It is January and all of the new or updated transport regulations are in full swing. This includes the new IATA addendums and IMDG Code corrigenda that were recently published. That leaves many tracking down what changed in and how those changes could impact business. Add to that dealing with the complexities that come with shipping lithium batteries and many people end up feeling confused like Vincent “Vinny” Barbarino on “Welcome Back Kotter”. Check out that memory.
Here is my attempt to simplify the placarding and segregation requirements as they now stand for lithium batteries. Let’s take a look at each topic and regulation to sort things out.
49 CFR – US Ground
Placarding (§172.504): Class 9 materials are found on Table 2. This indicates that when the gross aggregate weight of the materials in the transport vehicle reaches 1001 pounds (454 kilograms) placards would be needed. In Paragraph (f)(9) there is an exception. The exception tells us that placards are not needed for Class 9 materials shipped domestically. Easy right? Now this paragraph also tells us that should you use a bulk packaging of batteries, we would be required to mark the identification number on an orange panel, a white square-on-point configuration or a Class 9 placard.
Segregation and Separation Chart of Hazardous Materials (§177.848): There is currently nothing in this section of 49 CFR to indicate batteries should be segregated or Continue Reading…
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Check back weekly, the helpdesk rarely hears the same question twice.
Location of the To/From Address
Q: Can the name and address of the shipper and/or receiver be on top of packages of hazardous materials?
A: For 49 CFR only 1 address is needed and for air you would need both. Ocean doesn’t specifically mention addresses but we tend to include one since most carriers are going to ask for it. None of the regulations actually state where they MUST go. In some of our older trainings it was indicated that the addresses had to be near the name and number. I’ve tried to correct that.
For Air – Section 18.104.22.168(b) – both addresses “located on the same surface of the package near the proper shipping name mark, if the package dimensions are adequate“
49 CFR – Only one address is required per 172.301(d)
IMDG – There are no set guidelines for including addresses in Section 5.
New Segregation of Lithium Batteries
Q: Do lithium batteries have to be segregated?
A: It depends on the mode of transport.
In 49 CFR and IMDG 38-16, there are no segregation requirements for batteries. There could be information on a batteries SDS that should be followed.
For Air, in the new 59th edition of IATA or as some call it the 2018 version, there is some Continue Reading…
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.
UN Numbers on Explosive Placards
Q.Can the UN number be added to a class 1.4 placard shipping UN0323 ground in the U.S?
A. 49 CFR 172.334(a) States no person may display an identification number on Explosives 1.2, 1.2, 1.3, 1.4, 1.5, or 1.6. In this case 0323 is classified as a 1.4, So it cannot display the ID number.
Q. Section 22.214.171.124.1 has changed with the Dec 2017 Corrigenda to the IMDG. Why would you need to put a proper shipping name on a CTU when a placard is all that is really required?
A. First of all that section speaks specifically to 3 situations where information beyond a placard is required. The 3rd one really doesn’t exist anymore, but the first 2 do. The first is when you have a TANK cargo transport unit. Tanks as defined in Section 1.2 are those that are portable tanks, road tank-vehicles like gasoline highway trucks, and rail tank-wagons which are those rounded rail cars that you see. The second is when you have bulk containers. For either of these situations a placard is needed as well as the PSN. Given the corrigenda the height Continue Reading…
One of the great services offered by ICC Compliance Center to our customers is our Regulatory Helpline. Current customers can call in and have basic questions answered for free. Our Specialists are trained in all of the transport regulations for the US and Canada. We also answer questions surrounding HazCom2012 and WHMIS 2015. A great benefit of our service is getting the customer a “right” answer. Occasionally it may require some information gathering, but we still give you an answer. Being relatively new to our Helpline, I tend to take a bit longer to get an answer.
I mention this because of an interesting question that came in last week. A customer called and posed the following question:
If I want to move a container of oxygen in my personal vehicle, does [my vehicle] have to be placarded?
On the surface this seems easy enough to answer, but in reality that is not the case. As I discovered a good bit more information was needed to formulate a “right” answer.
Answer Step 1:
What is meant by “a container of oxygen”? This information is needed for several reasons. We have to determine if what the caller has is truly a hazardous material/dangerous good. For example, is it pure oxygen or is it a blend of oxygen and nitrogen similar to a SCUBA tank? One is much more dangerous in the event of Continue Reading…
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…
The headlines are frightening – Ebola virus, one of the most deadly viruses known, has broken out in several African countries. Medical authorities are concerned that it could spread beyond that region, carried by travellers all over the world. Laboratories in North America and Europe are on alert for patients showing suspicious symptoms. This, in turn, means that samples and specimens must be transported for testing and verification. How can the medical community deal with transportation of such high-risk materials?
Ebola virus is considered a “hemorrhagic fever,” which affects the blood system. Its virulence is astonishing, with a fatality rate of between 50 and 90 percent. Combine this with the ability to be transmitted through casual contact, and the lack of specific vaccines or treatment, and it’s understandable why Ebola is such a feared disease. Therefore, it is all the more essential that transporters make sure that they comply with all legal and safety requirements.
Ebola virus is one of the few pathogens that is always classed as a Category A infectious substance, even in its uncultured form. The shipping description will be:
Identification number – UN2814
Shipping name – Infectious substance, affecting humans
Class – 6.2 (Infectious substances)
Packing group – Class 6.2 is not assigned packing groups
Procedures for shipping samples suspected of containing the virus will depend upon the regulations involved – the Hazardous Materials Regulations (HMR) for Continue Reading…
Transport Canada published in Canada Gazette, Part I, the amendment titled “Part 4 Dangerous Goods Safety Marks”. Notable changes include:
introduction of overpacks
modifications to the use of the DANGER placard
introduction of new safety marks (3)
new proposal for placarding large means of containment
Let’s start with the overpacks. Currently under TDG, overpacks are not recognized although they are being used. And this is causing enforcement issues. TC considers an overpack to be a large means of containment. The definition for overpacks will be added to section 1.4 of TDG. Safety marks for overpacks is covered in section 4.10.1. As part of this section, when the overpack has a capacity ≥ 1.8 m3, then safety marks must appear on two opposite sides of the overpack.
All the safety marks are in the UN Model Regulations, ICAO Technical Instructions, IMDG Code and 49 CFR.
The requirements for placards will undergo a major change. The table in TDG section 4.15 is replaced. Placards will be required on both ends and sides of a large means of containment. The subsidiary placard requirements do not change. UN numbers on a placard or orange panel will be required when an ERAP is required, or the dangerous goods are liquids or gases in bulk. IBCs (intermediate bulk containers) will be permitted to only have 2 placards with UN Continue Reading…
Transport Canada published Amendment 11 in the Canada Gazette, Part II on December 5, 2012. In Amendment 6 (February 2008), a number of errors were introduced. This amendment corrects those errors, and brings others into line with some changes to the Act (June 2009).
The changes in this amendment are:
definition of “person” now aligns with the definition in the Act, including the addition of “organization”,
section 1.15 150 kg Gross Mass Exemption has been changed to allow up to 6 aerosols to be transported without complying with Part 5 Means of Containment. However, the aerosols must have a valve protection cap; in addition, special provision 80 has been changed to provide consistency,
section 5.5 Filling Limits goes back to the wording prior to Amendment 6 so as to remove any confusion and misinterpretation regarding standards or safety requirements,
the placarding provisions of the IMDG Code have been placed in Part 9 Road and Part 10 Rail; this allows for the placarding under the IMDG Code which means that placarding requirements are simpler and will reduce if not eliminate confusion,
other changes are of an editorial nature or typo:
in section 2.29(2)(c), 0.2 g/L now reads 0.2 mg/L
in the restricted paragraphs of section 1.15 and section 1.16, the title for Class 4 has been corrected
in section 1.32.1, the shipping name Liquefied Petroleum Gas now reads Liquefied Petroleum Gases
So, what’s going to be coming in TDG in the next year?
Well, let’s start with an Equivalency Certificate for limited quantities. Members of the Canadian Paint and Coatings Association have an Equivalency Certificate (http://www.tc.gc.ca/tdg/permits/htm/10832-eng.htm) for the use of the new limited quantity mark. If Transport Canada is not going to have this in a very near future amendment, then why don’t they issue the Equivalency Certificate to all shippers?
Amendments 8, 9 & 10 have come into force this year. Amendment 11 was sent to the Minister on October 20 and it deals with correcting errors in Amendment 6. The next step for Amendment 11 is a consultation phase.
Amendment 12, which was reviewed last June, is a large amendment with emphasis on placarding and introduces the overpack. The comment review was completed in June and it may go direct to Gazette II.
Amendment 13 will deal with the standards and Part 5 Means of Containment. This proposal has been at Justice since June and its next stop should be Gazette I.
Amendment Q will be an update of Schedule 1 and 2. Amendment 12 was to take us to the 17th Edition of the UN Recommendations on the Safe Transport of Dangerous Goods, so why would a separate amendment be needed for the Schedules? Interesting that Schedule 3 is not listed in this proposal – typo? The next step Continue Reading…
I admit it. I am a hazmat nerd. I’m not sure exactly when I realized it. Maybe it was the first time I recited a section of 49CFR from memory during a class. Maybe it was when I decided to keep a copy of the ERG in my car so I could identify the UN numbers on placarded trucks. Regardless of when it happened, I now embrace my hazmat nerdiness… even my Facebook profile lists my occupation as “Hazmat Nerd”. Obviously, this is a great benefit when I’m on the job. I have a knack for remembering obscure requirements and knowing where to find them in the appropriate regulation. I enjoy hunting down the answer to tough questions or unusual situations. I like having customers who think of me as their go-to source for their questions.
One aspect of being a hazmat nerd is that I am always noticing things that relate to my job, even when I’m not at work (hence the ERG in my glove compartment). There was the time that I was doing some geocaching (my obsession…I mean hobby) in Buffalo. I had parked the car and jumped out to go find a cache. On my way, I had to dodge some large puddles due to a recent downpour. As I approached one of the puddles, I noticed something odd. There was a Flammable Continue Reading…