Combustible Liquids, Using Chemtrec’s Number, Keeping Up-To-Date, and Other Paperwork
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.
DG Documentation on Overpacks
Q. If there are multiple skids of dangerous goods (overpacks) in a shipment on which one should the copies of the invoices and shipping papers be attached?
A. Neither the DOT nor IATA regulations tell you to put “paperwork” on the outer packages or overpacks. That is a carrier/driver thing. All the regulations care about is the proper marking and labeling that they require. You also have to be able to physically hand your paperwork to the carrier. Your best bet would be to talk to your carrier directly as to how they want it handled.
Q. I have a liquid with a flashpoint of 100° F and it does not meet any other hazard classes. It is not an RQ, waste or marine pollutant. After manufacturing, it is placed in tubes and then shipped for sale in retail stores. What marks and labels are needed on the outside of the packages?
A. The flashpoint of this material is 100° F and there are no other hazards under the transport regulations. This means it technically meets the definition of a flammable liquid in Packing Group III per §173.120 Continue Reading…
Dangerous goods, necessary for Canadians’ quality of life, are transported from one area to another across the country every day. These goods, which travel by road, air, rail, and sea, leave Canada by the same routes, railway stations, airports, and ports. All these displacements increase the risk of incidents harmful to human beings and the environment. Therefore, it is essential that manufacturers, shippers, carriers, terminal operators, users, and governments strive to minimize the risk of incidents and the damage they can cause.
Approximately 30 million shipments of dangerous goods are shipped annually in Canada, and 99.998% of them travel to destinations without any incident!
When a dangerous goods incident occurs, the person in possession of the dangerous goods at the time of the incident must call the relevant competent authority (usually the local police, or call CANUTEC at *666 / 613-996-6666 / 1-888-CANUTEC, or call the 24-hour number that appears on the transport document or in the case of an ERAP call that activation number).
When first responders arrive at the scene of an accident involving dangerous goods, they will consult the Emergency Response Guide (ERG). They may also contact CANUTEC for assistance.
CANUTEC is Transport Canada’s Canadian Transport Emergency Center where bilingual scientists are always ready to answer. They are trained in emergency response and are ready to assist when an accident happens involving dangerous goods. Continue Reading…
When you work in the field of safety, and so does your husband, it makes for interesting living situations. I no longer stand on a chair or stool to reach something on the top shelf. There are now ear plugs and safety goggles beside the lawn mower and weed eater in the garage. We have two fire extinguishers – one by the stove and one in the pantry. Our smoke detectors are checked twice a year from a ladder where three points of contact are maintained at all times. There is even an old Emergency Response Guidebook in my car for looking up UN numbers when I travel. Having lived this way for several years now, it surprises me when friends and family talk about near misses they have. Take heart other safety professionals, there is a month dedicated to our cause. June is National Safety Month.
The National Safety Council has outlined topics for each week of the month and even provides free downloadable resources in English and Spanish for each topic upon signup. I encourage you to do so as the resources are great. The link to the National Safety Council site can be found here. To sign up for the free materials, look to the right side of the website. Let’s take a look at each week and expand on the ideas.
A new online awareness tool designed by The Canadian Association of Petroleum Producers (CAPP) is for first responders that are faced with incidents involving flammable liquids. This tool was developed by Inform, Canada’s oil and natural gas safety association, in collaboration with the Canadian Association of Fire Chiefs and Transport Canada.
This tool helps first responders assess hazards at the scene, to know who to contact and what resources are available, and understand how to respond appropriately and safely. Furthermore, the tool addresses knowledge gaps brought forth by Transport Canada’s Emergency Response Task Force based on feedback from municipalities and first responders arising from the Lac-Megantic incident. The awareness tool, is available free of charge in English and French.
The response tool has been endorsed by Transport Canada, with the Minister of Transport, Marc Garneau, saying: “Training is the backbone of any emergency response, and this new tool will help guide first responders in these critical situations.” The Emergency Response Task Force brought together the parties needed to make this tool a reality and brought forward many recommendations that will continue to make transporting dangerous goods by rail safer. The Task Force has worked diligently to examine 650 flammable liquids in Canada and has provided over 33 safety recommendations to date, with more expected this year.
The shippers (consignors) of dangerous goods in Canada as per Section 3.5 of the Transportation of Dangerous Goods Regulations have to include an emergency telephone number on the transport document. Those consignors can now register online to use the free 24-hour emergency telephone number provided by the Canadian Transport Emergency Centre (CANUTEC). Registering with CANUTEC allows shippers to use the free number and makes the Centre’s technical assistance available in the event of an incident.
You can find more information available on the Transport Canada website:
What information do you need on a shipping paper or an emergency response situation? Depending on the country you are shipping from, the answer can vary.
The Transportation of Dangerous Goods Regulations, Part 3, (1) 3.5(f) and (2) outlines the requirements for the shipping document. These requirements include:
Having the words “24 hour number” followed by an active 10-digit telephone number xxx.xxx.xxxx,
Being able to reach the consignor immediately, and
Providing technical assistance without breaking the connection. An outside agency that is registered with the emergency response provider may be used.
The requirements outlined in the 49 CFR [172.201(d) and 172.604(b)(1)&/or(2)] states that if the shipper is using an Emergency Response Information provider or an agency on their behalf, a 24-hour telephone number and name of the person or contract number must be added to the Emergency Response Shipping paper.
Recently, an FAA inspector visited a customer of ours and the Emergency Response information on the shipping document was something they checked. As part of their audit, they called the number listed on the form to verify that the contract number was indeed valid.
Remember, during a transport emergency, first responders rely on this information to react to the situation quickly and to react with the correct protective and fire-fighting measures.
Do you need a 24-hour emergency response service?
ICC has a 24-hour phone number available in the USA, Canada and internationally.
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…