Regulatory Helpdesk: November 20, 2017

Top 5 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.

Overpacks

Q. My shipment was refused even though I followed what the regulations and my training said for shipping an overpack. My drums were on a pallet and shrink wrapped. All of the information on the drums could be seen. I placed a sticker with the words “Overpack Used” on the shrink wrap and listed it that way on my paperwork. Can you tell me why my carrier refused it?

A. Per Section 7.1.7 the actual wording that must be used on your pallet is just the word “overpack”. It seems confusing to have different terminology used but that is how the regulations work and why you should be trained every 2 years for IATA.

Using Combustible Liquid, N.O.S. (USA)

Q. Since this product meets the combustible definition, can we use ‘NA1993 Combustible Liquids, n.o.s.’ to ship to Canada or does Canada only recognize the ‘UN1993 Flammable Liquids, n.o.s.’?

A. Basically, to me, she is asking what is the difference between NA1993 and UN1993 and how it impacts transporting into Canada. NA1993 is a US only identification number. It is used for transporting combustible liquids in the US.  Technically, a combustible liquid is NOT Continue Reading…

OSHA
New OSHA Concentration Range FAQ

Validation

Oprah Winfrey once said, “I’ve talked to nearly 30,000 people on this show, and all 30,000 had one thing in common. They all wanted validation.” Validation is receiving feedback from others that what you do and say matters. It is an acknowledgment of your actions, deeds and accomplishments. To be a healthy person we need to receive positive validation and be able to give it to ourselves. So is it possible for a company to receive validation? I believe so and here’s why.

In one of OSHA’s recent Frequently Asked Questions (FAQ’s) postings a question regarding the use of ranges on Safety Data Sheets was added. To see the full FAQ and the answer, please click here. The specific question asked is: When may chemical manufactures/importers use concentration ranges rather than an exact percentage composition in Section 3 of the SDS, and how does this apply to trade secrets? Let’s take a closer look at OSHA’s answer. There are several parts to it and each deserves some attention.

Part 1 – Exact Percentage versus Concentration Range Clarification

The answer starts by clarifying the language used in Appendix D under Section 3. In the actual Appendix it states, “The chemical name and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards” must be disclosed in Section 3. However, in the FAQ answer the statement reads as “the chemical Continue Reading…

ICC Attends 33rd Annual DGAC Conference

This week, ICC attended the 33rd Annual Conference and Exposition of the Dangerous Goods Advisory Committee (DGAC), one of the largest trade associations for organizations involved in dangerous goods. The conference, which was held in Tampa, Florida, was well attended by shippers and carriers, as well as companies providing services such as emergency response. ICC’s own Karrie Monette-Ishmael and Barbara Foster were among the exhibitors showing their latest products and services.

The program started with a keynote address from Tim Butters, the Deputy Administrator of the Pipeline and Hazardous Materials Safety Administration (PHMSA). He described how PHMSA was “trying to reopen lines of communication with industry,” that may have been damaged in recent years, and discussed some of their important work on safety and security.

The program itself provided many informative and challenging sessions. Workshops gave a hands-on look at such diverse topics as writing closure instructions for packaging, and compatibility issues between chemicals and packaging. Regulators from North America and Europe gave overviews of issues and upcoming changes to the UN Recommendations on the Transport of Dangerous Goods, the Hazardous Materials Regulations of 49 CFR, and other related regulations. Speakers from industry were present to give insight into topics such as classification of environmentally hazardous substances. The ever-problematic issue of lithium batteries was addressed by Bob Richard, former Deputy Administrator of PHMSA and now with Labelmaster Services.

A Continue Reading…