Merriam – Webster dictionary a placard is defined as:

a large notice or sign put up in a public place or carried by people

Placards provide pertinent information about an area, a specific instruction, or a hazard. Placards are used in work places to communicate to people of special operating procedures. Placards are also used in transportation to warn of hazards that are present in a truck on the road, in a rail Continue Reading…

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

Continue Reading…

Can You Really Ship HazMat/DG Without Following the Regulations?

Can someone ship hazardous materials/dangerous goods without using regulatory publications?

This is often a question we ask ourselves when assisting customers. There are so many if’s, and’s, and but’s in the regulations, it’s hard to imagine someone shipping hazardous products without them. The regulations are just large instruction manuals on how to safely ship dangerous materials. We often have customers call and question why their shipment was rejected. After listening to their story, we can usually find the answer right in the regulations. When we tell a customer why their shipment may have been rejected, customers normally see why having a copy of the current regulations is so important. Every company shipping hazardous materials/dangerous goods should have all the regulatory manuals for the modes of transportation which they ship.

“That’s how we have always done it.”

This is something we hear very often, actually.

Just because that’s how you have always done it doesn’t mean it is compliant. The regulations are updated often for a reason – to ensure safety for everyone involved with shipping hazardous materials/dangerous goods. Recently, many of the regulations have been updated to include new UN numbers. The new shipping names and UN numbers will affect the way that companies label and document these products. This could easily become a scenario where “we’ve always done it this way” may lead to penalties or fines.

“These books Continue Reading…

Department of Transportation Logo
Transition Period for Two US Labels Coming to an End

On July 20, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published Final Rule HM-218F, bringing changes to the 49 CFR Hazardous Materials Regulations (HMR). Most of the amendments that were adopted in the final rule were intended to eliminate, revise, clarify or relax regulatory requirements. Two hazard class labels were revised in the final rule and were given a transition period for compliance until October 1, 2014.

Class 6 Label Changes

Class-6-Transition-Period-for-Two-US-Labels-Coming-to-an-End

Removal of CDC information on the class 6 infectious label

Prior to HM-218F, labels for Class 6 Infectious Substances were required by the HMR to include references to the Centers for Disease Control (CDC). The final rule removed the previously required statement “In U.S.A. Notify Director—CDC, Atlanta, GA 1–800–232–0124” from the label text. As of October 1, 2014, the statement must not appear on the Infectious Substances label.

Class 9 Label Changes

Class-9-Transition-Period-for-Two-US-Labels-Coming-to-an-End

Removal of horizontal line on the class 9 miscellaneous label

In 49 CFR, the Class 9 label was different from international regulations by including a thin, horizontal line running across the label at its midpoint. This led to some shipments being delayed or having to be relabeled by international carriers because there was no line required in the international standards such as the International Civil Aviation Organization (ICAO) Technical Instructions and the International Maritime Dangerous Good (IMDG) Code. HM-215F removed the requirement for the line on the Continue Reading…

Ebola Outbreak Puts Stress on Shippers of Infectious Substances

The headlines are frightening – Ebola virus, one of the most deadly viruses known, has broken out in several African countries. Medical authorities are concerned that it could spread beyond that region, carried by travellers all over the world. Laboratories in North America and Europe are on alert for patients showing suspicious symptoms. This, in turn, means that samples and specimens must be transported for testing and verification. How can the medical community deal with transportation of such high-risk materials?

Shipping biological substances training »

Ebola virus is considered a “hemorrhagic fever,” which affects the blood system. Its virulence is astonishing, with a fatality rate of between 50 and 90 percent. Combine this with the ability to be transmitted through casual contact, and the lack of specific vaccines or treatment, and it’s understandable why Ebola is such a feared disease. Therefore, it is all the more essential that transporters make sure that they comply with all legal and safety requirements.

Ebola virus is one of the few pathogens that is always classed as a Category A infectious substance, even in its uncultured form. The shipping description will be:

  • Identification number – UN2814
  • Shipping name – Infectious substance, affecting humans
  • Class – 6.2 (Infectious substances)
  • Packing group – Class 6.2 is not assigned packing groups

Procedures for shipping samples suspected of containing the virus will depend upon the regulations involved – the Hazardous Materials Regulations (HMR) for Continue Reading…

PHMSA Issues NPRM HM-215M for Harmonization with International Standards

The U.S. Department of Transportation (DOT) has been committed to ensuring that the domestic Hazardous Materials Regulations (HMR) are kept current with international standards. Since these standards are updated at the United Nations (UN) level every two years, this requires frequent amendments. The latest round of amendments has been started with the issue of a Notice of Proposed Rulemaking (NPRM) on August 25.

The NPRM has been issued by DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) as Docket Nos. PHMSA-2013-0260, HM-215M. It contains revisions necessary for harmonization with the UN Recommendations on the Transport of Dangerous Goods, the ICAO Technical Instructions for Safe Transport of Dangerous Goods by Air, and the International Maritime Dangerous Goods Code (IMDG). The comment period is until October 24, 2014. PHMSA’s goal is to ensure harmonization with the above regulations for the 2015-2016 biennium.

You can follow the links at the bottom of this article to read the proposed rulemaking or comment on it at the Federal Rulemaking Portal.

Shipping Hazardous Materials by Ground in the USA certification »

The extensive docket is about 90 pages long, and covers a number of areas for change.

HMR Significant Updates HM-215M:

  • Marine pollutants – the NPRM would exempt packages of small packages of marine pollutants (up to 5 Liters or 5 kilograms) from the HMR, due to the low risk for these goods in transport. Also, Chlorotoluenes will Continue Reading…
Reverse Logistics: When the Shipper Becomes the Receiver

PHMSA is submitting a Notice of Proposed Rule-Making (NPRM) to revise the Hazardous Materials Regulations applicable to return shipments of certain hazardous materials. By creating an exception from existing regulations for certain reverse logistics shipments, this NPRM offers opportunities for reduced compliance costs among hazmat shippers and carriers, without sacrificing safety. PHSMA proposes to establish a new section in the regulations to provide an exception for materials that are transported in a manner that meets the definition of “reverse logistics.”

The proposed definition of Reverse Logistics is:

… the process of moving goods from their final destination for the purpose of capturing value, recall, replacement, proper disposal, or similar reasons.

In addition to defining reverse logistics PHMSA is also trying to:

  • Establish regulations for the shipment of hazardous material in the reverse logistics supply chain
  • Establish clear applicability to the training requirements associated with “reverse logistics” shipments
  • Provide authorized packaging for reverse logistics shipments
  • Establish segregation requirements for reverse logistics shipments
  • Allow more flexibility for the transportation of lead acid batteries to recycling facilities

When goods are transferred from a manufacturer to a user, we call this downstream. Many hands change in-between before it lands in your own hands.  For example, Paint is manufactured at a plant, sent to a store, where it is purchased and often used by you-the downstream user. Careful thought and vast amounts of resources and dollars are set in motion Continue Reading…

DOT Issues NPRM for Crude Oil and Flammable Materials in Rail Cars

The U.S. Department of Transportation released the details of its comprehensive rule making proposal to improve the safe transportation of large quantities of flammable materials by
rail — particularly crude oil and ethanol — in the form of a Notice of Proposed Rulemaking (NPRM).

The NPRM proposes enhanced tank car standards, a classification and testing program for mined gases and liquids and new operational requirements for high-hazard flammable trains (HHFT) that include braking controls and speed restrictions.

Specifically, within two years, it proposes the phase out of the use of older DOT 111 tank cars for the shipment of packing group I flammable liquids, including most Bakken crude oil, unless the tank cars are retrofitted to comply with new tank car design standards.

These changes stem from the apparent volatile nature of oil coming out of the Bakken Formation in Western North Dakota. The crude is thought to contain high levels of methane and propane that make the oil more flammable than originally classified. The various amounts of gases included in crude oils varies, which makes it difficult to classify individual loads in rail cars. Following accidents in Quebec, North Dakota, and other states involving Bakken crude shipments, the DOT has singled it out as particularly dangerous, paving the way to change classification rules, alter tank car specifications and requirements, and shipping logistics involving crude oil from that region.

The changes Continue Reading…