ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 1

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Placarding Bulk Truckloads

Q. My truck has 4000kgs of drums of Class 3 UN1993 in it. Truck has Class 3 UN1993 placard on it . We pick up 1 empty tote (IBC) which is Class 3 UN1993 also. Can we keep the same placard on the truck or do we need to add Class 3 only? Same with empty drums. We just need to add primary CLASS card? All transported via ground within Canada.
A.Well the drums don’t need UN numbered placards since drums are considered small means of containment. A plain class 3 placard will do to represent the drums. It used to be in the Regulations that over 4000kg from one shipper could display UN numbered placard but it was repealed recently. Totes, even empty with residue, requires UN numbered placards for liquids in direct contact with the means of containment. You don’t need to add plain class 3 placard for the drums as both the drum and tote content is hazard class 3. So technically the truck displayed the correct placard (UN1993). If the drums were empty and less than 500kg gross mass then no placard will be required; however, if you Continue Reading…
Packaging Infectious Substances

Infectious Substances Packaging

What Are Infectious Substances?

Infectious Substances are defined as substances which are known or are reasonably expected to contain pathogens, or micro-organisms including bacteria, viruses, parasites, or fungi which can cause disease in humans or animals. Section 1.4 TDG, IATA 3.6.2.1.1. They are split up into two separate categories. Category A which is capable of causing permanent disability, life-threating or fatal disease in otherwise healthy humans or animals. Category A infectious substances are either assigned UN2814 or UN2900 and are class 6.2. IATA 3.6.2.2. Category B substances are any other infectious substances that do not meet the criteria for inclusion of Category A. They are assigned the UN number 3373.

Packaging Infectious Substances

For Category A substances, Infectous Substances Affecting Humans or Animals Only, strict performance criteria should be met on the packaging including drop testing, puncture testing, a pressure testing, and a stacking test. The configuring is often referred to as the triple packaging system. When packaging Category A substances, you must start out with a leak-proof primary receptacle. If the substances are shipped at room temperature or higher, these receptacles must be made of glass, metal, or plastic. The primary receptacles must then be placed into a leak-proof secondary packaging, either wrapped individually or separated to prevent any contact.

Both the primary and secondary packaging must be able to withstand an internal pressure of at least 95 kPa. If 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…

Must vs. May

In the regulatory world, things are not always as clear as they seem at first glance. One example of this is the use of the words must, may, shall and should. They seem pretty straightforward, but if interpreted incorrectly, they could lead you down the road of non-compliance, or leave you scrambling to comply with something that is not actually required.

Let’s imagine we are shipping an urgent package containing a sample of a virus that is included in division 6.2. We are shipping it by air according to the IATA Dangerous Goods Regulations. We have packaged the sample according to the regulations but when we go to label the package, we find that someone used the last label on the roll. We go hunting around the office to see if we can find more labels. The only 6.2 labels we can find are some that look similar to the ones we have always used, but they are not exactly the same. The labels that we normally use have text referring to notification to the public health authority in case of damage printed in the center. The labels we just found don’t have the text. Can we use them? Let’s see what the regulations say…

Section 7.3.15 of IATA shows a 6.2 label without the text. Below the picture of the label it states: "The Continue Reading…