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Hazmat Packaging Bears Rigorous Testing

Hazmat Packaging Specs

Shippers of Hazardous Materials (or Dangerous Goods) know that the packaging they use has to meet certain specifications and pass standard tests before it can be considered appropriate for the hazardous shipment. Most training classes will explain that the package design must go through various tests to simulate conditions they may encounter during transport.

I started to wonder if users of the packaging really understand the conditions these designs are put through. No, it doesn’t look like this…

… but a few of the tests are quite rigorous! Below are some examples.

  • Drop Test – Drop testing is done on five test samples. The samples are prepared as they are intended to be used by a shipper. Each sample is dropped on a different surface of the package (top, bottom, long side, short side, and corner) from a height between 2.9 and 5.9 feet (0.8 – 1.8 meters), depending on the packing group of the materials that are going to be authorized. Any release of sample material during any of the drops is considered a failure.
  • Stack Test – Stack testing is done on three test samples. The samples are subjected to force that is equivalent to the weight of identical packages stacked to 3 meters. The samples must withstand the weight for 24 hours without leaking or showing any damage or distortion that could reduce its strength or cause instability in stacks during transportation.
  • Puncture Test (required for Category A Infectious Substances Packaging) – Puncture testing is done on two test samples. Depending on the gross weight of the samples, they are either dropped onto a steel cylindrical rod, or have a steel cylindrical rod (weighing at least 7 kg) dropped onto them. Any leakage from the primary receptacle is considered a failure.

These tests should be carried out by a qualified technician who follows proper protocols and methods. A polar bear is not required, but they sure do like to test the limits of plastic drums!


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*Special thanks to Luna, one of the resident polar bears at the Buffalo Zoo for demonstrating how not to test packaging. No polar bears were harmed in the making of this blog … but I can’t say the same for the drum.

tdg-reporting
Transport Canada Amends TDG Reporting Requirements

On June 1, 2016, Transport Canada issued an amendment to the “Transportation of Dangerous Goods Regulations” (TDG) under the Transportation of Dangerous Goods Act. This amendment substantially revises the requirements for reporting spills of dangerous goods during transportation. It also addresses changes to air shipment of lithium ion batteries and makes various minor corrections and changes. The “Reporting Requirements and International Restrictions on Lithium Batteries Amendment” reflects concerns that the previous requirements for reporting spills, called “accidental releases,” was inefficient and didn’t allow the reporting parties to evaluate the risk to the public when deciding if a release had to be reported.

Continue reading “Transport Canada Amends TDG Reporting Requirements”

Canada!
Transport Canada Issues Protective Direction 36

On April 28, 2016, Transport Canada issued its latest Protective Direction. This Direction, number 36, will replace a previous one, Protective Direction 32, with more detailed instructions for rail carriers.

Protective Directions are rules that are not included in Canada’s Transportation of Dangerous Goods Regulations (TDG). Instead, they are announced by Transport Canada, and are published on their website. Usually, these directives are used when Transport Canada believes it’s important to bring in a new rule quickly in order to protect the public. Since amending the regulations can take months or longer, Part 13 of TDG allows them to use this method to respond to important issues with appropriate speed.

Protective Direction 36 requires Canadian Class I rail carriers to either publish information on the carrier’s website, or provide information to designated Emergency Planning Officials (EPOs) of each jurisdiction through which the carrier transports dangerous goods. This information includes:

  • Aggregate information on the nature and volume of dangerous goods that the rail carrier transported by railway car through the last calendar year (broken down by quarter);
  • The number of unit trains loaded with dangerous goods operated in the jurisdiction in the last year (again, broken down by quarter); and
  • The percentage of railway cars carrying dangerous goods that were operated by the rail carrier through the jurisdiction in the last calendar year.

Rail carriers transporting dangerous goods by railway car in a province must, by March 15 of the following year, publish on its website a report in both official languages detailing the dangerous goods shipments, including the percentage of cars that were loaded with dangerous goods, the top ten dangerous goods carried, the percentage of these top ten goods as part of the dangerous goods transported in this province, and the percentage of all residual dangerous goods on the total dangerous goods transported in that province.

Further details are given in the Protective Direction about how the rail carrier must communicate with the designated Emergency Planning Official in each jurisdiction, and how they must provide information to the agency CANUTEC to improve communication during accidents.

Protective Direction 36 replaces the earlier Protective Direction 32, and takes effect on April 28, 2016, the day it was issued. The full text of the Direction can be found at http://www.tc.gc.ca/eng/tdg/safety-menu-1281.html.

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

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.

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.

N.O.S. – Not Otherwise Specified

3 Little Letters, 1 Short Phrase

The DG/HazMat world occasionally encounters confusion when there’s a need to refer to the “N.O.S.” aspect of a shipping name. The abbreviation is used in the proper shipping name of mixtures that have a potential variety of hazardous ingredients and/or don’t have a more specific, applicable name in the UN list.

The principal is that if the shipping name preceding the N.O.S. doesn’t contain sufficient details on the hazardous ingredient, then a technical name must be included in brackets following the N.O.S. as part of the proper shipping name. In some cases (i.e. US shipments) more than one technical name may need to be shown if there is more than one ingredient contributing to the hazard.

For example, in a mixture containing both ethanol and isopropanol (ethyl & isopropyl alcohols) along with other ingredients; in sufficient concentration to be classed as a flammable liquid; the proper shipping description would be “UN1993, Flammable Liquid, N.O.S. (ethanol)” internationally, and “UN1993, Flammable Liquid, N.O.S. (ethanol, isopropanol)” in the US.

Similarly UN numbers with a subsidiary class would also have to list the ingredient, if different, resulting in the subsidiary hazard.

The US convention is allowed by the phrasing of “at least the most hazardous” or similar wording in other modal/national regulations.

Technical Names

The term “technical name” is defined in the various regulations, but the common theme is that it cannot be a marketing tradename- it must be a name such as the chemical name or a similar name recognized in scientific or technical publications. This can lead to some interpretation issues since the line between acceptable industry technical publications and scientific practise can be blurred. Typically an abbreviation will not be acceptable just because it’s used in the literature, unless a recognized body officially adopts it.

An example is the antiseptic known commonly by the abbreviation PHMB, for polyhexamethylene biguanidine. PHMB is not likely to be accepted (based on at least 2 anecdotal reports to our helpdesk) whereas the common chemical name polyhexamethylene biguanidine is acceptable (and much easier to remember than the formal scientific name which would be twice as long!).

The exception to this rule is when the DG/Hazmat list recognizes an abbreviation or code as an entry- such as the “R” codes for refrigerants e.g. “REFRIGERANT GAS R 152a” for “1,1,-DIFLUOROETHANE” (UN1030).

Another area that is subject to less stringent nomenclature is infectious substances. Depending on the specific jurisdiction, Class 6.2 Category A or B designations; or generic microbiological descriptions (e.g. bacterial, viral, etc. sample) may be used.

Look for the Trigger

A common misconception is that a technical name is required whenever the list name ends in “N.O.S.”. This is not the case. There are about 320 or so listings that end in “N.O.S.”, however about 38 of these are considered to have sufficient detail in the name. An example is UN 1268: “PETROLEUM DISTILLATES, N.O.S.” or “PETROLEUM PRODUCTS, N.O.S.”. Apparently the regulators see little advantage in adding the specific product that results in it being flammable to the term “petroleum”. Similarly UN1477: “NITRATES, INORGANIC, N.O.S.” is a stand-alone proper shipping name. As long as the correct PG is given, it matters little which specific nitrate compound (e.g. potassium or sodium) is in the nitrate mixture.

How is one to know the trigger? Each set of regulations has either a symbol or “special provision” that requires the addition of technical names to the proper shipping name. In the US 49 CFR, it’s a letter “G” in column 1 of the 172.101 HazMat Table; in the Canadian TDGR it’s invoked by Special Provision 16 (SP 16) in Column 5 of Schedule 1; IATA DGR uses a “star” symbol after “n.o.s.” in the Part 4.2 DG list; while the IMDG Code uses Special Provision 274 in column 6 of Volume 2’s Part 3.2 DG list.

Caution Regarding TDGR Schedule 2- SP 16

In common with the other jurisdictions’ regulations, Canada’s TDGR SP 16 contains a provision for not disclosing the technical name of medicinal ingredients which are controlled substances WHEN THEY ARE SUBJECT TO a domestic or international prohibition on disclosure ( Presumably to make it harder for the “bad guys” to know which shipments have the “good stuff”!). Thus, this is not an automatic omission – only those covered by a specific regulation or agreement can omit the technical name.

A general caution regarding TDGR’s usually helpful practice of listing the “Applicable UN numbers”, potentially affected by that special provision, in italics at the end of each Schedule 2 special provision:

Remember that elements (like these listings) in italics are for INFORMATION ONLY, they are not part of the regulation. Due to the positioning of the information, some users who initially refer to SP 16 interpret the list of UN numbers as being those which do not require a technical name – this is NOT correct.

Rather it is a complete listing of the UN numbers which do invoke SP 16 in Schedule 1 – exemptions are only applicable if they meet the criteria in 16(2) or 16(3)’s non-italicized text.

… A variety of pitfalls.

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.

Traveling With Hazmat … What Will and Won’t Fly

As a frequent traveler, for both business and pleasure, I am often passing though airport security checkpoints before whisking off to my final destination. Because of the industry I am in, I always seem to notice things that most travelers don’t. Most passengers tend to know the rules regarding carry on liquids. They usually know that they need to take off shoes and remove laptops from bags before x-ray screening. While waiting in line, I start thinking about how many of them really understand how many hazardous materials we may be taking on vacation with us and that there are additional rules for carrying them on aircraft.

Traveling with HazMatDuring my most recent trip, I noticed a sign while in the queue for the security checkpoint at Phoenix Sky Harbor Airport. It seemed odd to me that they would choose to display this sign in a passenger area. While the information provided on the sign is accurate and useful, it is not appropriate for the audience it is reaching. Those passengers who actually stop to read the sign will likely think it does not apply to them because they are not traveling with packages as pictured. In my opinion, a more effective sign for this location would warn that lithium batteries that are used with personal electronics can start fires if they are dropped or improperly charged. Showing photos of laptops, cellphones, e-cigarettes, and spare batteries would be more applicable than labeled shipping cartons.

When checking in for a flight in the US, passengers must acknowledge that they are not carrying any hazardous materials in their luggage. The acknowledgement usually gives a few basic examples, but again I wonder if people really understand what they are saying. The FAA has a webpage (click here) that details all of the possible hazardous materials and which ones can go in check baggage, carry-on baggage, both, or not at all. As I was scrolling though the list, I realized that I had inadvertently violated the rules with one item that I keep in my toiletry bag … anti-static aerosol spray! I have long hair so I usually carry a travel size container of the spray with me to deal with flyaway hair due to excessive static. I had no idea it was on the forbidden list until I already the statement “Aerosol laundry products do not qualify for the toiletry article exception, so if they are flammable they are forbidden in carry-on and checked baggage.” It does not qualify as a toiletry item because it does not touch your body when you use it.

Thanks to my research for this blog, I learned something new today. I will now be going through my pre-packed toiletry bag to make sure I don’t have any other forbidden materials. I hope more people become aware of the items on the list and help to make travel a little bit safer for all of us! As the FAA says on their page … When in doubt, leave it out!

Save

Save

Chemical Safety and Back to School

Every year around this time a feeling of nostalgia gets me. As soon as the first sign about “back to school” shows up in a store or on TV, I am transported to my previous life. For over 10 years I taught high school science. Each year there were plans to make, supplies to buy, and students to meet. Thinking on it now from the perspective of a safety professional, it is amazing the chemical hazards present in an everyday school situation.

Being a science teacher it was easy to engage students in their own learning. Usually, all it took was setting up some demonstrations of some basic chemical reactions and everyone was read to go. A few of the more common ones were called Colored Fire, Sugar Snake, and Elephant’s Toothpaste. In each one of these, hazardous chemicals are used to make the reaction. For the Colored Fire, alcohol solutions of various metals are used. The Sugar Snake involves the use of concentrated sulfuric acid. In Elephant’s toothpaste a hydrogen peroxide solution is used. As a teacher you always had to model good safety habits including the proper personal protective equipment and keep students far enough away for the actual demonstration to be safe.

Colored Fire

Sugar Snake

Elephant’s Toothpaste

Elsewhere in the school building there were other hazardous chemicals. Consider the toner in the copy room. Also, the Custodial department uses strong chemicals on a daily basis to keep things clean. Throughout the year, the grounds crew handles hazardous chemicals so the campus will look good and be safe. For many schools there is also the garage and maintenance areas where buses are serviced which can involve hazardous materials. All of these locations must be made aware of the chemicals being handled and how to do so safely.

It begs the question – Are schools aware of HazCom 2012? Have the staff and faculty been trained to recognize the wider range of hazards? Have the locations that deal with hazardous materials been updated with more current safety data sheets. In doing some research on my own, I found organizations such as the National Science Teachers Association and the Chemical Safety Board have released various messages calling attention to the new regulation and offering resources to help with safety inside the school setting.

While the school systems juggle so many things at the start of a school year, the safety of their teachers, faculty and most importantly students should never be compromised. Be sure to contact ICC Compliance Center for the best options for labeling the hazardous chemicals in your school.

TDG
Know Your Exemptions – the 500 Kilogram Exemption (TDG Section 1.16)

Like most regulations based on the UN Recommendations for the Transport of Dangerous Goods, Canada’s “Transportation of Dangerous Goods Regulations” (TDG) includes a number of exemptions. These provide easier and more cost-effective ways for shipping low-risk materials. However, each exemption needs to be carefully studied. If you don’t comply with all the requirements, you are not entitled to any part of the exemption.

One of the most misunderstood exemptions in TDG is found in section 1.16, the “500 Kilogram Exemption.” The provisions in this section originated in a long-ago series of permits intended to make shipment of small quantities of dangerous goods easier. Over the years, changes to this section have reduced its effectiveness; it still may be a helpful exemption in certain specific cases, but it must be used appropriately.

The first myth about the 500 kilogram exemption is that it is a total exemption from all requirements of TDG. This is far from the truth. At best, the exemption relieves the shipper from Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks) and Part 5 (Means of Containment). All other requirements of TDG will still apply. This includes, for example, the requirement that the carrier and all handlers must be TDG-certified. At one point, receivers were exempted from Part 6, Training, but this relief was removed in an amendment several years ago.

Obviously, the exemption only applies if the total of all dangerous goods on board does not exceed 500 kilograms. Although section 1.16 itself does not mention it directly, Transport Canada has reportedly interpreted that this quantity would include limited quantities under section 1.17, and other exempted goods. So, if you have 300 kilograms of regulated material, and 400 kilograms of limited quantities on board, you could not use this exemption.

Package size is restricted to no more than 30 kilograms for classes other than class 2. Packaging for liquids and solids does not have to be UN specification, but containers of gases must meet the standards set out in Part 5, Means of Containment. Non-specification packaging must be designed, constructed, filled, closed, secured, and maintained so that it will not leak during normal conditions of transport.

Once we check the total weight of shipment, and the weight of the individual packages, we can move on to hazard communication. The packages themselves must be marked and labelled as regular dangerous goods as per Part 4; however, they may alternatively display the labels required by regulations under either the Hazardous Products Act or the Pest Control Product Act. This would allow packages not to show TDG marks and labels if a WHMIS label or a “Pest Control Product Regulation” label can be seen on the outside.

Note that when this section was first written, labels for hazardous consumer products would also be acceptable, since the “Consumer Chemicals and Containers Regulations” (CCCR 2001) came under the Hazardous Products Act. However, the CCCR 2001 was afterwards moved to the Canada Consumer Product Safety Act. Transport Canada has never updated section 1.16 to address this, so consumer labels should not be used as a way of satisfying section 1.16.

Next we come to shipping document requirements. Here’s where the exemption still gives some useful relief; instead of a normal shipping document, with its many requirements, the shipping paper under the 500 kilogram exemption merely needs to include the class of dangerous goods, and the number of means of containment for that class. The wording for this is given specifically as “Class X, number of means of containment Y.” The regulation gives an example of a shipment with ten packages of Class 3, and twelve packages of Class 8, as follows:

    Class 3, number of means of containment, 10
    Class 8, number of means of containment, 12

Other requirements, such as total weight on board and the date of shipment, do not apply. This makes it useful, for example, for goods such as work supplies that are kept permanently on a vehicle, but do not qualify for other exemptions. The document can be written up for the standard quantity of supplies, and left in the vehicle permanently.

Since the shipment is exempted from all of Part 4, Dangerous Goods Safety Marks, placards are not required, even if the load contains goods that would require placarding for any amount.

Not all types of dangerous goods can be transported under this exemption. Section 1.16(2) lists various classes of goods which cannot use this exemption. This includes most explosives (except for those in Class 1.4S), radioactives, infectious substances, toxic gases and liquid toxic materials in Packing Group I, Class 4.2 or 4.3 materials in Packing Group I, Class 2.1 gases if in cylinders exceeding 46 Litres, and Class 5.2 materials that are not allowed to be transported as limited quantities. Also, any material that requires an Emergency Response Assistance Plan (ERAP) or which requires control and emergency temperatures cannot be shipped under these provisions.

To sum up, this is an oddly specific set of conditions for an exemption, which can probably be traced back to its origin as a permit designed for a specific situation. Furthermore, some of the benefits of using it have been removed over time. But if you’re looking for a way, for example, to put several 20 Litre pails of paint in a vehicle, this would remove the requirement for you to use UN specification packaging, or to complete a full shipping document. You wouldn’t even need to put TDG labels on the pails, if they displayed WHMIS labels. For some shippers, these benefits still make section 1.16 worth using.

Remember, of course, that simply because your shipment totals less than 500 kilograms, you do not have to use these provisions; like most exemptions, section 1.16 is optional.


Do you have any questions about this or other exemptions in the TDG Regulations? Contact ICC Compliance Center here at 888-442-9628 (U.S.) or 888-977-4834 (Canada), and ask for one of our regulatory specialists. We can help you find the easiest and most efficient method to ship your goods.