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?
Shipping biological substances training »
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.
The new safety marks to be introduced are:
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
- table of contents for Part 2 Continue Reading…
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…
Some observations from behind the wheel:
- why do some carriers mount their rear placard holders as a square, instead of the square on point as required by the TDG regs?
- why does Canada use the DANGER placard? Other than the US, no other country has it.
- why is the limited quantity (LQ) mark changing? (see 16th Ed. UN model regs, figure 3.4.1) What was the matter with the UN number in a diamond? From an emergency responder viewpoint, the UN number in the diamond is the common sense way to do it.
- why do transit buses drive to the end of a turn lane and force their way into traffic? Under the Highway Traffic Act (HTA), the bus bay is where the bus stop is – not the end of the turn lane.
- why do transit buses force their way into the adjacent lane? The HTA only requires drivers to yield to buses exiting a bus bay.
- why do two (2) fully loaded trucks drive side by side up an incline?
- why does the driver behind you get upset when you stop for the changing light? Remember—a yellow light does not mean race through the intersection to beat the red light. (see HTA section 144)
- why do construction companies move their heavy equipment on public roads when not Continue Reading…
The placarding saga continues. Transport Canada has issued an ALERT to explain (?) the options available when a large means of containment that requires placards is loaded into a large means of transport. So if we have 2 IBC’s (class 8 and class 3) to be shipped, our options are:
Option 1: for each primary class placard and UN number, duplicate on the outside of the truck.
Option 2: utilize the table in section 4.15(1) which states that for dangerous goods in direct contact with the large means of containment, display the primary class placard with UN number; but as the dangerous goods are not in direct contact with the trailer, then the truck can be placarded with the primary class placards alone OR with the DANGER placard; use of the DANGER placard is only for more than one different class provided that an ERAP is not required or that the dangerous goods are not Class 7 or Class 1.
Transport Canada has drafted a proposal to Part 4 to clarify the issue. Apparently the DANGER placard option will disappear and the use of the primary placard with UN number will be required on the truck.