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Hazmat Packaging Bears Rigorous Testing

Hazmat Packaging Specs

Shippers of Hazardous Materials (or Dangerous Goods) know that the packaging they use has to meet certain specifications and pass standard tests before it can be considered appropriate for the hazardous shipment. Most training classes will explain that the package design must go through various tests to simulate conditions they may encounter during transport.

I started to wonder if users of the packaging really understand the conditions these designs are put through. No, it doesn’t look like this…

… but a few of the tests are quite rigorous! Below are some examples.

  • Drop Test – Drop testing is done on five test samples. The samples are prepared as they are intended to be used by a shipper. Each sample is dropped on a different surface of the package (top, bottom, long side, short side, and corner) from a height between 2.9 and 5.9 feet (0.8 – 1.8 meters), depending on the packing group of the materials that are going to be authorized. Any release of sample material during any of the drops is considered a failure.
  • Stack Test – Stack testing is done on three test samples. The samples are subjected to force that is equivalent to the weight of identical packages stacked to 3 meters. The samples must withstand the weight for 24 hours without leaking or showing any damage or distortion that could reduce Continue Reading…
OSHA Update
Are you a One Percenter? Enforcement Delay of PSM 1% Concentration Policy

Recently in popular culture and the news the term “one percenter” can be heard. What does that mean, to be a one percenter? According to one urban dictionary site a one percenter is defined as a member of the top one percent of a population as decided by wealth. The term comes from the same rationale as being in the ninety-ninth percentile which means there is only one percent of the population who is better. So do you fall into the one percenter club? You might be surprised at the answer.

For those who are not familiar with the new one percent policy, let’s review some terminology and information on this standard. OSHA Standard 29 C.F.R. § 1910.119 which is the Process Safety Management of Highly Hazardous Chemicals “contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.” Part of this standard is Appendix A (found here) which contains a listing of toxic and highly reactive hazardous chemicals that could present a potential for a catastrophic event at or above the threshold quantities. In 1991 the PSM Final Rule was published. It was followed by a series of letters of interpretation and compliance directives. In 1994, OSHA further defined the policy. The letter from 1999 basically stated:

“chemicals listed in Appendix A without minimum Continue Reading…

Prop 65
Extra! Extra! Read All About It: California Proposition 65 List Updated!

A few weeks ago I had the opportunity to see Disney’s Broadway musical “Newsies”. The show is about the 1899 strike of New York City’s Newsboys. For those that aren’t familiar with Newsboys, these are the young men who would stand on the street corners in big cities selling the daily newspaper to the people walking past. In the event of a big news story, publishers would print an “Extra” edition. On these occasions the Newsboys could be heard shouting, “Extra! Extra! Read All About It!” to let people know something big had happened and that they had the news on hand.

Consider this blog my “Extra! Extra! Read All About It!” story in regards to California’s update to the Safe Drinking Water and Toxic Enforcement Act of 1986 or as it is more commonly known Prop 65. The list was updated on April 22, 2016. You can download the full list here. The biggest change for the list is the addition of Styrene (CAS No. 100-42-5). It is now listed as a substance “known to cause cancer”.

Styrene was included on the “Notice of Intent to List” published in February of 2015. Open comments were taken and the final decision was published and went into effect on April 22, 2016. The 2015 proposal was made under the authoritative bodies listing mechanism. Under this mechanism, a chemical must be Continue Reading…

PHMSA
Correction to HMT in 49CFR

On Monday, April 25, 2016 the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a correction to the 49CFR Hazardous Materials regulations in the Federal Register.

The correction states:

“In Title 49 of the Code of Federal Regulations, parts 100 to 177, revised as of October 1, 2015, on page 269, in § 172.101, in the Hazardous Materials Table, for the entry ‘‘Phenylmercuric compounds, n.o.s.’’ add ‘‘G’’ in the first column.”

The federal register notice can be viewed here: https://www.gpo.gov/fdsys/pkg/FR-2016-04-25/pdf/2016-09615.pdf

The “G” in the first column of the Hazardous Materials Table (HMT) identifies proper shipping names for which one or more technical names of the hazardous material must be entered in parentheses, in association with the basic description. The technical name(s) must be shown on package marking and shipping papers. Failure to comply with the corrected information can result in non-compliant shipments.

OSHA Labeling
Disney, Dwarfs and Workplace Labels

It was recently announced that Disney was re-releasing the classic animated movie “Snow White and the Seven Dwarfs”. The commercial started with the dwarfs singing their classic song “Heigh-Ho”. In this tune, the cute characters of Dopey, Bashful, Sneezy, Happy, Grumpy, Sleepy and Doc all sing about coming home from working all day digging in the mine. To remember these characters, watch and listen here.

As the scene starts, I can’t help but notice there are no OSHA workplace labels anywhere. In the new OSHA Hazard Communications Standard 1910.1200 there isn’t much guidance on how to handle workplace labeling. The regulation states “the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked”. The regulation goes on to say use the same information that is found on the shipped containers or use a “Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.”

Many Employers may feel overwhelmed trying to figure out what to have in a workplace after reading the regulation. Let us help. We offer the GHS Workplace Labels (Orange System).

Orange System GHS Workplace Labels Available Continue Reading…

OSHA
OSHA, Newspapers, and Pictures

Before the age of television, cell phones and the internet, news was conveyed via newspapers. In 1911, Arthur Brisbane, a reporter and editor in New York City, used the expression “use a picture. It’s worth a thousand words.” Today, that phrase has been adjusted and is more commonly known as “a picture is worth a thousand words.”

Keep this quote in mind for the next few seconds. Close to my home is a gas station that sustained some damage from a recent summer storm. The awning over the gas tanks had collapsed and was being replaced. As my husband and I drove past the station, I took the following picture.

Fall Prevention

Now my husband and I both work in the safety field, so you can imagine the conversation we had after seeing this. The comment that struck me most was “I’d rather terminate a person for working at elevation without fall protection than have to tell their family that they died.” Think about that statement. It is powerful, honest and true.

For the past few years one of the top ten OSHA violations is in the area of Fall Protection. In 2014, it was the number one violation. Per OSHA 1926.501, Employers must design the workplace in such a way as to keep Employees from falling. Falling can be from overhead platforms, elevated work stations or even into holes.  In fact, the regulation Continue Reading…

TDG
Know Your Exemptions – the 500 Kilogram Exemption (TDG Section 1.16)

Like most regulations based on the UN Recommendations for the Transport of Dangerous Goods, Canada’s “Transportation of Dangerous Goods Regulations” (TDG) includes a number of exemptions. These provide easier and more cost-effective ways for shipping low-risk materials. However, each exemption needs to be carefully studied. If you don’t comply with all the requirements, you are not entitled to any part of the exemption.

One of the most misunderstood exemptions in TDG is found in section 1.16, the “500 Kilogram Exemption.” The provisions in this section originated in a long-ago series of permits intended to make shipment of small quantities of dangerous goods easier. Over the years, changes to this section have reduced its effectiveness; it still may be a helpful exemption in certain specific cases, but it must be used appropriately.

The first myth about the 500 kilogram exemption is that it is a total exemption from all requirements of TDG. This is far from the truth. At best, the exemption relieves the shipper from Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks) and Part 5 (Means of Containment). All other requirements of TDG will still apply. This includes, for example, the requirement that the carrier and all handlers must be TDG-certified. At one point, receivers were exempted from Part 6, Training, but this relief was removed in an amendment several years ago.

Obviously, the exemption only applies Continue Reading…

OSHA HazCom 2012
Time Requirements Under OSHA HazCom 2012

As a new order for classifications and label text is begun, the song “Time Is On My Side” by The Rolling Stones comes to my mind. Take a listen here to remind yourself of the rhythm and lyrics. I and many other SDS and Label authors approach each new request with optimism and the hope that a perfect world exists. Believing all of the information needed is supplied by the client, the data needed is readily available and the time needed for work is plentiful.

For any given order there could be multiple products and each product requires an SDS and Label. Each of the products is probably a mixture. In some cases the products are actually mixtures made up of other mixtures. Some of the products have trade secret claims. Taken together, this means we authors start to question what Mick Jagger is saying. Is time really on my side?

Now, clients are amazing. Any information needed requires a simple email or phone call. If they have it, then within a short period of time it is provided.

Things start to fall apart though when information just is not there. Many companies are still struggling with receiving SDS and Labels that are compliant with HazCom 2012 from their manufacturers and suppliers. When this happens, I am tasked with finding information on my own. This finding of information is the Continue Reading…

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…

OSHA Labeling
It’s What’s Inside that Counts — OSHA Labeling of Shipped Containers

Sometimes, regulations don’t give us all the answers we need. For example, many people are confused about the labelling requirements found in the Hazard Communication Standard (HCS) of Part 1910.1200 of the Occupational Safety and Health Act (OSHA). This section tells us that we must label all “shipped containers” that contain hazardous substances destined for workplace use. But what exactly is the “shipped container,” when you have inner containers inside an outer one?

The simplest form of “shipped container” is a single packaging. This is a packaging such as a drum or bag, with no inner containers. Such a packaging must be labeled according to the HCS, if the product is hazardous and is intended for a U.S. workplace. If the product is also regulated as a hazardous material for transport according to the Department of Transportation (DOT), then we must also display DOT labels and marks as required by 49 CFR.

However, it gets murkier when we look at combination packagings. These packagings consist of an outer packaging as well as one or more inner packagings. In a transportation sense, both the inner and outer packagings are “shipped.” But are they “shipped containers”?

The answer to this question isn’t found directly in the HCS. Instead, OSHA has issued interpretations that provide guidance here and here. (Note that one of these interpretations was issued long before the current rules, known as Hazcom Continue Reading…