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…
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 126.96.36.199.1 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…
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…
IMDG issued an Erratum for “IMDG Code, 2014 Edition“. They have provided a link to customers to be able to download (PDF) and print it. Customers who purchased the e-reader version can access the erratum using the Internet Update/Check for Content Update function on The IMO Bookshelf. Customers who purchased the CD, electronic download and internet subscription versions need no correction.
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.
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:
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. )
Cannot be used as a replacement for inadequate, required “standardized” packaging
Is to be unopened between consignor and receiver
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.
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…
IMDG issued an Erratum for “IMDG Code, 2014 Edition“. There has been a misprint for the Class 7 fissile marking on page 261 of volume 1. They have provided a link to customers to be able to download (PDF) and print it. Customers who purchased the e-reader version can access the erratum using the Internet Update/Check for Content Update function on The IMO Bookshelf. Customers who purchased the CD, electronic download and internet subscription versions need no correction.
“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:
The List of Dangerous Goods has new entries and/or updates to existing substances
Packing Instructions for Lithium Batteries was updated to include not only a change but also a new addition
Section 7 – Marking and Labeling for Limited Quantities has new information
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.
The U.S. Department of Transportation (DOT) has been committed to ensuring that the domestic Hazardous Materials Regulations (HMR) are kept current with international standards. Since these standards are updated at the United Nations (UN) level every two years, this requires frequent amendments. The latest round of amendments has been started with the issue of a Notice of Proposed Rulemaking (NPRM) on August 25.
The NPRM has been issued by DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) as Docket Nos. PHMSA-2013-0260, HM-215M. It contains revisions necessary for harmonization with the UN Recommendations on the Transport of Dangerous Goods, the ICAO Technical Instructions for Safe Transport of Dangerous Goods by Air, and the International Maritime Dangerous Goods Code (IMDG). The comment period is until October 24, 2014. PHMSA’s goal is to ensure harmonization with the above regulations for the 2015-2016 biennium.
You can follow the links at the bottom of this article to read the proposed rulemaking or comment on it at the Federal Rulemaking Portal.
The extensive docket is about 90 pages long, and covers a number of areas for change.
HMR Significant Updates HM-215M:
Marine pollutants – the NPRM would exempt packages of small packages of marine pollutants (up to 5 Liters or 5 kilograms) from the HMR, due to the low risk for these goods in transport. Also, Chlorotoluenes will Continue Reading…