Safety Data Sheets (SDS)
ICC Compliance Center Writes Science Fiction?

In the 1960’s, an American author by the name of Robert A. Heinlein wrote a science fiction story about a man born and raised on Mars, but as an adult comes to Earth. The title of the novel is “Stranger in a Strange Land”. The plot focuses on the main character adapting and understanding humans – their language, laws and culture.

How does this connect with ICC Compliance Center, Safety Data Sheets (SDS), and labels one might ask? Consider this scenario: a US chemical with its SDS and label end up in a Chinese chemical plant or a Romanian factory. Can the workers in either of those places read it? Can it be understood? Are the workers aware of the hazards or dangers of the chemical? Are these workers safe when using this US chemical?

By using ICC Compliance Center, companies now have the capability to translate an entire SDS or label into any of 40 languages. Granted using a third-party is a possibility for translating specific words and phrases, but that can be expensive given how long SDS documents and labels are under the new GHS regulations. ICC Compliance Center is different, because we allow for flexibility when translating. Since we work per SDS document we’re likely a lower cost than other companies.

Learn about ICC’s full range of compliant SDS services »

One also has to remember the regulations and what they Continue Reading…

TDG
New Year – New TDG Amendment

TDG Regulations Update – Gazette II, December 31, 2014

For those that thought the amendments to the Canadian Transportation of Dangerous Goods Regulations (TDGR) had settled down following the July changes, Transport Canada has provided us with another “gift” to unwrap.

The Canada Gazette Part II published on December 31, 2014 introduces additional changes, the majority of which become mandatory by June 30, 2015 (although they are in effect as of January 1, 2015).

An exception to the date is the formalization of Protective Direction 33 which required ERAPs for 9 flammable liquids in September- now formalized in the TDGR and continuing to be mandatory as of January 1, 2015. This change resulting from the Lac Mégantic disaster was expected. Two additional UN Numbers have been added (UN1987- Alcohols N.O.S. & UN3494- Petroleum Sour Crude Oil, Flammable, Toxic) with a mandatory date of May 31, 2015 for ERAPs to be in place.

SHIP vs. ISHP

Of interest to all TDGR shippers is the removal of the “SHIP” format for describing dangerous goods on the shipping document. Transport Canada has jettisoned this option to follow the international convention of the “ISHP” order as the mandatory format.

  1. Identification/UN Number
  2. Shipping (Proper) Name
  3. Hazard Class
  4. Packing Group

Excepted Quantities

The concept of “excepted quantities” (already in air/maritime regulations) as an option for shipping very small quantities has been added- resulting in splitting Column 6 into 6a)- Continue Reading…

Can You Really Ship HazMat/DG Without Following the Regulations?

Can someone ship hazardous materials/dangerous goods without using regulatory publications?

This is often a question we ask ourselves when assisting customers. There are so many if’s, and’s, and but’s in the regulations, it’s hard to imagine someone shipping hazardous products without them. The regulations are just large instruction manuals on how to safely ship dangerous materials. We often have customers call and question why their shipment was rejected. After listening to their story, we can usually find the answer right in the regulations. When we tell a customer why their shipment may have been rejected, customers normally see why having a copy of the current regulations is so important. Every company shipping hazardous materials/dangerous goods should have all the regulatory manuals for the modes of transportation which they ship.

“That’s how we have always done it.”

This is something we hear very often, actually.

Just because that’s how you have always done it doesn’t mean it is compliant. The regulations are updated often for a reason – to ensure safety for everyone involved with shipping hazardous materials/dangerous goods. Recently, many of the regulations have been updated to include new UN numbers. The new shipping names and UN numbers will affect the way that companies label and document these products. This could easily become a scenario where “we’ve always done it this way” may lead to penalties or fines.

“These books are Continue Reading…

WHMIS 2.0: Another Step on the Journey (GHS In Canada)

Bill C-31 Receives Royal Assent

Canada has taken another step forward in the long journey (this writer attended workshops on implementation in Oct. 2003!) to incorporate Globally Harmonized System of Classification and Labelling of Chemicals (GHS) elements into the WHMIS hazard communication regulations with final passage and Royal Assent given to Bill C-31 late last week.

The Hazardous Products Act provisions in the “Budget Implementation Act” (BIA-Bill C-31) are only one aspect of this “Economic Action Plan” and arise from the Canada-US Regulatory Cooperation Council deliberations.

The foundation for WHMIS (officially the “Controlled Products Regulations”) is the Hazardous Products Act. Changes to this act prepares the way for the formal introduction of WHMIS 2.0 (as the proposed replacement “Hazardous Products Regulations” have become affectionately known) by Health Canada.

See all of our GHS solutions for Canada and the USA »

According to Health Canada’s WHMIS Directorate:

“This important milestone in the implementation of the GHS enables the Minister of Health to publish proposed changes to the Controlled Products Regulations, to be renamed the Hazardous Products Regulations, in the Canada Gazette, Part I. This publication will provide another opportunity to comment on Health Canada’s proposed regulations.”

GHS in Canada Changes Include:

Some of the details of changes involve: the aforementioned change from “controlled” to “hazardous” products; including of some of the “guidance” material from the WHMIS Reference Manual into the actual regulatory wording (e.g. a Continue Reading…

Graduation Cap
Do You Know Who is Training You?

Do-You-Know-Who-is-Training-You-500

Many people these days are calling themselves regulatory specialists, dangerous goods experts, or health and safety experts. The dangerous goods/hazardous materials field is a detailed, comprehensive topic requiring hands-on experience and a strong technical understanding of topics directly related to the industries we serve.

Finding the right training company is critical to ensuring that the processes and procedures you need to continue operating remain uninterrupted. Here are some questions you should consider when looking for trainers with the ‘right stuff’:

We’ve got the right stuff. Contact us today and find out more!

Download our Regulatory Specialists Bio (PDF) and learn about our team


1) What are their qualifications?

  1. What education and knowledge do your instructors have?

Meet our regulatory staff »

2) What experience do they have?

  1. How many Fortune 500 or multi-national companies have they helped train?
  2. How many satisfied customers have they trained over the years?
  3. What associations do they belong to?
  4. How do they find out about pending regulatory changes?

3) What other avenues do they offer?

  1. Can they provide the products and services that they are teaching you to use properly?

4) What is their approach to training?

  1. Are they offering the same course to everyone?
  2. Where can they train?
  3. Are they educated in training adults?
  4. Do they have an online option?

View our training locations and accommodations »

5) Are they the only person that will be working with you?

  1. Are Continue Reading…
The Rulemaking Process

Have you ever been curious about how a rulemaking is published?  Have you ever wondered how you can participate in the rulemaking process?

We came across a link we want to share from The Office of the Federal Register. When you follow this link https://www.federalregister.gov/learn/tutorials, then scroll down to Tutorials, you will see A Guide to the Rulemaking Process containing answers to the questions below.

Gavel and books

Before the proposed rule

What gives agencies the authority to issue regulations?

How does an agency decide to begin rulemaking?

When can the public learn that an agency plans to start a rulemaking?

How does an agency involve the public in developing a proposed rule?

What is the role of the President in developing a proposed rule?

The proposed rule

What is the purpose of the proposed rule?

How is the proposed rule structured?

What is the time period for the public to submit comments?

Why do agencies re-open comments or issue multiple proposed rules?

Do agencies have additional options for gathering public comments?

Why should you consider submitting electronic comments?

Before the final rule

How do public comments affect the final rule?

What is the role of the President in developing a final rule?

The final rule

How is the final rule structured?

When do final rules go into effect?

Can an agency issue a final rule without publishing a proposed rule?

What are interim final rules and direct final rules?

After the final rule

How are final rules integrated into the CFR?

How is Continue Reading…

What do you do for a living?

I always cringe when someone asks me what I do for work. Not because I dislike my job (in fact, I’m one of the few people I know who truly enjoys their work) but because it’s so complicated to explain what I do! Sure, I could simply say I’m a Regulatory Specialist and let them stare at me blankly and try to figure out what that means, but they usually expect more of an explanation.

After going through the explanation for a new acquaintance yesterday, I got to thinking that many of our customers may not know exactly what ICC’s Regulatory Specialists do either. Some of my “regular” customers only deal with one aspect of my expertise, and are often surprised when they learn how many hats I really wear on a regular basis. After 8 years on the job, I have collected many responsibilities to keep me on my toes.

  1. Training – One of the main duties of the Regulatory Specialist (RS) at ICC is to deliver training classes to our customers. For me, this includes the US 49CFR Hazmat regulations, the IATA Dangerous Goods Regulations and the IMDG Code. These classes can take place at our training centers, the customer’s facility, a hotel, or even via an online webinar. Not only do we conduct the training, but we also develop the presentations and quizzes that are Continue Reading…
GHS in the Workplace

The new Globally Harmonized System of Classification and Labeling (GHS) is now ready for worldwide implementation. Many countries have already adopted the GHS, while the USA and Canada are just beginning the task of harmonizing existing regulatory regimes within the GHS framework. Whereas the question on most people’s minds these days is “When will GHS be implemented?” concern should focus on how GHS will affect our commerce and safety in our workplaces. Target audiences for the GHS include consumers, workers, and emergency responders. GHS will benefit these folks. Though for the employer or Environmental, Health & Safety (EHS) Manager, once you’ve educated yourself in GHS principles, expect to spend much time sifting through the data needed to correctly categorize chemicals and their mixtures per the new GHS criteria. You should also expect to spend much money and time applying new GHS labels to chemical containers, reformat existing MSDSs to the sixteen sections Safety Data Sheet (SDS) and retrain workers how to interpret GHS hazard information. Do not expect a GHS shift to magically make your workplace safer, since GHS is not intended to harmonize risk assessment procedures or risk management. This gradual process of GHS assimilation should however eventually help in the decisions process.

The advantage of GHS is the way it identifies the intrinsic hazards found in chemical substances and mixtures and conveys this hazard information Continue Reading…

We’re Ready When OSHA Is!

ICC is ready for GHS

In January 2011, OSHA proposed that in August of this year, they would publish the final rule to align the current Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The more recent DOL Spring semi-annual regulatory agenda released in June revisits the scheduling of the release of the HCS revision to an unspecified date in September of this year. September has now come and gone, and we are still without a final rule from OSHA.

This leads to the question of “If not now, then when?”. It is probably a safe assumption that OSHA’s lack of implementation of GHS to date will be a major topic of discussion at the October 1st – 5th Society for Chemical Hazard Communication (SCHC) fall conference in Washington, DC. Many health and safety professionals, myself included, will be impatiently waiting for word of a revised deadline.

At ICC, we have been preparing for the new requirements so that we are ready when OSHA is. Updates and products related to GHS can be found on our website at: http://www.thecompliancecenter.com/regulations/ghs.htm

Online or Mail Order Shopping – A Reminder for Responsible Shopping and Product Safety

Most people have seen, at one time or another, ads for new children’s products or household/personal use products on the television, or online, with what appears to be an ‘amazing’ deal… those famous ‘limited time offers’ with the amazing deal to ‘purchase now and you’ll get two products for the price of one’.Shoppers need to keep in mind that it’s not always just about the ‘deal’.

When shopping online or via mail, shoppers need to keep in mind that some products may be prohibited in your home country and others still may have special safety requirements that are actually more strict than the safety requirements for the same product in other countries. The more you know about the health, environmental and user risks of the product you are about to purchase, the better you can protect the health and stability of both you and your family. If you do not practice responsible shopping, you can end up putting yourself and your family into some sticky situations.

One example of the consequences of not practicing responsible shopping is during the purchase of a children’s car seat in Canada. Perhaps you’ve seen an ad online for a really good deal on a car seat that is coming from the United States and you happen to live in Canada. Car seats for children are regulated by both Health Canada and Transport Canada, and must pass Continue Reading…