Why You Need the Most Updated Regulatory Texts

The Bible, Shakespeare and Transport Regulations

“Woe is me” is a phrase heard by many. It basically means someone is unhappy or distressed. The Bible uses this phrase in several locations including Job 10:15, Isaiah 6:5 and Psalms 120:5. Shakespeare later used this same expression when writing for his tragic character Ophelia in “Hamlet”. Existing and operating in the world of regulations can also bring on this feeling. It is difficult enough learning the basics of any regulation, but to truly “know” it takes time, patience and work. This process is complicated by the fact that many regulations change. Is it really necessary to have the newest, latest regulation? To answer that question it is time to look to the regulations.

International Air Transport Association (IATA):

For many, these are the Air Regulations. In this instance, the regulation is updated YEARLY. A new edition goes into effect on January 1st of any given year and ends on December 31st of that same year. The Regulation is currently on its 56th Edition. To showcase some of the changes that could apply to a variety of shippers, please read the following:

  1. The List of Dangerous Goods has new entries and/or updates to existing substances
  2. Packing Instructions for Lithium Batteries was updated to include not only a change but also a new addition
  3. Section 7 – Marking and Labeling for Limited Quantities has new information

Continue Reading…

Safety Data Sheets (SDS)
Looney Tunes, “Of Mice and Men,” and Safety Data Sheets

Which way do I go, George?

John Steinbeck’s novella “Of Mice and Men” is often a required reading for many school children. Though published in 1937 about a story of migrant workers in the Great Depression, it has many themes that are still powerful today. What many don’t know is that one of Steinbeck’s characters from this story is parodied in a classic Looney Tunes cartoon.

Of Fox and Hounds

In this cartoon, Willoughby the dog is fooled by George the fox. Willoughby is voiced by Tex Avery, while George’s voice is done by Mel Blanc.

Now what does this have to do with Safety Data Sheets or SDS? Often when tasked with writing a SDS one can feel like poor Willoughby. All of the information is available, but which way do you go. Which way do you go?

ICC Compliance Center can help and it won’t be in the way of George in the cartoon. We offer five different SDS Services.

But how do I choose which is right for me?

  1. SDS Creation: The process is simple. Send us a basic product information sheet, the raw materials SDS documents, and the countries involved and we can write an SDS for you that meets the requirements of OSHA HazCom 2012, WHMIS, European REACH, or European CLP. We even offer to sign a non-disclosure agreement to keep your product information private.
  2. SDS Reformats and Revisions: Most companies already Continue Reading…
PHMSA Withdraws NPRM

PHMSA has decided to not move forward to amend HMR 49 CFR 171-180 that would require CMTV loaders and unloaders to perform a risk assessment prior to activities and implement safety procedures based on the results.

On March 11, 2011 PHMSA published a Notice of Proposed Rule Making (NPRM) based on their regulatory assessment, public comments and the completion of a supplementary policy analysis to address risks associated with loading and unloading operations. Also included in this proposal was additional training and qualification requirements for loading personnel.

PHMSA’s regulatory assessment cited “human error” as the reason for most cargo-related accidents. This decision was based on a 10 year study of CMTV incidents between 2000 and 2009. The study claimed that the human factor was attributed to inattention to detail while loading or unloading, attendance requirements, leaving valves in the open or closed position, failure to segregate incompatible materials, and improper hose connections and filling practices that result in over-pressurized CMTV’s. Over 3,500 of these incidents during the study period resulted in a total of $68 million in damages.

Public comments to the proposed amendment regarding performing risk assessments expressed concern over redundancy by facilities and carriers, as well as the record-keeping efforts for such a task, declared as “burdensome”.

Comments on PHMSA’s recommendation that operators perform an annual refresher under direct observation of actual duties and drills was strongly opposed Continue Reading…

IATA Posts Addendum I to 55th Edition

pdf Addendum I to the 55th Edition (PDF) download

In keeping with past practice, IATA has issued a late year 2013 (December 26) Addendum I to the 55th Edition of the DGR, in effect January 1, 2014.

Some significant changes in the DGR include:

  • Section 3.9.2.6 conditional extension of shipping lithium batteries tested according to Rev. 3 of UN s.38.3
  • Section 1.4.3.1 regarding passenger awareness is now mandatory (“must” replaces “should”)
  • SP A807 excludes hay, straw or (UN1327) from regulation if it’s dry & uncontaminated
  • PI-101, 562, 953, 965, and 968 have had revisions for content and editorial changes – e.g.

    (Note that the page reference in Addendum I regarding PI-953 should read “page 546…”!)

  • Section 7.1.5.5 clarifies the use of ground/sea Limited Quantity marks in relation to the LQ requirements of IATA
  • Colour requirements are modified for 5.1 (removes “black-on-red” option) and 5.2 (permits black-on-red” option for upper flame portion) labels

In addition there are so some editorial changes (e.g. correcting the reference to Package Use Markings- 7.1.4.1 found in various packaging instructions and sections 10.7.1.3.1 & 2; options for locating “IB” on the Shipper’s Declaration – Section 8.1.6.9.

There are also changes to State and Operator variations as reviewed below.

FedEx to extend edit checking software requirement:

One of the most significant changes for non-US shippers will be the elimination of FX-12 and the simultaneous extension of FX-18 to shipments originating anywhere. As of May 1, 2014 Continue Reading…