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…
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.
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:
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…
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.
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 220.127.116.11 states that 5.0.2 through 5.0.4 must be met, except for 18.104.22.168, 22.214.171.124, 126.96.36.199(f), 188.8.131.52.(g) and 184.108.40.206.2. Section 5.0.2 is the general packing requirements. The performance test requirements for a package, also known as UN specification packaging, section 220.127.116.11 does not apply as well as 18.104.22.168. After reading these sections, does this mean the shipper can use their package? Not quite, there is another section to read – 22.214.171.124. 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…