North American Rail Safety Progresses

FRA Solicits Comments on Securement NPRM

The Federal Railroad Administration (FRA) published a Notice of Proposed Rule Making on September 9 to further enhance rail transportation safety and security following the recent incidents involving derailments of rail cars carrying hazardous petroleum products. The NPRM expands upon Emergency Order 28 and updates 2001 provisions regarding securement of unattended equipment. The FRA notes that there has been an increase in rail incidents involving flammable liquids since 2009 including (but not ending with) the 2013 Lac Mégantic, QC disaster with the tragic loss of life that resulted.

The proposed rule would require formal planning, job briefing, and verification measures to ensure that trains carrying specified hazardous materials/dangerous goods are secure when left unattended on main lines or sidings when specified materials [e.g. PIH, Class 1.1, 1.2, 2.1, 3 or specific items listed in 49CFR173.31(f)(2)] are present in specified configurations.

Locomotives in particular will require an exterior locking mechanism by March 2017. Provisions are also proposed requiring attendants when equipment cannot be secured according to the regulations.

Additionally procedures will be required to verify continued securement following incidents where non-railroad emergency personnel have been involved in a response that could have affected the integrity of the securement.

Although railways will not require prior FRA approval of securement plans, the FRA must be notified of amendments to existing plans and details must be provided upon request.

The Continue Reading…

Sailing Along – Significant Changes to the IMDG Code 37-14

The next edition of the IMDG Code will soon be available for use in January 2015, becoming mandatory in January 2016. This amendment sees additions (some of which are also incorporated into IATA – see Suzanne’s Blog of August 28th) to the DG list adding UN numbers for adsorbed gases and capacitors; and re-naming air bag modules/seat belt pretensioners to “Safety Devices”.

The latter will have 2 designations: “electrically initiated”, UN3268 (Class 9); or “pyrotechnic”, UN0503 (Class 1.4) depending on the classification. Parts 1, 2, 4 & 6 update Class 7 requirements for radioactive materials. These additions and changes require a series of modifications to the other parts of the Code.

The GHS reference has been updated to the 5th edition and the revised CSC International Convention for Safe Containers (including criteria for taking units out-of-service) has been added to the General Provisions in Part 1.

Column 16 in Part 3 (“the DG list”) has been split into “a)” and “b)” with the addition of new provisions in Part 7, to list codes and for stowage (“SWxx”- 7.1.5)/ handling (“Hxx” – 7.1.6) and Segregation (“SGxx” – 7.2.8) respectively. This modified system also results in a series of consequential changes throughout the other sections.

Required training for shipping DG by sea »

As expected, there is an exemption for Marine Pollutants in quantities of 5L/5kg, or less, net per package or inner Continue Reading…

IMDG Code Updates

Amendment 36-12 of IMDG code finalized
Just in time for the Holidays

The IMO’s Maritime Safety Committee has adopted Resolution MSC.328(90) finalizing Amendment 36-12 which updates the Volumes 1 and 2 of the 2012 IMDG version. These changes become mandatory January 1, 2014. Implementations can be made in part or in whole on a voluntary basis from January 1, 2013 thru December 31, 2013. Amendment 36-12 includes revisions, and additions required for shipping specific substances. In particular, Part 7- Transport Operations has the most substantial changes.

Some of the key changes are as follows:

  • Stowage and segregation provisions including rules separating Cargo Transport Units (CTU) and Vessel Types (7.3, 7.4, 7.5, 7.6, and 7.7)
  • Foodstuffs segregation rules have eliminated the categories “away from” and “separated from” and now have specific storage distance requirements (3.0 meters) when Class 8 or Class 6.1 substances are being transported in the same CTU. (1.2.1)
  • Keep away from heat has now been changed to “Protected from sources of heat” (7.1.2). Specifically this indicates a distance of 2.4 meters away from heated ship structures.  Also there is mention of protecting CTU’s stored on deck, from direct sunlight requiring them to be shaded.

10 new UN Numbers have been added to the Dangerous Good List and include:

  • UN 3498 Iodine Monochloride Liquid (a red liquid that reacts violently with water)
  • UN 3499 Capacitor (articles intended to store electrical energy)
  • 6 new substances under UN Continue Reading…