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Hazmat Packaging Bears Rigorous Testing

Hazmat Packaging Specs

Shippers of Hazardous Materials (or Dangerous Goods) know that the packaging they use has to meet certain specifications and pass standard tests before it can be considered appropriate for the hazardous shipment. Most training classes will explain that the package design must go through various tests to simulate conditions they may encounter during transport.

I started to wonder if users of the packaging really understand the conditions these designs are put through. No, it doesn’t look like this…

… but a few of the tests are quite rigorous! Below are some examples.

  • Drop Test – Drop testing is done on five test samples. The samples are prepared as they are intended to be used by a shipper. Each sample is dropped on a different surface of the package (top, bottom, long side, short side, and corner) from a height between 2.9 and 5.9 feet (0.8 – 1.8 meters), depending on the packing group of the materials that are going to be authorized. Any release of sample material during any of the drops is considered a failure.
  • Stack Test – Stack testing is done on three test samples. The samples are subjected to force that is equivalent to the weight of identical packages stacked to 3 meters. The samples must withstand the weight for 24 hours without leaking or showing any damage or distortion that could reduce its strength or cause instability in stacks during transportation.
  • Puncture Test (required for Category A Infectious Substances Packaging) – Puncture testing is done on two test samples. Depending on the gross weight of the samples, they are either dropped onto a steel cylindrical rod, or have a steel cylindrical rod (weighing at least 7 kg) dropped onto them. Any leakage from the primary receptacle is considered a failure.

These tests should be carried out by a qualified technician who follows proper protocols and methods. A polar bear is not required, but they sure do like to test the limits of plastic drums!


Check out our new bear awareness online course »

*Special thanks to Luna, one of the resident polar bears at the Buffalo Zoo for demonstrating how not to test packaging. No polar bears were harmed in the making of this blog … but I can’t say the same for the drum.

PHMSA
Correction to HMT in 49CFR

On Monday, April 25, 2016 the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a correction to the 49CFR Hazardous Materials regulations in the Federal Register.

The correction states:

“In Title 49 of the Code of Federal Regulations, parts 100 to 177, revised as of October 1, 2015, on page 269, in § 172.101, in the Hazardous Materials Table, for the entry ‘‘Phenylmercuric compounds, n.o.s.’’ add ‘‘G’’ in the first column.”

The federal register notice can be viewed here: https://www.gpo.gov/fdsys/pkg/FR-2016-04-25/pdf/2016-09615.pdf

The “G” in the first column of the Hazardous Materials Table (HMT) identifies proper shipping names for which one or more technical names of the hazardous material must be entered in parentheses, in association with the basic description. The technical name(s) must be shown on package marking and shipping papers. Failure to comply with the corrected information can result in non-compliant shipments.

Toxic
The Zika Virus — Public Health Crisis and Regulatory Puzzle

Zika virus – the name itself sounds exotic and dangerous. It is believed to be a serious risk for pregnant women. And it’s due to arrive in North America. Just how great a danger is this virus, and how should research and medical facilities prepare for the regulatory burden?

First of all, Zika is not a new virus. It has been known since the 1950s in equatorial Africa and Asia, but only recently has it appeared to migrate to new territories, including South and Central America, the Caribbean and Mexico. It is primarily a mosquito-borne illness, transmitted by the Aedes genus of mosquitos. Possibly climate change has increased the populations of these mosquitos in the areas where Zika is spreading. Aedes mosquitos are found in some parts of the U.S., and although they are not currently believed to be in Canada, they may spread as the climate warms. Person-to-person transmission by body fluids is possible, but this would be relatively rare compared to the mosquito vector.

Zika is classed in the Flaviviridae family of viruses, along with dengue fever, West Nile virus and the notoriously dangerous yellow fever. However, compared to these, Zika is usually a mild affliction. According to the Centers for Disease Control (CDC), only one in five persons infected with the virus shows any symptoms at all. For those who do fall ill, the symptoms are described as flu-like: fever, joint and muscle pain, inflammation of the eyes (conjunctivitis) and a rash. Although there is no cure, and the virus does not respond to antibiotics, the infection normally resolves without treatment within a week. Fatalities are extremely rare. In other words, Zika is, for most people, a mildly unpleasant illness that they recover from quickly. Even better, exposure to Zika usually results in lasting immunity.

So, why has Zika become such a big issue in public health? While most people only become mildly ill when infected with Zika, the infection appears to be correlated to increases in two much more serious conditions: the neurological condition called Guillain-Barré syndrome (which can be triggered by a number of infections), and most tragically, the birth defect called microcephaly.

Microcephaly is a condition where a baby’s head is smaller than normal, and often includes abnormal brain development. The CDC indicates “problems can range from mild to severe and are often lifelong. In some cases, these problems can be life-threatening.

It should be noted that we don’t yet have a conclusive linking of Zika to microcephaly, but some relatively strong evidence has been gathered. There appears to be a statistical increase in microcephaly in the children of mothers infected by Zika, as well as evidence that the virus can pass the placental barrier. The virus has been found in the brains of affected infants. So, it seems at least plausible that there is connection between the condition and exposure to the virus during fetal development. We don’t yet know just how likely the condition will be if the mother is infected with the virus, and we don’t know if it can occur at any stage in fetal development, or if there is only a short window of time for the defect to arise.

It would appear, therefore, that the main public health issue is the risk to developing fetuses. This is not a new problem; pathogens such as those responsible for rubella (German measles) and toxoplasmosis are also known to cause serious birth defects. But Zika has gathered headlines due to its fast spread, its previously unknown status to the public, and the difficulty in avoiding exposure to mosquitos if you live in an area where the disease is prevalent.

Based on mosquito distribution, it’s likely that Zika will obtain at least a foothold into the United States. Canada may be at less risk due to its colder climate, but there is a possibility of spread as global temperatures warm. The CDC and Health Canada have put out advisories to help people protect themselves from exposure to the virus. But medical facilities and laboratories must also take steps to prepare for Zika’s arrival, from preparing the infrastructure to send samples for analysis and diagnosis, to disposing of contaminated linens.

The first step in transporting infectious substances is to classify it according to either the U.S. “Hazardous Materials Regulations” of 49 CFR, or Canada’s “Transportation of Dangerous Goods Regulations”. Although many disease organisms have accepted classifications established for them (such as those found in the IATA Dangerous Goods Regulations), Zika virus is so new to North America that there has not yet been an official classification assigned.

Pathogens fall under two categories. Category A is used for organisms that are “transported in a form that, when exposure to it occurs, is capable of causing permanent disability, life-threatening or fatal disease in otherwise healthy humans or animals.” Pathogens that do not meet that criteria will be classed as Category B, less hazardous.

Although it is not immediately dangerous to the person affected, Zika is capable of causing permanent disability (birth defects) or life-threatening conditions (Guillain-Barré syndrome). However, it is not likely to cause these effects simply from a spill in transportation – it appears that direct blood contact is necessary to contract the disease. Unless the Department of Transportation or Transport Canada make an official determination of the appropriate category, as they did in the SARS outbreak, the decision will be the shipper’s, and should be guided by medical or scientific personnel. It may be noted that many other viruses in the Flaviviridae family have a split classification; they are placed in Category A when transported as a culture (artificially propagated to increase the virus concentration), but Category B when transported in samples in their natural state, such as blood or other body fluids.

Once the classification has been determined, packaging must be selected for Category A or B as appropriate. Obviously, the highly dangerous Category A organisms will require a much more secure packaging, one which must be approved to a standard created by the United Nations. Category B packages do not have to meet UN specification, but they must follow the regulations for construction and use. Note that ICC Compliance Center can provide packagings for various needs, from shipping small samples to disposing of contaminated linens as hazardous waste.

Once assembled, you must identify the package as containing Category A or B substances with the appropriate safety marks and labels. Note that Category B substances do not have to show the Class 6.2 label, but must show a diamond with the applicable UN number, UN3373, in the center. Category A pathogens will require full dangerous goods shipping papers. Most regulations exempt Category B from some or all of the shipping paper requirements. While placards are not required for Class 6.2 materials under the “Hazardous Materials Regulations” in the U.S., Canada does require placards if the shipment exceeds 500 kilograms or is subject to an Emergency Response Assistance Plan (ERAP). And, of course, personnel performing dangerous goods functions must be trained and certified in the appropriate regulations.

If you intend to ship pathogens outside your own country (for example, for international research efforts), remember that exporting and importing of infectious substances will involve additional regulations, such as the CDC’s Import Permit Program.

For more information on protecting yourself and your family from Zika, consult the Centers for Disease Control, or Health Canada.

 

Do you have questions about how to transport infectious substances? Need labels, packaging or other supplies for such shipments? Contact ICC Compliance Center here at 888-442-9628 (U.S.) or 888-977-4834 (Canada), and ask for one of our regulatory specialists.

Special Permits
Adoption of Special Permits into the HMR (HM-233F)

There was a Legislative act signed by US president Barack Obama in July of 2013 called Moving Ahead for Progress in the 21st Century Act or MAP-21. As a result, the Pipeline and Hazardous Materials Safety Administration (PHMSA) is making changes to the Hazardous Materials Regulations (HMR). These changes will incorporate some provisions from some of the special permits that have a proven safety record and have been widely used over an extended period of time. The intent in doing this is to provide widespread access to regulatory flexibility normally offered in special permits and removing the need for abundant renewal requests. The adopted amendments will also reduce paperwork burdens and help commerce while sustaining an appropriate level of safety.

Special permits set out variances to the requirements found in the regulations, but still has a level of safety that is equal to the safety level required otherwise in the regulations. The MAP-21 legislation required PHMSA to take a look at the special permits that have been in effect for 10-years. PHMSA conducted an investigation of all active special permits and categorized them, as appropriate, as suitable for inclusion into this rulemaking.

The result is PHMSA amending the regulations, 49 CFR Parts 171–180, by accepting requirements within 96 existing special permits. These amendments are based on the review they did of all active special permits as of January 1, 2013. There were 1,070 Special Permits that were not suggested for inclusion in the HMR due to these special permits having requirements that do not have a wide range for applicability, have already been implemented into the HMR, are being addressed in other rulemakings, or were removed after receiving comments in response to the notice of proposed rulemaking (NPRM) under this HM-233F.

In doing this PHMSA was to determine which ones may be implemented into the HMR. This also required PHMSA to adopt any special permits identified for inclusion in a final rule by October 1, 2015.

The factors to be considered during the examination to determine suitability for implementation into the HMR are as follows:

  1. The safety record of the hazardous materials (hazmat) transported under the SP;
  2. The application of a SP;
  3. The suitability of the provisions in the SP for incorporation into the hazmat regulations; and
  4. Rulemaking activity in related areas. [i]

Before the MAP-21 was put into legislation, PHMSA had already completed a number of rulemakings to adopt some special permits that had a proven safety record into the HMR. Some of these can be found on Table 1[ii] in this final rule.

After the passing of the MAP-21, PHMSA had to change its approach to fulfill the requirements set forth in this legislation. They established terms for reviewing, set up criteria and categories, and put tools in place to help track and facilitate in analyzing current special permits in timely and efficient manner.

In the MAP-21 Legislation the Federal Hazardous Materials Transportation Law was revised to address the “SP and exclusions,” section under paragraph (f).

It states:

(f) Incorporation into regulations.

(1) IN GENERAL-Not later than 1 year after the date on which a SP has been in continuous effect for a 10-year period, the Secretary shall conduct a review and analysis of that SP to determine whether it may be converted into the hazardous materials regulations.

(2) FACTORS-In conducting the review and analysis under paragraph (1), the Secretary may consider-

(A) the safety record for hazardous materials transported under the special permit;

(B) the application of a special permit

(C) the suitability of provisions in the special permit for incorporation into the hazardous materials regulations; and

(D) rulemaking activity in related areas.

(3) RULEMAKING- After completing the review and analysis under paragraph (1) and after providing notice and opportunity for public comment, the Secretary shall either institute a rulemaking to incorporate the special permit into the hazardous materials regulations or publish in the Federal Register the Secretary’s justification for why the special permit is not appropriate for incorporation into the regulations[iii]

PHMSA was also required to implement standard operating procedures (See my previous blog on SOP) to assist with the special permit review and approval processes.

PHMSA has requested comments from holders of special permits that were not implemented. “We stated that we were particularly interested in comments that confirm or refute the suitability, safety, and general applicability of the Special Permit. We asked that if you are a holder of a SP that was not proposed to be adopted but believe it should be, you should submit material to support such an argument.”

They requested that special permit holders submit information and supporting arguments along with technical/scientific data as well as the cost, benefits and frequency of shipments made under said special provision. Information regarding any incidents during transport with said special provision and how often the incidences occurred is also to be provided. PHMSA also asked for commenters to include suggested regulatory text.

The final rule includes much more detailed information like a special permit conversion project chart, where the method is shown on how they staged the analysis and decision process. This includes the specific Special Permits proposed for inclusion, also includes many comments from industry that give a good look into what others are thinking, which brings in different useful perspectives. For more on this final ruling please follow the HM-233 links within this blog.

[i] Pg. 4 of the HM-233F Final Rule

[ii] Pg. 6 of the HM-233F Final Rule

[iii] Pg. 7-8 of the HM-233 Final rule

N.O.S. – Not Otherwise Specified

3 Little Letters, 1 Short Phrase

The DG/HazMat world occasionally encounters confusion when there’s a need to refer to the “N.O.S.” aspect of a shipping name. The abbreviation is used in the proper shipping name of mixtures that have a potential variety of hazardous ingredients and/or don’t have a more specific, applicable name in the UN list.

The principal is that if the shipping name preceding the N.O.S. doesn’t contain sufficient details on the hazardous ingredient, then a technical name must be included in brackets following the N.O.S. as part of the proper shipping name. In some cases (i.e. US shipments) more than one technical name may need to be shown if there is more than one ingredient contributing to the hazard.

For example, in a mixture containing both ethanol and isopropanol (ethyl & isopropyl alcohols) along with other ingredients; in sufficient concentration to be classed as a flammable liquid; the proper shipping description would be “UN1993, Flammable Liquid, N.O.S. (ethanol)” internationally, and “UN1993, Flammable Liquid, N.O.S. (ethanol, isopropanol)” in the US.

Similarly UN numbers with a subsidiary class would also have to list the ingredient, if different, resulting in the subsidiary hazard.

The US convention is allowed by the phrasing of “at least the most hazardous” or similar wording in other modal/national regulations.

Technical Names

The term “technical name” is defined in the various regulations, but the common theme is that it cannot be a marketing tradename- it must be a name such as the chemical name or a similar name recognized in scientific or technical publications. This can lead to some interpretation issues since the line between acceptable industry technical publications and scientific practise can be blurred. Typically an abbreviation will not be acceptable just because it’s used in the literature, unless a recognized body officially adopts it.

An example is the antiseptic known commonly by the abbreviation PHMB, for polyhexamethylene biguanidine. PHMB is not likely to be accepted (based on at least 2 anecdotal reports to our helpdesk) whereas the common chemical name polyhexamethylene biguanidine is acceptable (and much easier to remember than the formal scientific name which would be twice as long!).

The exception to this rule is when the DG/Hazmat list recognizes an abbreviation or code as an entry- such as the “R” codes for refrigerants e.g. “REFRIGERANT GAS R 152a” for “1,1,-DIFLUOROETHANE” (UN1030).

Another area that is subject to less stringent nomenclature is infectious substances. Depending on the specific jurisdiction, Class 6.2 Category A or B designations; or generic microbiological descriptions (e.g. bacterial, viral, etc. sample) may be used.

Look for the Trigger

A common misconception is that a technical name is required whenever the list name ends in “N.O.S.”. This is not the case. There are about 320 or so listings that end in “N.O.S.”, however about 38 of these are considered to have sufficient detail in the name. An example is UN 1268: “PETROLEUM DISTILLATES, N.O.S.” or “PETROLEUM PRODUCTS, N.O.S.”. Apparently the regulators see little advantage in adding the specific product that results in it being flammable to the term “petroleum”. Similarly UN1477: “NITRATES, INORGANIC, N.O.S.” is a stand-alone proper shipping name. As long as the correct PG is given, it matters little which specific nitrate compound (e.g. potassium or sodium) is in the nitrate mixture.

How is one to know the trigger? Each set of regulations has either a symbol or “special provision” that requires the addition of technical names to the proper shipping name. In the US 49 CFR, it’s a letter “G” in column 1 of the 172.101 HazMat Table; in the Canadian TDGR it’s invoked by Special Provision 16 (SP 16) in Column 5 of Schedule 1; IATA DGR uses a “star” symbol after “n.o.s.” in the Part 4.2 DG list; while the IMDG Code uses Special Provision 274 in column 6 of Volume 2’s Part 3.2 DG list.

Caution Regarding TDGR Schedule 2- SP 16

In common with the other jurisdictions’ regulations, Canada’s TDGR SP 16 contains a provision for not disclosing the technical name of medicinal ingredients which are controlled substances WHEN THEY ARE SUBJECT TO a domestic or international prohibition on disclosure ( Presumably to make it harder for the “bad guys” to know which shipments have the “good stuff”!). Thus, this is not an automatic omission – only those covered by a specific regulation or agreement can omit the technical name.

A general caution regarding TDGR’s usually helpful practice of listing the “Applicable UN numbers”, potentially affected by that special provision, in italics at the end of each Schedule 2 special provision:

Remember that elements (like these listings) in italics are for INFORMATION ONLY, they are not part of the regulation. Due to the positioning of the information, some users who initially refer to SP 16 interpret the list of UN numbers as being those which do not require a technical name – this is NOT correct.

Rather it is a complete listing of the UN numbers which do invoke SP 16 in Schedule 1 – exemptions are only applicable if they meet the criteria in 16(2) or 16(3)’s non-italicized text.

… A variety of pitfalls.

The Compliance Center
The Story of ICC

One thing that amazes me after 25 years in business is the fact that (even long time) customers do not understand the spectrum of products, services, and training we offer. After hearing yet another customer say, “we did not know you did that” I was inspired to tell you this story.

Once upon a time, not so long ago there was a train wreck, not unlike Lac Megantic disaster of late. A man who owned a printing company was inspired to start another company and together with his partners started to print products that related to shipping dangerous goods.

With the onset of the Transportation of Dangerous Goods Regulations (1985), released by Transport Canada, the company was kept busy producing placards, hazard class labels, signage, and other transportation supplies.

Within a few short years Health Canada introduced WHMIS (1988), where supplier and workplace labels were in high demand. In addition WHMIS introduced Material Safety Data Sheets (MSDS), and with that, the introduction of a new arm of the company. Training was also introduced not only for transportation, but workplace safety as well.

In 1991, The IATA Dangerous Goods regulations, and 49 CFR (remember HM-181?) introduced something new called UN Performance Packaging, or commonly called “POP Packaging” at the time. ICC Compliance Center was one of the first companies to introduce packaging and educate companies on its use.

Bring on the new era of computers and the internet. Customers are looking for ways to print labels more efficiently, and host the MSDSs so they can be accessed by all. Software and printers were introduced to the product offering, making “on-demand” a reality.

Rumblings at the UN about a Globally Harmonized System for Classification (GHS) and Labeling were heard, and most would say, “not in my lifetime.” It took time, but eventually, countries around the word began to release plans to adopt and enforce this new recommendation. ICC Compliance Center once again strategizes and develops products, services, and training to help those in the industry with the changes. Finally, GHS becomes a reality in the USA and Canada (2012 and 2015).

Today, ICC Compliance Center serves customers across North America providing more products, services, and training than ever before. We are a one-stop shop for customers who offer, handle, or transport dangerous goods, and workplace compliance and safety.

If you have ever thought of us as “the box company” or “the training company”, give one of our other products, services, or training a try. Happily ever after is only a phone call away.

The End.

Traveling With Hazmat … What Will and Won’t Fly

As a frequent traveler, for both business and pleasure, I am often passing though airport security checkpoints before whisking off to my final destination. Because of the industry I am in, I always seem to notice things that most travelers don’t. Most passengers tend to know the rules regarding carry on liquids. They usually know that they need to take off shoes and remove laptops from bags before x-ray screening. While waiting in line, I start thinking about how many of them really understand how many hazardous materials we may be taking on vacation with us and that there are additional rules for carrying them on aircraft.

Traveling with HazMatDuring my most recent trip, I noticed a sign while in the queue for the security checkpoint at Phoenix Sky Harbor Airport. It seemed odd to me that they would choose to display this sign in a passenger area. While the information provided on the sign is accurate and useful, it is not appropriate for the audience it is reaching. Those passengers who actually stop to read the sign will likely think it does not apply to them because they are not traveling with packages as pictured. In my opinion, a more effective sign for this location would warn that lithium batteries that are used with personal electronics can start fires if they are dropped or improperly charged. Showing photos of laptops, cellphones, e-cigarettes, and spare batteries would be more applicable than labeled shipping cartons.

When checking in for a flight in the US, passengers must acknowledge that they are not carrying any hazardous materials in their luggage. The acknowledgement usually gives a few basic examples, but again I wonder if people really understand what they are saying. The FAA has a webpage (click here) that details all of the possible hazardous materials and which ones can go in check baggage, carry-on baggage, both, or not at all. As I was scrolling though the list, I realized that I had inadvertently violated the rules with one item that I keep in my toiletry bag … anti-static aerosol spray! I have long hair so I usually carry a travel size container of the spray with me to deal with flyaway hair due to excessive static. I had no idea it was on the forbidden list until I already the statement “Aerosol laundry products do not qualify for the toiletry article exception, so if they are flammable they are forbidden in carry-on and checked baggage.” It does not qualify as a toiletry item because it does not touch your body when you use it.

Thanks to my research for this blog, I learned something new today. I will now be going through my pre-packed toiletry bag to make sure I don’t have any other forbidden materials. I hope more people become aware of the items on the list and help to make travel a little bit safer for all of us! As the FAA says on their page … When in doubt, leave it out!

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Chemical Safety and Back to School

Every year around this time a feeling of nostalgia gets me. As soon as the first sign about “back to school” shows up in a store or on TV, I am transported to my previous life. For over 10 years I taught high school science. Each year there were plans to make, supplies to buy, and students to meet. Thinking on it now from the perspective of a safety professional, it is amazing the chemical hazards present in an everyday school situation.

Being a science teacher it was easy to engage students in their own learning. Usually, all it took was setting up some demonstrations of some basic chemical reactions and everyone was read to go. A few of the more common ones were called Colored Fire, Sugar Snake, and Elephant’s Toothpaste. In each one of these, hazardous chemicals are used to make the reaction. For the Colored Fire, alcohol solutions of various metals are used. The Sugar Snake involves the use of concentrated sulfuric acid. In Elephant’s toothpaste a hydrogen peroxide solution is used. As a teacher you always had to model good safety habits including the proper personal protective equipment and keep students far enough away for the actual demonstration to be safe.

Colored Fire

Sugar Snake

Elephant’s Toothpaste

Elsewhere in the school building there were other hazardous chemicals. Consider the toner in the copy room. Also, the Custodial department uses strong chemicals on a daily basis to keep things clean. Throughout the year, the grounds crew handles hazardous chemicals so the campus will look good and be safe. For many schools there is also the garage and maintenance areas where buses are serviced which can involve hazardous materials. All of these locations must be made aware of the chemicals being handled and how to do so safely.

It begs the question – Are schools aware of HazCom 2012? Have the staff and faculty been trained to recognize the wider range of hazards? Have the locations that deal with hazardous materials been updated with more current safety data sheets. In doing some research on my own, I found organizations such as the National Science Teachers Association and the Chemical Safety Board have released various messages calling attention to the new regulation and offering resources to help with safety inside the school setting.

While the school systems juggle so many things at the start of a school year, the safety of their teachers, faculty and most importantly students should never be compromised. Be sure to contact ICC Compliance Center for the best options for labeling the hazardous chemicals in your school.

When a Hazmat Incident Hits Close to Home

I was scrolling through my news feed this morning when a post from the local Fire Department info page caught my eye. I read the statements “Suspicious Package. Niagara County Hazmat Team and US Airforce Hazmat Team from Niagara Falls Air Base requested to scene.” and I immediately started to look for more information. The location of the scene is not only within a few hundred feet of Niagara Falls and the Canadian border, but it is approximately 8 miles from my office and only 1.5 miles from my daughter’s elementary school. In this industry, I hear about hazmat incidents every day, but this one hit close to home.

Thanks to social media, I was able to get real time updates on the situation from the Facebook pages of The Niagara Gazette, Niagara County Fire Wire and Niagara Falls Fire Department Calls and Info. These sources were reporting information broadcast over public scanners. Local news stations hadn’t yet started to report the story. An envelope with a suspicious material was discovered in the human resources department. Employees were evacuated as a precaution. The Air Reserve team was on site first, with the county team in route to assist them. The hazmat team was directed to take samples, check the package for any additional suspicious content and to photograph the package. Initial data lead the Hazmat Command to believe that the package contained crushed medication, but further testing is needed to confirm.

It has now been 1 hour since the first posts from local departments hit social media and the local news channels are starting to report the incident on their pages. Since the immediate concern has passed, the updates have slowed. It was reported that 10-20 employees would require decontamination if the substance was determined to be hazardous. Thankfully, it doesn’t appear that will be necessary. It was very interesting to me to “watch” these events unfold in real time and see how quickly teams are able respond when needed.

READ:
The article from the Niagara Gazette
WIVB’s Article (Video)

Single Packaging
The Carrier Has The Final Say

Have you ever prepared a shipment that you were 100% certain was done according to regulation, only to have it refused by the carrier? The reason may be because carriers can put in place requirements that go above and beyond the regulations and will refuse your shipment if you do not comply. Finding these extra requirements can be simple for air shipments thanks to the Operator Variations listed in IATA Section 2.8.3. However, other modes of transport do not have the variations listed, and even the IATA variations don’t cover every possible extra requirement.

Below are a few ways you can determine if there are additional requirements for your shipment.

  1. Ask your carrier! If you are using a new carrier or shipping a new material with your current carrier, ask them if there are any additional requirements that you should be aware of before you prepare the shipment. Most carriers have dedicated Dangerous Goods agents who will be able to let you know about any extras.
  2. Check the IATA variations even for ground or vessel shipments. Many of the operator variations that are listed in IATA apply to all shipments for that carrier, regardless of the mode of transportation. One common example is FedEx’s FX-02, which requires Division 6.1 material in PG I or II to be in special permit packaging for domestic shipments.
  3. Trial and error. Sometimes, the way we learn about additional requirements is by having a shipment refused the first time we try to ship it. Most times, a carrier will let you know why they refused the shipment so that you know for the future.

Keep in mind, these additional requirements are changing just as often as the regulations are. Make sure that you are always up to date on your training and that you communicate with your carrier to ensure that your shipments are compliant. I always say in my training classes; “If your carrier wants every hazmat package identified with a pretty pink bow, go out and buy some ribbon if you want to use that carrier!”


Is your training up to date? To schedule your training, or to find out more information, call one of our customer relations centers today: 888-442-9628 in the US or 888-977-4834 in Canada.