Recognizing Technological Evolution while Maintaining Safety & Security
Explosives Regulations (ER) – Ports & Wharves
The Explosives Safety & Security Branch (ESSB) of Natural Resources Canada, and Transport Canada, have issued a Gazette I (CG I) proposal to amend their respective Explosives Regulations (ER, under the Explosives Act), and the Cargo Fumigation and Tackle Regulations (CFTR, under the Canada Shipping Act).
The initial reason for the proposed amendment is to remove reference to the express requirement to use quantity/distance principle (QDP) restrictions and ESSB Inspectors from the CFTR. A more modern approach of quantitative risk assessments (QRA), based on actual probable hazards following, methodology authorized by the ESSB (Chief Inspector of Explosives), would replace the more rigid QDP.
QDP, currently covered in CAN/BNQ 2910-510/2015, were established mainly for fixed manufacturing/storage facilities and specifically exclude transportation activities from the scope of the standard.
The proposal also provides for having qualified individuals, not just ESSB Inspectors, determine the risk following an approved QRA methodology. The requirements will appear in a new ER section 203.1 instead of the current CFTR section 155(2) & (3).
It is expected that international trade and commerce will be improved without sacrificing safety or security under this proposal.
Explosives – Other Amendments
The CG I amendment proposes to also include ER changes under the topics of:
Eliminating or relaxing license requirements for certain “low risk” explosives (7 components);
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.
Q. What edition of the IMDG should I be using?
A. The customer would still need the 38th edition to get him through all of next year. The new 39th edition will be published at the end of 2018 but it can’t be used at all until Jan 1, 2019. Even then the 38th is still a viable option.
Placement of the Consignor’s Certification Statement
Q. Can the Consignor’s certification appear on a second page or on the back of the shipping document?
A. Yes, if there is no other non-DG information intervening when using the phrase in TDGR 3.6.1(1)(a). This phrase requires that the certification appear below the information specified in 3.5. The Transport Canada FAQ page indicates that the “consignor’s certification may appear on the back of the shipping document as long as it is after the information required under Section 3.5“.
Limited Quantities Under IMDG
Q. Can limited quantity provisions be used to ship under the IMDG Code?
A. Yes, but you should have IMDG Code training or consider a re-packing service if you are not trained, since the requirements are not the Continue Reading…
Here it is January of 2015 and I’m so lost and confused in this world of Hazard Communications. Is there a set of directions or a map through this land of labels, safety data sheets and classifications? Daily, phrases such as “UN Model Regulations”, “Purple Book”, “HazCom2012”, “GHS Classification” and “June 1, 2015” are tossed around in conversation with great emphasis.
Are these the same?
Are they different?
Can you explain it?
Luckily, ICC Compliance Center is here to help with you navigate. There are multiple resources in particular that can help.
Here is just a sample of what we have to offer:
Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
Also known as the “Purple Book”: This is the UN Model REGULATION that outlines exactly what GHS is. It explains the comprehensive changes to how customers are informed of hazards, by finally establishing an internationally uniform system for classifying hazardous chemicals, labeling them and providing Safety Data Sheets (SDS). Encompassing many sectors, including workplace safety, consumer sales, transportation, and environmental protection. This is updated every two years so be sure to use the correct edition! Use this to see if you are on the correct continent of your map.
Just HazCom: Hazard Communication Regulation
Here is “HazCom2012” or the “US GHS”. “Just HazCom” has the parts of 29 CFR 1910.1200 used to ensure that the hazards of all chemicals produced Continue Reading…
The Occupational Safety and Health Administration (OSHA) has issued a correction and technical amendment to the March 26, 2012 final rule incorporating the GHS recommendations into the Hazard Communication Standard.
The majority of the corrections are to references originally missed in the original final rule. Other corrections include correcting values and notations in table and updating references to terms (e.g. Material Safety Data sheet (MSDS) to Safety Data Sheet (SDS)).