Environmental Update
EPA e-Manifests Open to Waste Generators

Using computer near truck

Are You Ready for e-Manifests?

Paperwork – it’s one of the worst parts of dealing with hazardous waste shipments. In both Canada and the United States, hazardous wastes require a special document, the Waste Manifest that will not only serve as the transportation document for the dangerous goods/hazardous materials transportation regulations, but also allow environmental authorities to track the waste from the generator, who sends it for disposal, through the hands of the carrier, to the end receiver (in the US referred to as a TSDF, for Hazardous Waste Treatment, Storage and Disposal Facility).

In Canada, some jurisdictions have eased the burden by allowing the waste manifest to be created electronically. For example, in Ontario, the HWIN system has been used for years. However, until now, the United States has not had a system for electronic documentation, called e-Manifests. On June 30, 2018, that has changed.

The change has been a long time coming. Although the initial proposal by the Environmental Protection Agency (EPA) was made in 2001, it was not until 2012 that Congress passed the “Hazardous Waste Electronic Manifest Establishment Act.” Under the Act, a final rule was published in 2014 that approved the use of such manifests. Since then, the EPA has been working to create an online system that will allow the e-manifest to eliminate substantial chunks of the burden of manifests, as well as Continue Reading…

dangerous goods forms, IATA, IMDG, 49 CFR, TDG documentation
How to Document Weights on DG/HazMat Transport Paperwork

Dangerous goods and hazmat forms

IATA, IMO, 49 CFR, & TDG Documentation

No one wants to talk about their weight. Ever. In the world of transport though, you have no choice. You are required to list on your transport paperwork some sort of weight, mass, or volume. The trick is to know which regulation requires what. Should be the net weight or gross weight? Is it per package or per packaging? Sadly, depending on the regulation, the answers to those questions may differ.

Before getting started, be sure you understand what all of those terms mean. I tend to default to the IATA regulations when it comes to definitions. These are found in Appendix A. Take note that these terms are also defined in the other regulations, too. In 49 CFR check in §171.9. For IMDG they are in 2 places – Volume 1, Chapter 1.2 and Volume 2, Appendix B. TDG defines them Part 1.4.

Definitions:

Package
The complete product of the packing operation consisting of the packaging and the contents prepared for transport.
Packaging
A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.
Means of containment
(in TDG) a container or packaging or any part of a means of transport that is or may be used to contain goods.
Means of transport
(in TDG) a road or railway vehicle, aircraft, vessel, pipeline or any other contrivance that is or may be used Continue Reading…
Regulatory Helpdesk: February 19 & 26

Shipments to Puerto Rico, Non-hazardous substances, the Overpack label, and Aviation Regulated Liquids or Solids

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.

Shipping to Puerto Rico

Q.  If 49 CFR is used to make a vessel shipment of limited quantities from the mainland US to Puerto Rico is a shipping paper required? I’m asking because limited quantities don’t require shipping papers.

A. Technically that is true. Shipping papers are not needed for US GROUND shipments. You have to read the fine print in paragraph 173.150(b) which is the section on limited quantities for flammable and combustible liquids. It that paragraph it says, ” … is not subject to the shipping paper requirements of subpart C of part 172 of this subchapter, unless the material meets the definition of a hazardous substance, hazardous waste, marine pollutant, or is offered for transportation and transported by aircraft or vessel, and is eligible for the exceptions provided in §173.156 of this part“.

Non-hazardous substances under WHMIS 2015

Q.Customer called and asked if SDS’s were required for non-hazardous substances and where to find this in the WHMIS 2015 Regulations?

A.The answer to your question can be found below in WHMIS 2015, which states that safety data sheets only pertain to a hazardous product, therefore Continue Reading…

TDG Update – Regulations Amending the Transportation of Dangerous Goods Regulations (Update of Standards)

On July 2, 2014, Transport Canada issued its amendment regarding updating the Transportation of Dangerous Goods Regulations (TDG) to reflect recent international standards, and to incorporate some new packaging standards. This amendment is intended to harmonize Canada’s regulations more fully with those used for international shipment, therefore simplifying international transport and improving safety. Please note that is a separate amendment from the one issued at the same time regarding safety marks.

The first thing you’ll notice in this amendment is the table in section 1.3.1, Table of Safety Standards and Safety Requirement Documents, has been extensively revised. Many standard references have been updated to more current versions; one of the most significant updates is the new reference to the Seventeenth Edition (2011) of the UN Recommendations on the Transport of Dangerous Goods. Also, some standards have been deleted, such as CAN/CGSB 43.150, “Performance Packagings for the Transportation of Dangerous Goods,” from the Canadian General Standards Board. Instead, new standards such as Transport Canada Standard TP14850, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and 9” have been added. This will bring in a whole new system for selecting packagings for these classes. Other new standards will introduce UN packaging provisions for portable tanks and rail containers.

Not all standards have been updated; note, for example, that CAN/CGSB 43.125, “Packaging of Infectious Substances, Diagnostic Continue Reading…