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 It used to be in the Regulations that over 4000kg from one shipper could display UN numbered placard but it was repealed recently.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…
Prop 65
Proposition 65 List Updated – Again

California Prop 65 Updates

Sometimes I feel behind in the regulatory world. It is just a fact that regulations often change faster than one has time to process.  A good case for this is California’s Proposition 65. Not only are there multiple changes for how to represent substances that are on the list, but the list itself changed in May 2018.  For more information on “how to represent” and the August 30, 2018 changeover date, take a look at ICC’s blog found here

To refresh your memory, the Safe Drinking Water and Toxic Enforcement Act of 1986 is the official name for California’s Prop 65.  The list has to be revised and republished at least once per year.  California’s Office of Environmental Health Hazard Assessment (OEHHA) is the agency responsible for Prop 65 implementation.  They consider adding chemicals to the list when some other “authoritative body” makes a determination regarding a substance’s ability to cause cancer, birth defects or other reproductive harm. Shown below are all of the new substances that were added and or removed by month. They are listed by name, type of toxicity and Chemical Abstracts Service Registry Number (CAS).

Now would be a good time to see not only if you are up to date on the new required “warnings” but if any of your products or substances were added to the new list.

Proposition 65 – Continue Reading…

Prop 65
California Proposition 65 Warnings – After August 30, 2018

California horizon

California Proposition 65 Update

By now, you may or may not have heard the Prop 65 regulation in California was ‘recently’ updated. Wait, what? Prop 65 was updated? Yes … Yes it was. In August of 2016, the California ‘Office of Administrative Law adopted amendments to Article 6, for Clear and Reasonable Warnings, in the California Code of Regulations’.

The goals of the amendments were to make the necessary warnings stand out more, to give the public more information on what chemicals they are actually being exposed to, to update information to be more in-line with current technology, and to update responsibilities for companies. The changes will be fully in force at the end of this summer, August 30, 2018.

What do the new warnings look like?

The new warning requirements not only require companies to list at least one specifically listed chemical by name, but they also introduce a pictogram component to warnings. A bright yellow exclamation mark triangle.

As an example, a previous liquid chemical product perhaps was sold in a 5 gallon (18.9 Liter) container. The container was big enough to have a fairly large sized label on it, and the product was known to contain Toluene, Naphthalene and Benzene.

Those three chemicals are listed on California’s Prop 65 list as known to cause developmental harm, male reproductive harm, and/or cancer.

Prior to the 2016 amendments, the statement you would Continue Reading…