ICC Compliance Center
Looking Forward to 2019

At the start of each new year lots of things are said about changes to make in order for the next year to be better. Many make resolutions about losing weight or getting healthy. Others decide to be nicer to people, spend more time with family or volunteer. It doesn’t mean the previous year was bad, but things can always get better. Let’s look at this from a regulatory compliance point of view, and see if things will be better in 2019.

Changes to Regulations:

Starting January 1, 2019 there is a new version of the IATA Dangerous Goods Regulations. You must now be using the 60th edition. Luckily, IATA does a great job of giving advanced notice about what is changing late in 2018 so people can start to prepare before the new version takes effect. You can see the list of “significant” changes here. The IMDG Code was also updated for 2019. The new version is the 39-18 Amendment. You are allowed to use the 39-18 starting in January 2019, but the older 38-16 version is still viable for the rest of this year. Again, a summary of the changes for that regulation was published as well. You can find them here. The US ground regulations of 49 CFR had a few amendments throughout 2018, and there is a large one looming for 2019. To stay up-to-date Continue Reading…

dangerous goods forms, IATA, IMDG, 49 CFR, TDG documentation
Inner quantities on the IMO declaration…do you need to add it?

For many of us who have been preparing international ocean shipments for sometime now we know that the requirements of what needs to be included on the IMO declaration hasn’t changed all that much.   

One of the biggest frustrations is when carriers or agents of carriers reject the IMO declaration because the inner quantity information is not provided on the actual declaration. I know carriers need to enter information in their internal system for acceptance of shipments (DG or not), and perhaps the system requires the breakdown of inner packaging but why is the IMO declaration being rejected? This information can be provided on an alternate document (i.e., packing list).

As per section 5.4.1.5.1 of the IMDG Code “The number, type and capacity of each inner packaging within the outer packaging of a combination packaging is not required to be indicated.” The Code never asked for it; however, a few editions back, “they” clarified it by adding the above quoted note. And I for one am grateful for it because now when someone comes back stating the declaration is incorrect, I just scan, highlight this section from the Code, and email it to them. I am not trying to be a smart-ass, but for me it’s about educating others. They can read that specific section to avoid future hindrance with others. This goes for me as well. I appreciate it Continue Reading…

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 Continue Reading…

Overpack Label
“OVERPACK” Markings – Overdone?

The Issue

The formalization of the overpack concept into the Canadian TDG regulations has been the subject of concern for domestic shippers of dangerous goods due to the wording for fully regulated (TDGR 4.10.1) products. The wording implies that even when the DG safety marks for packages within the overpack are visible, the overpack must still have an “OVERPACK” mark displayed. This leads to some additional labelling requirements, particularly for shippers of stretch-wrapped pallet loads.

Definition

We’ll pause to review the concept of an overpack, consistent among the various regulations (e.g. TDG, UN Model Recommendations, IMDG, IATA, & 49 CFR).
An overpack is non-standardized packaging that:

  1. Is used for handling convenience (e.g. to reduce multiple handling- I.e. 4 drums on a skid, allowing loading 4 at once rather than 4 trips, or 6 small containers in a “non-spec” master carton, or 48 small boxes stretch wrapped on a skid; a keg (small drum) in a non-spec box for stability, etc. )
  2. Cannot be used as a replacement for inadequate, required “standardized” packaging
  3. Is to be unopened between consignor and receiver
  4. Cannot interfere with the integrity of the standardized packaging (e.g. banding cutting into boxes on a pallet)

The common principle requires that the description of DG that cannot be seen once the overpack is in place will be reproduced on the outside of the overpack.

However, this could be misleading in that Continue Reading…

Danger Placard
Remembering Placards

Mnemonic Devices

How do you remember the meaning of something? Do you try to KISS it where KISS stands for – Keep It Simple Silly? Do you use mnemonics from elementary school and even through college to trigger your memory? I do, and boy how they make things easier. I bet you can remember ROY G BIV, the colors of the rainbow from art class. Music class they gave us easy ways to remember the treble clef with Every Good Boy Does Fine for the lines on the staff and FACE for the spaces. One of my favorites however, is PEMDAS to help remember the order of operations in math!

I am always looking for a fun way to help reinforce my memory. In the hazardous transportation industry there are so many things to remember or define. Oh and the acronyms!

What is a Placard?

Let’s take a look at placards. What is a placard? As defined in the Merriam – Webster dictionary a placard is defined as:

a large notice or sign put up in a public place or carried by people

Placards provide pertinent information about an area, a specific instruction, or a hazard. Placards are used in work places to communicate to people of special operating procedures. Placards are also used in transportation to warn of hazards that are present in a truck on the road, in a rail Continue Reading…

Why You Need the Most Updated Regulatory Texts

The Bible, Shakespeare and Transport Regulations

“Woe is me” is a phrase heard by many. It basically means someone is unhappy or distressed. The Bible uses this phrase in several locations including Job 10:15, Isaiah 6:5 and Psalms 120:5. Shakespeare later used this same expression when writing for his tragic character Ophelia in “Hamlet”. Existing and operating in the world of regulations can also bring on this feeling. It is difficult enough learning the basics of any regulation, but to truly “know” it takes time, patience and work. This process is complicated by the fact that many regulations change. Is it really necessary to have the newest, latest regulation? To answer that question it is time to look to the regulations.

International Air Transport Association (IATA):

For many, these are the Air Regulations. In this instance, the regulation is updated YEARLY. A new edition goes into effect on January 1st of any given year and ends on December 31st of that same year. The Regulation is currently on its 56th Edition. To showcase some of the changes that could apply to a variety of shippers, please read the following:

  1. The List of Dangerous Goods has new entries and/or updates to existing substances
  2. Packing Instructions for Lithium Batteries was updated to include not only a change but also a new addition
  3. Section 7 – Marking and Labeling for Limited Quantities has new information

Continue Reading…

Sailing Along – Significant Changes to the IMDG Code 37-14

The next edition of the IMDG Code will soon be available for use in January 2015, becoming mandatory in January 2016. This amendment sees additions (some of which are also incorporated into IATA – see Suzanne’s Blog of August 28th) to the DG list adding UN numbers for adsorbed gases and capacitors; and re-naming air bag modules/seat belt pretensioners to “Safety Devices”.

The latter will have 2 designations: “electrically initiated”, UN3268 (Class 9); or “pyrotechnic”, UN0503 (Class 1.4) depending on the classification. Parts 1, 2, 4 & 6 update Class 7 requirements for radioactive materials. These additions and changes require a series of modifications to the other parts of the Code.

The GHS reference has been updated to the 5th edition and the revised CSC International Convention for Safe Containers (including criteria for taking units out-of-service) has been added to the General Provisions in Part 1.

Column 16 in Part 3 (“the DG list”) has been split into “a)” and “b)” with the addition of new provisions in Part 7, to list codes and for stowage (“SWxx”- 7.1.5)/ handling (“Hxx” – 7.1.6) and Segregation (“SGxx” – 7.2.8) respectively. This modified system also results in a series of consequential changes throughout the other sections.

Required training for shipping DG by sea »

As expected, there is an exemption for Marine Pollutants in quantities of 5L/5kg, or less, net per package or inner Continue Reading…

IMDG Code Updates

Amendment 36-12 of IMDG code finalized
Just in time for the Holidays

The IMO’s Maritime Safety Committee has adopted Resolution MSC.328(90) finalizing Amendment 36-12 which updates the Volumes 1 and 2 of the 2012 IMDG version. These changes become mandatory January 1, 2014. Implementations can be made in part or in whole on a voluntary basis from January 1, 2013 thru December 31, 2013. Amendment 36-12 includes revisions, and additions required for shipping specific substances. In particular, Part 7- Transport Operations has the most substantial changes.

Some of the key changes are as follows:

  • Stowage and segregation provisions including rules separating Cargo Transport Units (CTU) and Vessel Types (7.3, 7.4, 7.5, 7.6, and 7.7)
  • Foodstuffs segregation rules have eliminated the categories “away from” and “separated from” and now have specific storage distance requirements (3.0 meters) when Class 8 or Class 6.1 substances are being transported in the same CTU. (1.2.1)
  • Keep away from heat has now been changed to “Protected from sources of heat” (7.1.2). Specifically this indicates a distance of 2.4 meters away from heated ship structures.  Also there is mention of protecting CTU’s stored on deck, from direct sunlight requiring them to be shaded.

10 new UN Numbers have been added to the Dangerous Good List and include:

  • UN 3498 Iodine Monochloride Liquid (a red liquid that reacts violently with water)
  • UN 3499 Capacitor (articles intended to store electrical energy)
  • 6 new substances under UN Continue Reading…
Shipping Something Less Familiar — Bromine

What does one do when the need to ship something outside the realm of “ordinary” arises?

Last month I had to ship a couple of small bottles of bromine for a client. It was more involved than I originally expected.  Before even getting close to the bottle, I wanted to know what was so bad about it. Why is bromine hazardous?

I read through the MSDS to get an idea of what I was about to work with. This shipment was going by ocean so I also had a look at the IMDG code. According to IMDG, it has an extremely irritating odour, is a powerful oxidant, and is highly corrosive to most metals. Also, it is toxic if swallowed, by skin contact or by inhalation. Furthermore, it can cause burns to skin, eyes and mucous membranes. To say the least, it is pretty nasty stuff.

Here is the classification:
UN 1744, BROMINE, CLASS 8(6.1), PG I

As you can see, it is Packing Group I material. I went to IMDG packing instruction P804 to see what was required for packaging and found that it read completely different than the normal P001 and P002 that one frequently sees. This instruction lists four possible ways that this material can be packaged, all varying depending on what type of inner package is used to contain the actual liquid. To give you an idea, Part 1 refers to using Continue Reading…

Single Packaging
Minimum Height of UN Numbers on Packages

Anatomy of a Box - UN Packaging

Update to UN Number Minimum Height

Are my eyes getting better with age or did something change? Something changed.

New to the regulations this year is a statement regarding the size of text on labels for dangerous goods. Both IATA (Air) and IMDG (Marine) have made changes to reflect the UN Model Regulation that become mandatory as of January 1st, 2014. Please reference “UN Model Regulations: 17th Edition; Section 5.2.1.1 (Vol 2. pg. 139)”, “IATA: 54th Edition; Section: 7.1.5.5 – Size (pg. 619)” and “IMDG Code: 2012 Edition; Section: 5.2.1.1 (Vol 1. pg. 244)” to find the following information.

As of January 1, 2014, mandatory size for “UN number” and letters “UN”:

UN Number Measurement

Some things to note:

  1. The way this is written is such that the UN number and letters “UN” MUST be at least the size specified above whereas other package markings SHOULD be that minimum size.
  2. Other package markings include the proper shipping name, technical name, the word “Overpack”, and any other markings.
  3. For IMDG, cylinders marked in accordance with the 2010 version of IMDG are acceptable until no later than July 1st, 2018 (and only if marked by December 31st, 2013), otherwise the sizing requirements must be followed.

New UN Number Measurements