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…
Transport Canada’s Standard TP14850, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8, and 9”
Transport Canada is well into the process of producing the 3rd Edition of TP14850. The current 2nd Edition (2010) has been in effect since it replaced the CGSB 43.150-97 standard in 2014. Changes to TP14850 are required to reflect current harmonization with the UN Recommendations, changes in the TDG regulations, improvements to ensure the integrity of standardized packaging, addition/clarification of Part 14 special cases, and simplify use of the standard.
Comments are welcomed until May 31, 2017.
An initial draft update was prepared for discussion in January 2016 and a committee of 30-40 stakeholders has been reviewing, discussing and proposing modifications between the initial draft and the May 2017 draft version of the 3rd Edition (by way of disclosure, the author of this Blog is one of the stakeholder representatives). The May 2017 draft follows these reviews and feedback from an initial 2016 public consultation.
Manufacturer’s Periodic Re-Test Obligation
A new requirement (Clause 7.1.7) requires the registered manufacturer to periodically, at least every 5 years, repeat performance tests on a representative sample. Typically, registration certificates are issued for 5 year periods.
One thing to note is that although TP14850 as currently written/proposed does not define “manufacturer” with respect to obligations under the standard, the application form for registration clarifies, in section 4 and Continue Reading…
How to Select and Use Single Packaging
“Less is more” is a concept that applies to many things, including selecting packaging for hazardous chemicals. Is dealing with complicated packaging designs with multiple components too costly and time consuming? Do you want to “go green” by eliminating unnecessary packaging material? If you do, the minimalistic single packaging format may be for you.
What is Single Packaging?
Basically, single packaging is packaging that does not incorporate inner containers. It can be compared to the other major packaging type, the combination packaging, which has inner containers inside an outer packaging. The design of a single packaging, by contrast, consists of one single “layer” of packaging and a closure. Typical single packagings include:
- Jerricans (rectangular drums)
- Boxes (if no inner packagings are used)
For hazardous materials, single packagings must be tested according to the United Nations (UN) specifications. This involves preparing samples of the packaging design, and running them through a gauntlet of tests that simulate common causes of package failures. These tests include a drop test and a stacking test, as well as others aimed at specific packagings, such as fibreboard components or wooden barrels.
Types of Single Packaging
Single packagings are divided into two types – those that will be used for solids only, and those that also can be used to ship liquids. The main difference is that those suitable 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