Top 4 Questions from the Regulatory Helpdesk
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.
UN Numbers on Explosive Placards
Q.Can the UN number be added to a class 1.4 placard shipping UN0323 ground in the U.S?
A. 49 CFR 172.334(a) States no person may display an identification number on Explosives 1.2, 1.2, 1.3, 1.4, 1.5, or 1.6. In this case 0323 is classified as a 1.4, So it cannot display the ID number.
Q. Section 184.108.40.206.1 has changed with the Dec 2017 Corrigenda to the IMDG. Why would you need to put a proper shipping name on a CTU when a placard is all that is really required?
A. First of all that section speaks specifically to 3 situations where information beyond a placard is required. The 3rd one really doesn’t exist anymore, but the first 2 do. The first is when you have a TANK cargo transport unit. Tanks as defined in Section 1.2 are those that are portable tanks, road tank-vehicles like gasoline highway trucks, and rail tank-wagons which are those rounded rail cars that you see. The second is when you have bulk containers. For either of these situations a placard is needed as well as the PSN. Given the corrigenda the height Continue Reading…
Recognizing Technological Evolution while Maintaining Safety & Security
Explosives Regulations (ER) – Ports & Wharves
The Explosives Safety & Security Branch (ESSB) of Natural Resources Canada, and Transport Canada, have issued a Gazette I (CG I) proposal to amend their respective Explosives Regulations (ER, under the Explosives Act), and the Cargo Fumigation and Tackle Regulations (CFTR, under the Canada Shipping Act).
The initial reason for the proposed amendment is to remove reference to the express requirement to use quantity/distance principle (QDP) restrictions and ESSB Inspectors from the CFTR. A more modern approach of quantitative risk assessments (QRA), based on actual probable hazards following, methodology authorized by the ESSB (Chief Inspector of Explosives), would replace the more rigid QDP.
QDP, currently covered in CAN/BNQ 2910-510/2015, were established mainly for fixed manufacturing/storage facilities and specifically exclude transportation activities from the scope of the standard.
The proposal also provides for having qualified individuals, not just ESSB Inspectors, determine the risk following an approved QRA methodology. The requirements will appear in a new ER section 203.1 instead of the current CFTR section 155(2) & (3).
It is expected that international trade and commerce will be improved without sacrificing safety or security under this proposal.
Explosives – Other Amendments
The CG I amendment proposes to also include ER changes under the topics of:
- Eliminating or relaxing license requirements for certain “low risk” explosives (7 components);
- Clarification of wording (13 components); and
- Increasing Continue Reading…
As everyone gathers to enjoy time with friends and family for the 4th of July, it is important to remember that one of our favorite traditions can be dangerous. There are hundreds of injuries and fatalities each year due to fireworks.
“Fireworks on the Fourth of July are an American tradition,” said U.S. Transportation Secretary Ray LaHood. “We want to make sure the traveling public and commercial operators know how to safely transport fireworks so we can all enjoy these colorful displays, both small and large.”
Fireworks are regulated under the hazardous materials regulations. They are a class 1.4G explosive. When transporting fireworks, you must follow the rules as outlined in the regulations including: shipping papers, loading/blocking/bracing, placarding, security plans and you must be a trained person. Workplaces must also meet the requirements under the OSHA regulations, including personal protective equipment and the use of fire extinguishers.
There is a variety of guidance documents available to keep you, your family and your employees safe. Keep safety in mind so everyone has an enjoyable holiday.
OSHA’s Guidelines for the Pyrotechnics Industry – Fireworks Display
Industry Alert for Fireworks Shippers, Distributors, and Carriers