Regulatory Helpdesk: October 2, 2017

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.

#4. Shipping Sodium (UN1428) by Air (USA)

Q. The Customer asked if Sodium (UN1428) can be shipped by air using a plastic bag as an inner container inside of a 4GV box.

A. Per the 49 CFR 172.102 Special Provision A20, Plastic Bags are not allowed to be used as inner receptacles in combination packaging by aircraft.


#3. When to Use Bilingual Packaging (Canada)

Q. Does every word on [my] packaging need to be in French and English to sell in retail stores in Canada?

A. Canada has the federal Consumer Packaging and Labelling Act and the Consumer Packaging and Labelling Regulations. That Act and Regulation requires 2 mandatory items to be bilingual. Those items are the product identity, and the net quantity. The dealers name and place of business can be in either English or French according to those laws.

However, the guide specifically states: Subsection 6(2) of the Consumer Packaging and Labelling Regulations requires that “all” mandatory label information be shown in English and French Continue Reading…

Regulatory Helpdesk: September 30, 2017

Answers from the Helpdesk

ICC supports our valued customers with access to our complimentary Regulatory Helpdesk. To further assist clients, we will be sharing some of the highlights of those calls each week. If you have a question, contact one of our regulatory specialists today.

#2. Certifier’s Signature (Canada)

Q: Can the 49 CFR certification statement be used on Canadian TDG shipping documents for shipments between two points in Canada, having only a signature for the certifier’s name?

A: TDGR 3.6.1(1)(a) does not restrict the use of the 49 CFR statement to US bound/origin shipments. TDGR 3.6.1(2), in conjunction with Transport Canada (TC) Safety Awareness Guidance Bulletin RDIMS#11829346 (August 2017), does not require that the individual’s name be a signature; but if a signature is used it must be clearly legible, identifying the individual, to be compliant.


#1. Refrigeration Regulation (USA)

Q: We need to ship a refrigeration unit (UN2857) that contains a small amount of non-flammable, non-toxic gas. How is this regulated?

A: In general, REFRIGERATING MACHINES, UN2857 are regulated as Division 2.2 dangerous goods, with no packing group. However, small units can usually be shipped as exempted dangerous goods, with no significant requirements, if they contain no more than 12 kg of non-flammable, non-toxic gas as a coolant, Continue Reading…