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 Continue Reading…
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:
- The List of Dangerous Goods has new entries and/or updates to existing substances
- Packing Instructions for Lithium Batteries was updated to include not only a change but also a new addition
- Section 7 – Marking and Labeling for Limited Quantities has new information
Which way do I go, George?
John Steinbeck’s novella “Of Mice and Men” is often a required reading for many school children. Though published in 1937 about a story of migrant workers in the Great Depression, it has many themes that are still powerful today. What many don’t know is that one of Steinbeck’s characters from this story is parodied in a classic Looney Tunes cartoon.
Of Fox and Hounds
In this cartoon, Willoughby the dog is fooled by George the fox. Willoughby is voiced by Tex Avery, while George’s voice is done by Mel Blanc.
Now what does this have to do with Safety Data Sheets or SDS? Often when tasked with writing a SDS one can feel like poor Willoughby. All of the information is available, but which way do you go. Which way do you go?
ICC Compliance Center can help and it won’t be in the way of George in the cartoon. We offer five different SDS Services.
But how do I choose which is right for me?
- SDS Creation: The process is simple. Send us a basic product information sheet, the raw materials SDS documents, and the countries involved and we can write an SDS for you that meets the requirements of OSHA HazCom 2012, WHMIS, European REACH, or European CLP. We even offer to sign a non-disclosure agreement to keep your product information private.
- SDS Reformats and Revisions: Most companies already Continue Reading…
Have You Made Your TDG Updates Yet?
The holiday rush for 2014 is over. Our parties have been held, and our gifts are unwrapped and appreciated. But if you’re a dangerous goods shipper or carrier, you can’t relax just yet. New requirements from Transport Canada become mandatory, January 15, 2015. So, it’s time to make sure that everything in in compliance with the new system.
Back on July 2, 2014. Transport Canada issued two amendments to the Transportation of Dangerous Goods Regulations (TDG). One was called the Safety Mark Amendment, and the second was the Update of Standards Amendment. Both will have important effects on dangerous goods shipping procedures, and will need to be addressed immediately if you want your shipments to remain in compliance.
If your organization hasn’t already done so, it will need to review these amendments and make all necessary changes as soon as possible. Here are some of the most critical changes:
- Non-bulk packaging must now be selected for ground shipment using a standard published by Transport Canada, called Transport Canada Standard TP14850E, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and, 9, a Transport Canada Standard.” Note that this is available as a free download from the Transport Canada site at http://www.tc.gc.ca/publications/en/tp14850/pdf/hr/tp14850e.pdf
- Consignors of dangerous goods must keep on file a “proof of classification” for all dangerous goods they offer Continue Reading…
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.
As the start of a new year approaches, it’s time for parties, resolutions – and to check our dangerous goods/hazmat procedures, and see what’s changing. If you are a shipper of non-bulk packagings, one thing to watch out for is the new size limit for identification numbers that will be introduced in many regulations for 2014.
Identification numbers (which cover UN numbers, NA numbers and ID numbers) are the main way for packages to be identified as to their contents, in a format that does not depend on language. In the past, incidents have occurred because these numbers were marked on dangerous goods packages, but were not large enough to be seen easily. Therefore, the United Nations has, in the UN Recommendations for Dangerous Goods, established minimum size requirements.
The size minimums are:
- For packages with a capacity of 5 Litres or net mass of 5 kilograms or less, the size should be “an appropriate size,” based on the size of the container.
- For packages containing more than 5 Litres or kilograms, up to a maximum capacity of 30 Litres or net mass of 30 kilograms, the letters and numbers of the marking must be at least 6 millimeters (1/4 inch) tall.
- For packages exceeding 30 Litres capacity, or 30 kilograms net mass, the letters and numbers of the marking must be at least 12 millimeters (1/2 inch) tall.
These size minimums will Continue Reading…
The Alberta government has issued Industrial Railway Circular No. 1 (Guideline for the Transfer of Dangerous Goods to or from a Railway Vehicle).
Although only a 7 page document, there are 11 sections:
- Notification/site selection
- Primary selection criteria
- Additional selection criteria
- Regulatory requirements
The guideline falls under the Railway (Alberta) Act and applies to companies that intend to transfer dangerous goods to or from a railway vehicle. This circular does not apply to Class 1 Explosives. These must be handled under the Federal Handling of Carloads of Explosives on Railway Trackage Regulations.
Railways that intend to construct or connect railway track to a service provider or construct railway works must have approval from the provincial government. Site selection is done in accordance with sections 4 and 5, and if the criteria cannot be met, the application may still be considered if an equivalent level of safety can be demonstrated.
The guideline suggests a dangerous goods transfer track/rack should meet minimum distances from residences, commercial establishments, schools, hospitals, recreation centres, etc..
Dangerous Goods Class
|3 excluding inhalation hazard materials
|4.1 molten sulphur
|5.1 excluding inhalation hazard materials
|6.1 excluding inhalation hazard materials
In addition, the site shall not be located next to busy highways, under a bridge or overpass, next to transformers, power lines, sources of ignition, etc.. The site shall be located so that emergency responders can access it as well as be Continue Reading…
One of the conundrums of the Transportation of Dangerous Goods Regulations (TDG) is the requirement to have an ERAP for a UN number that is not listed in Schedule 1 of TDG.
The problem we run into is that Schedule 1 is only up to the 11th Edition of the UN Recommendations on the Safe Transport of Dangerous Goods (model regulations). In section 1.3.1, item 39 in the table of standards indicates that TDG is at the 14th Edition of the model regulations. But since the 13th Edition of the model regulations, the UN has issued over 130 new classifications.
But section 1.10 of TDG states:
A person may use the appropriate classification set out in the ICAO Technical Instructions, the IMDG Code or the UN Recommendations to transport dangerous goods within Canada by a road vehicle, a railway vehicle or a ship on a domestic voyage if these Regulations or the document from which the classification is taken does not forbid their transport.
This means that if the consignor cannot find a classification in TDG, then the consignor can use a classification from the model regulations, ICAO Technical Instructions (TIs) or the IMDG Code. And this is where the conundrum lies. TDG section 7.1(12) states:
Any substance that would require an ERAP if its classification were determined in accordance with Part 2, Classification, requires an approved ERAP if its classification from the Continue Reading…
Online shopping – whether from large internet companies such as Amazon, to individual vendors on sites such as eBay – has grown, well, explosively, in the past few years. But with this growth has come a headache for shippers, receivers and regulators. How do you handle online purchases of product that may actually be classified as dangerous goods (or, in the US, as hazardous materials)?
Often, people are not aware that common consumer products may be considered hazardous for transportation. These include:
- Aerosol sprays
- Cosmetics, such as nail polish remover or perfumes
- Flammable liquids, such as paints and adhesives
- Smoke detectors containing radioactive sources
- Refrigerants (including those in equipment)
- Fire extinguishers
- Goods with internal combustion engines
- Lithium batteries, including batteries packed in or with electronic equipment
There are, of course, provisions in various regulations such as the US Hazardous Materials Regulations of 49 CFR (Title 49 of the Code of Federal Regulations), and Canada’s Transportation of Dangerous Goods (TDG) Regulations. Small packages of dangerous goods can often be shipped more easily under the provisions for Limited Quantities or Consumer Commodities. These provisions, however, do vary from country to country.
In addition, the regulations for shipment by air are much more stringent. Shipments by carriers who specialize in fast delivery may need to comply with the system for air transportation from ICAO (International Civil Aviation Organization), and IATA (International Air Transport Association). These may require additional packaging, labeling Continue Reading…
When shipping limited quantities (LQ), you do not need to use a UN specification package. But what specs should the package you want to use meet? IATA section 2.7.6 states that the shipper must do a series of drop tests and a 24 hour stacking load test before using the package. Does this then mean that the shipper is done?
Section 220.127.116.11 states that 5.0.2 through 5.0.4 must be met, except for 18.104.22.168, 22.214.171.124, 126.96.36.199(f), 188.8.131.52.(g) and 184.108.40.206.2. Section 5.0.2 is the general packing requirements. The performance test requirements for a package, also known as UN specification packaging, section 220.127.116.11 does not apply as well as 18.104.22.168. After reading these sections, does this mean the shipper can use their package? Not quite, there is another section to read – 22.214.171.124. Here it states that the outer packaging must meet the construction requirements of section 6.2. For combination packages, the most used outer packaging is the fibreboard box. In section 6.2.12, it states that the box must be subjected to the Cobb test. This is a test to determine the water absorbency of the fibreboard box, where the increase in weight cannot exceed 155 g/m2.
Are shippers aware of this requirement? And how are they to determine this when selecting a packaging to use? It might just be easier to use a UN specification package and send the shipment Continue Reading…