ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 29

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

VOC/SDS

Q. We have a customer that is asking why the VOC content is “N/Av” on their SDS. It is required under OSHA or WHMIS?
A. According to US federal OSHA Hazcom 2012, and Canadian WHMIS 2015 rules, VOC information is not actually a mandatory item to appear in any section of a 16 Section SDS. It is commonly requested as a sub-item in Section 9, which is why ICC automatically includes the subheading. ICC does not calculate VOC levels, so the data would have to be provided by you. VOC information is common info to have for coatings, and has become important for coatings manufacturers due to Environmental regulations.

Lithium Battery Mark

Q. Customer called and asked if they ship UN3480 lithium batteries ground within the US, can they use the lithium battery mark instead of the class 9 lithium battery label, or do both have to be on the package. He also wanted to know what packing group lithium battery packaging had to be?
A. When shipping ground within the US, you are required to use a lithium battery mark OR a Class 9 lithium battery label. So just the lithium battery mark is fine in Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 22

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Lithium Battery Contained in Equipment

Q. We need to ship a lithium ion battery installed in a scooter. The battery is 36 volts and 14.5 ampere-hours which makes it 522 watt-hours. We are in California and need to get it to Seattle, Washington. We believe the box needs a class 9 label but aren’t sure about the other requirements.
A. Since it is an ion battery installed in equipment with a watt-hour rating of 522 that makes this a fully regulated shipment. Transport will likely be by ground which would fall under US 49 CFR. This makes it UN3481 Lithium ion batteries contained in equipment Class 9 with no packing group. Hopefully the battery doesn’t weigh more than 26 pounds. If it does, then we will need to have a slightly different conversation. So, following 173.185 of the 49 CFR you don’t need UN Specification packaging. As for the outside you will need the UN number, proper shipping name, and the Class 9 hazard class label (preferably the one dedicated to batteries). You will need a shipping paper completed for this as outlined in 172.200. No placards would be needed unless you ship 8820 pounds Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 1

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Placarding Bulk Truckloads

Q. My truck has 4000kgs of drums of Class 3 UN1993 in it. Truck has Class 3 UN1993 placard on it . We pick up 1 empty tote (IBC) which is Class 3 UN1993 also. Can we keep the same placard on the truck or do we need to add Class 3 only? Same with empty drums. We just need to add primary CLASS card? All transported via ground within Canada.
A.Well the drums don’t need UN numbered placards since drums are considered small means of containment. A plain class 3 placard will do to represent the drums. It used to be in the Regulations that over 4000kg from one shipper could display UN numbered placard but it was repealed recently. Totes, even empty with residue, requires UN numbered placards for liquids in direct contact with the means of containment. You don’t need to add plain class 3 placard for the drums as both the drum and tote content is hazard class 3. So technically the truck displayed the correct placard (UN1993). If the drums were empty and less than 500kg gross mass then no placard will be required; however, if you Continue Reading…
Safety Data Sheets (SDS)
Should You Use CANUTEC as Your 24-Hour Number on Your SDS?
Compliant SDSs

SDS Requirements

Safety Data Sheets (SDSs) have been an important tool for worker safety for decades. In Canada, they became mandatory for hazardous materials in 1988, and although their basic format has been modified by WHMIS 2015 (the Workplace Hazardous Materials Information System 2015), one constant has always been a heading for “emergency telephone number.”

This brings up the question of what number should be on the SDS. Yes, it’s possible to run the emergency number internally, but most companies don’t use this solution. First, if you’re using it for transportation purposes, the law requires that the number be staffed 24 hours a day. Even if you have staff to do that, they must be trained to give effective advice over the telephone. That can be a difficult job, and requires professionals with both technical knowledge and the ability to remain calm in emergencies. Therefore, most companies these days outsource this function to specialist services.

Having a direct line to a live, knowledgeable person can be a true lifesaver in an emergency. Early in my training days, a customer told how he’d been given the job, late at night, of cleaning out a tank of chemicals by siphoning them into a waste container. In those days, safety standards were sometimes lax, and he was taught to start the siphon by mouth. Unfortunately, he was distracted during the procedure and ended Continue Reading…

OSHA Labeling
Can you ship DG and non-DG Together in One Package?

Can you ship DG and non-DG Together in One Package?

Surprisingly this is pretty common. Normally the answer is, “Sure.”

However, that’s not always the case. Sometimes a dangerous goods commodity can react with a non-dangerous goods commodity. I do come across this type of situation occasionally.

Shipping from Canada to USA via Air

Earlier this week a client dropped off 2 different product samples going to USA via air transport. He provided the SDS for both products, one was DG and the other not. He asked if both samples can go together in one package. I told him, “Maybe.” Without consulting the SDSs and gathering more information I couldn’t be sure. If they are compatible, then I can package them together.

I used to work in the carrier industry so I know it’s better to consolidate than to have a multiple piece shipment. Most times all the pieces will arrive together, but there is a chance they may not. So for me, personally, I prefer to minimize the number of packages, which means using a bigger box if I need to.

Determining Compatibility

So back to this. I checked the SDS for both and the one that was DG was a corrosive material.

The non-DG product requires a more thorough read-through to see which material this material was incompatible with and in Section 10: Stability and Reactivity it said incompatible with oxidizing materials Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 2

How to determine if a product is regulated, SAPT on a SDS, Shipping a drone, and using a UN package

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Is my product regulated?

Q. I have 2 products I distribute to various stores to sell. The SDS files say my product is not regulated under DOT and TDG in Section 14. Since this is sold as a consumer product, doesn’t that mean it is regulated for IATA should I ship it via air? (the SDS were emailed to me)
A. Nothing in your SDS files leads me to believe either one would meet any of the 9 hazard classes in IATA. This is further confirmed by neither SDS classifying the products for DOT and TDG. Basically, what you have are containers of non-regulated liquids.  There is no need for UN Specification packaging or paperwork for IATA or any other transport regulation.

SAPT on my SDS

A. Since the addition of UN numbers for polymerizing substances, we’ve been told we must include the Self-Accelerated Polymerization Temperature (SAPT) on our SDS documents in Section 9. Is this a new requirement?
Q. There is no requirement in OSHA HazCom 2012 to include that particular data point in Section 9. All of the Continue Reading…
WHMIS 2015 Concentration Ranges – Finally Some SDS ‘Relief’

WHMIS Update

Health Canada Amendment to the HPR (Hazardous Product Regulations)

Health Canada published a proposed amendment to the HPR (Hazardous Product Regulations), which included an option to use specified concentration ranges for ingredients rather than the exact or actual chemical concentration on their SDSs (safety data sheets) (October 21, 2017).

That proposed amendment to allow ranges, would offer industry some Confidential Business Information (CBI) protection of formulations without having to go through a potentially costly CBI application claim under the Hazardous Materials Information Review Act (HMIRA).

Ahhh….’Relief’

After receiving comments and questions on the proposed amendment to allow the use of concentration ranges on SDSs, Health Canada has advised that the amendment has been approved and registered as of April 4, 2018. The approved amendment has yet to appear in the official Gazette II publication, but is expected to appear on April 18, 2018. Since it is officially registered, the amendment is effective, and can be applied, now.

The Details…

Health Canada, through this new amendment, is giving the option to suppliers, to list prescribed concentration ranges for ingredients on SDSs, without having to apply for a potentially costly exemption, in accordance with the HMIRA.

Suppliers may use this option when they wish to protect exact concentrations, or ‘actual concentration ranges’, which they feel are trade secrets.

The following are the approved, prescribed, list of concentration ranges:

0.1 – 1.0%
0.5 – 1.5%
1.0 – 5.0%
3.0 – 7.0%
5.0 Continue Reading…
Regulatory Helpdesk: March 5

Batteries, Batteries, and more Lithium Batteries

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Why do I need an SDS for a Laptop Battery?

Q. We are shipping used laptops with batteries in the units from the US to HK via air. There are multiple manufacturers and models, are (M)SDS sheets required for each model? Our forwarder is requesting them in order to provide pricing.
A. To answer your question, it would depend on why the forwarder is requesting them. They may be asking for them to meet the written emergency response requirements. However, they could be asking for them for classification purposes to prove which part of the packing instructions these meet.

The SDS could tell them the watt-hour rating which would then drive which part of the instruction to use. Forwarders and carriers have a lot of leeway. I can only speak to what the regulations say. There is nothing in 49 CFR or IATA that indicates you must use an SDS. Most people tend to default to them because they meet so many parts of the regulations in one place.

Manufacturer’s Packaging (Lithium Battery)

Q. Should I remove the manufacturer’s packaging from lithium ion batteries being shipped by air under PI 965 Continue Reading…
Regulatory Helpdesk: February 12

Lithium Batteries, Placards, and SDS in the Workplace

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Lithium Batteries (Air)

Q. For PI 967 in IATA is the weight limit the weight of the equipment and battery inside of it or just the battery.
A. For all battery packing instructions in IATA it is always the weight of the battery itself.

Lithium Batteries (IMDG)

Q. Do “excepted” batteries require segregation from limited quantity packages under IMDG?
A. Under IMDG §3.4.4.2 it tells you that segregation requirements in Chapters 7.2 – 7.7 plus any information on Stowage in column 16b of the table do not apply to goods in limited quantity packages. Lithium ion batteries do not yet need segregation under IMDG either. It is only IATA that has implemented segregation this year as part of the packing instructions for shippers. IATA has also added batteries to the segregation table for operators, but it isn’t mandatory until next year and only applies to those in Section 1A and 1B not Section II.

Placards (TDG)

Q. Customer asked if his Class 8 material (UN 1830) needed to have a UN number on the placard if shipping 1 liter per package and 7 per tote for a total of 17 Liters for the shipment in Canada. Continue Reading…
Regulatory Helpdesk: February 5

Labels, Placards, Segregation, Documentation, SDSs & Emergency Response

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Here are the top 6 questions from last week.

SDS and Workplace Labels

Q. If I have a product like a concentrated cleaner which is corrosive to the eyes and skin that I water down at my facility, do I need a new SDS and workplace labeling?
A. You have 2 options. You can use the SDS as provided to create your workplace labeling. This may cause concern with your workers. However, it would be better for you to develop your own and re-evaluate the product using the hazards presented in the watered-down version. It is possible, depending on how diluted it is, to move into the irritation or non-hazardous range.

Listing Canutec or Chemtrec on Lithium Battery Marks

Q. Regarding the new battery mark, am I allowed to add “in case of emergency, contact Chemtrec”?
A. The regulations are pretty clear (DOT §173.185(c)(3) and IATA 7.1.5.5). What should be listed there is a phone number for “additional information”. There should be no extra phrasing other than phone number itself. As for listing Chemtrec, Infotrac or even Canutec, those are 3rd party Emergency Response Providers and would not be appropriate to include in that section of Continue Reading…