ICC's Regulatory Helpdesk
Regulatory Helpdesk: Sept 24

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Limited Quantity from Canada to the USA

Q: I ship my material as a limited quantity under TDG in Canada. What do I need to do to ship it to customers in the US? We are also considering opening a hub in the US.
A: You will have to receive training in 49 CFR. Even though there are many similarities between the 2 regulations they are not exact matches. You may be able to use some reciprocity agreements in regards to transborder shipments. A hub based in the US will definitely have to have 49 CFR training.

New testing, now what?

Q: We just ran some testing on one of our products. It has been shipped as UN2468 in the past. However, the test report O.1 came back and said our material is not an oxidizer. What does that mean for the next time we ship the product?
A: If you have proof that your product is no longer a hazardous material, then you do not have to ship it as such. It does not meet the classification criteria set out in 49 CFR starting in §173.50.

TDG wallet card requirements

Q: I have worked with a courier company for Continue Reading…
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 Continue Reading…

DOT Provides Guidance on Marine Pollutants

Identifying environmental hazards is an important part of the current transportation of hazardous materials system. However, changes that have originated in the UN Recommendations for the Transport of Dangerous Goods (the so-called “Orange Book”) are making classification of such hazards more complex than it used to be. Fortunately, the US Department of Transport (DOT) has issued a short guide that will help those who deal with such chemicals, called Marine Pollutants, in the United States work their way through the system a little easier.

Environmentally hazardous substance marking

Originally, the concept of Marine Pollutants was developed to deal with chemicals that could cause significant damage if released into the ocean. A list of such chemicals was developed, based on Annex III of the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 (MARPOL 73/78). Classification depended on whether or not the chemical was identified on this list, or if a substance contained ingredients on the list, above a certain concentration cut-off. While this was a relatively straightforward way of classifying well-known chemicals, it did not fully address how chemicals should be classified if information was discovered about hazards after the list had been established – added or deleting chemicals from the list required extensive work at the international level. With more environmental data being developed all the time, a new method was called Continue Reading…

Gasoline mixtures

Transport Canada has posted a Bulletin to their website on ethanol and gasoline mixtures.

For shippers, the classifications to be used are as follows:

  • for mixtures up to 10% ethanol (E10): gasoline, UN1203
  • more than 10% but less than 100% (> E10 < E100); ethanol and gasoline mixture, UN3475
  • 100% ethanol (E100): ethanol or ethyl alcohol, UN1170

Ethanol and gasoline mixtures must not be classified as:

  • UN1987, ALCOLHOLS, N.O.S.,

For emergency responders, the different blends mean different responses in the event of fire. For mixtures up to E10 (UN1203), emergency responders can use the aqueous film forming foam (AFFF) that is usually used to combat gasoline fires.

However, for mixtures in excess of E10 (UN3475 and UN1170), the use of AFFF is virtually useless as these mixtures are polar/water-miscible flammable liquids that degrade the AFFF. Emergency responders should be using AF-AFFF (alcohol resistant, aqueous film-forming foam).

View the complete Bulletin on Transport Canada’s website.