ICC's Regulatory Helpdesk
Regulatory Helpdesk: Sept 24

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.

Limited Quantity from Canada to the USA

Q: I ship my material as a limited quantity under TDG in Canada. What do I need to do to ship it to customers in the US? We are also considering opening a hub in the US.
A: You will have to receive training in 49 CFR. Even though there are many similarities between the 2 regulations they are not exact matches. You may be able to use some reciprocity agreements in regards to transborder shipments. A hub based in the US will definitely have to have 49 CFR training.

New testing, now what?

Q: We just ran some testing on one of our products. It has been shipped as UN2468 in the past. However, the test report O.1 came back and said our material is not an oxidizer. What does that mean for the next time we ship the product?
A: If you have proof that your product is no longer a hazardous material, then you do not have to ship it as such. It does not meet the classification criteria set out in 49 CFR starting in §173.50.

TDG wallet card requirements

Q: I have worked with a courier company for Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: May 21

Limited quantities, manufacture expiry dates, regulated or not regulated, and reclassifying flammables to combustibles.

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.

Limited Quantity Limits (TDG)

Q. Customer called and asked if he can ship a box with 16 liters of UN1219 in inner containers as a limited quantity through ground in Canada.
A. The max according to the TDG is 1 L for limited quantity, so they can’t ship limited quantity.

Manufacture Expiry Dates

Q. Can you tell me if both the manufacturer and expiration dates are required to be on each label? Or if we have the option of just stating the manufacture date and verbiage that states the product is good for two years after the manufacture date? Also, would you happen to know which regulatory agency monitors these types of things?
A. The expiration date or manufactured date are not requirements of a GHS label. OSHA and The Globally Harmonized System of Classification and Labelling of Chemicals considers this supplementary Information, which is permissible as long as it doesn’t contradict any other information on the label, but they are not required components of the label.

Combustible materials (49 CFR)

Q. We have some drums of a material classified as NA1993 Combustible Liquid and only ever Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: May 14

Classification, Personal Electronic Devices, Consumer Commodities, and Preparing Hazardous Materials for Transport

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.

Classification Question

Q. I’m trying to verify how to ship a drum that has a flashpoint of 170° F and is a marine pollutant to Japan. My company has to get it to the port and then it will go on a boat. The SDS says it is a combustible liquid NA1993 but Japan doesn’t have that designation.

Do I ship this product as UN1993?

A. No. The flashpoint of 170° F puts you well beyond the limits of any packing group for a Class 3 flammable liquid, n.o.s. under UN1993. The flashpoint does qualify as a combustible liquid but it would only be regulated in a bulk packaging.

Your drum is not bulk. Technically the “flammability” aspect of this is now a moot point. Since you know the material is a marine pollutant, shipping it as UN3082 would be the best bet.

Personal Electronic Devices

Q. I have an employee flying from the US to Greece with a satellite phone so he can have access to the office and home while he is on vacation. Does he need to do anything different or follow any regulations?
A. No. Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: May 7

IATA declaration, limited quantity labels, training requirements, and placarding

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.

Listing Overpack on a Declaration (IATA)

Q. Caller needed to clarify what should be listed on an IATA declaration for an overpack.  I have 2 overpacks of the exact same thing. The overpack is 2 drums inside an outer overpack box. Each drum holds 18.9 L. I have it listed as “Overpack Used x 2”. For the alphanumeric identifier for each it is “Box 1” and “Box 2”. How do I list the “total quantity per overpack”?
A. Take a look at Figure 8.1.L. It shows multiple identical overpacks. The example shows 200 boxes each with a weight of 0.2 kg in each overpack. It then lists the total quantity per overpack as 40 kg, which is the result of the 200 boxes multiplied by the 0.2 kg.

For her question then it would be 2 drums multiplied by the volume of 18.9 L. The total quantity per overpack is then 37.8 L.

Limited Quantity Labels

Q. Caller was on our website and had a question about LQ marks/labels. He has a distributor in Canada that will be shipping fire extinguishers to a location in the US from Canada. They use the LQ label in Canada Continue Reading…
Regulatory Helpdesk: November 13, 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.

WHMIS Label Size Requirements

Q. Is there were size requirements for WHMIS labels?
A. No, the HPR does not mandate a size requirement other than saying it has to be legible. But, what does legible mean? As a general rule of thumb, which we have developed from reviewing many different labeling regulations is 10 mm for one side of the pictogram, and 2 mm for the font size (1.6 mm for a worst-case scenario).

IATA Special Provision

Q. What does  IATA’s Special Provision A191 mean?
A. It was determined that SP A191 means if you have a manufactured article with less than 5 kg of mercury in it (like a thermometer) then you don’t need the Class 6.1 label for mercury’s subsidiary hazard and you don’t have to list the 6.1 subsidiary hazard on the shipper’s declaration.   From what we can tell that only applies to UN3506 which is Mercury contained in manufactured articles.

Quantity Limits – TDG (Canada)

Q: What does the quantity limit in TDG Columns 8 & 9 represent in terms of Passenger conveyance restrictions- package, consignment, …?
A: Good point which many find confusing. The answer is in the often-overlooked Continue Reading…
Shipping by Road
UN3363 Dangerous Goods in Machinery or Apparatus

Red semi truck on highway

When Can I Use UN3363?

What does one do when there is device or piece of equipment (“apparatus” or “machinery”) that is not intended to consign dangerous goods or hazmat (DG) specifically, but requires a certain quantity as part of its function or as a residue from earlier use or testing?

Many consignors can take advantage of UN3363, Dangerous Goods in Machinery (or Dangerous Goods in Apparatus), Class 9 – with (depending on the mode) a potential relaxation of packaging, marking, and documentation requirements.

Restrictions

There are basic conditions that must be met, however, to use this entry. Restrictions on using this entry exist in special provisions (SP) or packaging requirements in national and modal regulations.

Function – Not “Deus EX Machina”

This term is derived from the classical theatre world- but could represent an effort to use a “loophole” or take advantage of an unintended provision – for a discussion of the term see:
https://en.wikipedia.org/wiki/Deus_ex_machina

The apparatus or machinery’s primary function cannot be to “deliver” the DG in question. That is the item must have a purpose other than solely to act as a container to get the DG to the destination; and it must not be intended that the DG is discharged from the item.

Exclusions – Wisdom Begins in Calling Things by Their Proper Name

… with apologies to Confucius

Any article which has an appropriate UN number/shipping name already assigned must be shipped Continue Reading…

New Limited Quantity Mark

Transport Canada announced at the COSTHA annual forum that they are moving quickly to update the regulations to permit the use of the new limited quantity mark:

New limited Quantity Mark

Click here to see our limited quantity labels.

Marie-France Dagenais, Director-General of the Dangerous Goods Directorate at Transport Canada told the forum that equivalency certificates will be issued to shippers that apply for them, to allow them to use the new mark. It is expected that an amendment on dangerous goods safety marks will be published in the Canada Gazette, Part I, sometime in June of this year.

Shipping Limited Quantities by Air

When shipping limited quantities (LQ), you do not need to use a UN specification package. But what specs should the package you want to use meet? IATA section 2.7.6 states that the shipper must do a series of drop tests and a 24 hour stacking load test before using the package. Does this then mean that the shipper is done?

Section 2.7.5.1 states that 5.0.2 through 5.0.4 must be met, except for 5.0.2.3, 5.0.2.5,  5.0.2.11(f), 5.0.2.11.(g) and 5.0.2.14.2. Section 5.0.2 is the general packing requirements. The performance test requirements for a package, also known as UN specification packaging, section 5.0.2.3 does not apply as well as 5.0.2.5.  After reading these sections, does this mean the shipper can use their package? Not quite, there is another section to read – 2.7.5.5. Here it states that the outer packaging must meet the construction requirements of section 6.2. For combination packages, the most used outer packaging is the fibreboard box. In section 6.2.12, it states that the box must be subjected to the Cobb test. This is a test to determine the water absorbency of the fibreboard box, where the increase in weight cannot exceed 155 g/m2.

Are shippers aware of this requirement? And how are they to determine this when selecting a packaging to use? It might just be easier to use a UN specification package and send the shipment Continue Reading…