Explosives
Explosives Consultation – Ports & Other Proposals

Recognizing Technological Evolution while Maintaining Safety & Security

Explosives Regulations (ER) – Ports & Wharves

The Explosives Safety & Security Branch (ESSB) of Natural Resources Canada, and Transport Canada, have issued a Gazette I (CG I) proposal to amend their respective Explosives Regulations (ER, under the Explosives Act), and the Cargo Fumigation and Tackle Regulations (CFTR, under the Canada Shipping Act).

The initial reason for the proposed amendment is to remove reference to the express requirement to use quantity/distance principle (QDP) restrictions and ESSB Inspectors from the CFTR. A more modern approach of quantitative risk assessments (QRA), based on actual probable hazards following, methodology authorized by the ESSB (Chief Inspector of Explosives), would replace the more rigid QDP.

QDP, currently covered in CAN/BNQ 2910-510/2015, were established mainly for fixed manufacturing/storage facilities and specifically exclude transportation activities from the scope of the standard.

The proposal also provides for having qualified individuals, not just ESSB Inspectors, determine the risk following an approved QRA methodology. The requirements will appear in a new ER section 203.1 instead of the current CFTR section 155(2) & (3).

It is expected that international trade and commerce will be improved without sacrificing safety or security under this proposal.

Explosives – Other Amendments

The CG I amendment proposes to also include ER changes under the topics of:

  1. Eliminating or relaxing license requirements for certain “low risk” explosives (7 components);
  2. Clarification of wording (13 components); and
  3. Increasing Continue Reading…
Skull and Cross Bones
Inhalation Hazards – TDG Marking & Documentation

Man Wearing Respirator

Changes in Special Provision 23

One aspect of the International Harmonization amendment (SOR/2017-137) of the Canadian Transportation of Dangerous Goods Regulations (TDGR) that did not receive a lot of attention is the change in Special Provision 23. This special provision (SP) deals with the assignment of markings on containers and descriptions on shipping documents for entries related to goods which exhibit inhalation toxicity. Although the basic concept for classification remains the same- i.e. gases in Class 2.3 and Class 6.1 with associated inhalation toxicity. The majority of the latter are in PG I, but there are several PG II entries invoking SP23).

Marking – Keep It Simple?

A significant difference is the change in wording applied to means of containment (MoC). Following the transition period, markings required under SP23 must read “inhalation hazard” for all entries except UN 1005 (anhydrous ammonia). This eliminates the previous options of either “toxic by inhalation” or “toxic-inhalation hazard” (TBI or TIH).

UN1005 retains the previous wording “Anhydrous Ammonia, Inhalation Hazard” when the option of using the ammonia placard (rather than Class 2.3) is chosen. However small MoC of UN1005 will use the standard Class 2.3 label and “inhalation hazard” wording.

Size Matters

Letter Size
The new SP23 simplifies things somewhat by referencing the specific sections of Part 4 that apply- i.e. 4.18.2 for UN1005 and 4.23 for the rest. These sections include specifications for the height and Continue Reading…

A Reminder – US Shipping Description Changes Becoming Mandatory for 2013

We’ve turned our clocks backwards, started our holiday preparations, and maybe even bought new calendars for 2013. But there’s one other thing that should be on our minds for the New Year, at least for shippers in the United States. We must make sure that our shipping descriptions are in order.

In 2006, a Final Rule, Docket No. PHMSA–06–25476, known as HM-215I, was issued by the Pipelines and Hazardous Materials Safety Administration (PHMSA). The goal of this rule was to bring the US Hazardous Materials Regulations (HMR) of Title 49 of the Code of Federal Regulations (49 CFR) into line with the current UN Recommendations for Transport of Dangerous Goods. One major change was that the shipping description order, as described in 49 CFR section 172.202(a), would be rearranged to reflect the international standard.

Originally, the shipping description order was prescribed as:

  • Shipping name, hazard class, identification number and packing group (if applicable)

However, HM-215I changed this order to:

  • Identification number, shipping name, hazard class, and packing group (if applicable)

PHMSA recognized that making this change would take some time, and granted a six-year transition period. After all, making this change would include retraining workers who prepare or read shipping papers, reprogramming computerized document systems, and rewriting standard operating procedures regarding shipping papers. However, the transition period is reaching its end. Starting on January 1, 2013, shipping papers must be in the “identification Continue Reading…