ICC Compliance Center constantly evaluates our courses to be sure they are the most up-to-date with current versions of the regulations. Our Regulatory Team works hard to make sure the information we get you is complete and correct. In that regard, I am in the process of revising and updating our course on shipping reduced amounts of materials. It will focus on the options outlined in the US 49 CFR and the IATA regulation. We are talking about a focused course on the topics of small quantities, excepted quantities, limited quantities and consumer commodities.
During the course of the update, I came across an odd word in regards to drums under the Excepted Quantities exception. It was one not familiar to me at all even after 10 years of being in the “business.” Of course, my first thought was to look in the definitions or glossary section of the regulations. It wasn’t there. Then I tried to Google it. No luck. At this point, it was time to reach out to the Team. Sure enough, within minutes there was the answer and even where I could find it for future reference.
What was the word? It was the word “chime.” In both 49 CFR and IATA for Excepted Quantities is the package test requirement that must be met for drums. It says that when the package is in the shape of Continue Reading…
Or: “When I use a word,” Humpty Dumpty said, … “it means just what I choose it to mean …”
Lewis Carrol “Through the Looking Glass” in Bartleby’s “A Dictionary of Quotations”:
Health Canada provided an FAQ presentation at a recent CIC (Current Issues Committee) meeting that may provide a useful lead in to the more detailed Guidance document published in December 2016.
The latter, “Technical Guidance on the Requirements of the Hazardous Products Act & Hazardous Products Regulations – WHMIS 2015 Supplier Requirements”, provides (at 540 pages) a detailed review of the content of the law and various aspects of guidance/interpretation. This document is available for download at:
The length of the document may be daunting to the casual user, so the FAQ presentation attempts to present Health Canada’s position on items that are of current concern.
The CIC is a multi-representative committee that meets several times a year to review, as it’s name implies, issues that can be improved to increase the effectiveness of WHMIS in helping to protect workers. Currently there are representatives from various government levels (Federal/Provincial/Territorial), Health & Safety organizations (e.g. CCOHS), industry organizations (e.g. RDC, CIAC, etc.) and Labour (CLC, Unifor, etc.).
One of the current issues being addressed is to form sub-committees that may streamline the effectiveness of the committee in considering jurisdictional issues; in addition to establishing a working group to look at Continue Reading…
Terminology in Regulatory Manuals
Language, as defined by the Merriam-Webster dictionary, is the formal system of words or signs that people use to express thoughts and feelings. Learning a new language is often a complex undertaking. It is also a time that lends itself to funny stories. While living in Austria for a few years taking German lessons was part of our visa process. We were encouraged to practice often. On one of my first attempts was to buy a certain pretzel. Somehow my request came out as asking for the “slow one” rather than the “long one”. My husband told a co-worker he “believed” he was a pencil. While neither request caused harm, it was confusing to the German speakers who heard us. I mention this because the language of transport regulations can be confusing as well until you have a good handle on the language used in them.
Let’s take a look at two simple words. We will compare their “everyday” usage with how they are used for transporting hazardous materials or dangerous goods. The two words will be “should” and “may”.
Word #1: Should
In normal usage, this word indicates certain obligations or expectations. Take for example the statement, “John should be ready by now.” By using the word “should” in the sentence, the expectation is that John is ready or prepared for whatever situation he finds himself. In Continue Reading…
Transport Canada has posted a consultation document on their website for Amendment 9. This proposed amendment will deal with:
- Changes to 1.3.1: updating the standards for items 10, 12, 22 and 34.
- Item 10 will now reference CGSB-43.126-2008
- Item 12 will reference CGSB-43.147-2005 as amended in 2008
- Items 22 and 34 reference the ICAO Technical Instruction and Supplement for the 2009-2010 Edition
- Section 11.4: the definitions for ICAO Technical Instructions and the Supplement are updated
- A new section 5.9: this deals with CGSB-43.147 where paragraph 4.11.3c does not apply. This paragraph deals with the registration of tank car test facilities.
- Section 5.12(1): this is a housekeeping change—it skips section 18 of CGSB-43.150.
- Section 5.12(2): again, this is a housekeeping change that pertains to steel or plastic drums needing to be reconditioned, remanufactured or repaired. These steps must be done at a Transport Canada registered facility.
If you have comments for Transport Canada on this amendment, please forward them to:
Director, Legislation and Regulations