Regulatory Helpdesk: January 22, 2018

Shipping Alkaline Batteries, IBC Pressure Gauges, and SDS Expiry Under WHMIS 2015

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.

Shipping Spent Alkaline Batteries (49 CFR)

Q. Can spent alkaline batteries (Duracell) be shipped to a recycling facility by ground without being declared dangerous goods?
A. Assuming that these are dry alkaline batteries that are used or spent for recycling, they are not required to be shipped as dangerous goods by ground in the USA per 172.102 Provision 130 (d) provided they are rated under 9 volts per below.

Ground Transport (US DOT): 49 CFR 172.102 SPECIAL PROVISION 130

Used or spent battery exception. Used or spent dry batteries of both non-rechargeable and rechargeable designs, with a marked rating up to 9-volt that are combined in the same package and transported by highway or rail for recycling, reconditioning, or disposal are not subject to this special provision or any other requirement of the HMR.

Pressure Gauge Requirements for IBCs

Q. What are the pressure gauge testing requirements for 31A IBCs?
A. I referred the customer to 178.814 d (1) (2) which lists 2 consecutive tests that must be administered with a rating of 65kPa first followed by 200kPa.

Can You Use Capital Letters (TDG)?

Q. Do Continue Reading…
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…

Auditing – I’m Here to Help You*

Let’s Start With Some Definitions

According to the Oxford English Dictionary there are essentially two types of audits:

1. “Conduct an official financial inspection…”
1.1 “Conduct a systematic review of…”

The latter is of interest here as, whether the topic is environment, health & safety (EHS) or transportation of hazmat/dangerous goods; we aren’t generally in the business of inspecting financial issues.

To expand, in the context of auditing in the non-financial context, a more relevant definition was provided in the classical (some things never grow old!) handbooks authored by Greeno et al:

“Auditing in general is a methodical examination -involving analyses tests and confirmation- of local procedures and practices where the goal is to verify whether they comply with legal requirements, internal policies and (or) accepted practices. Auditing differs from assessments in that it requires the collection and documentation of competent and sufficient evidence rather than opinion based purely on professional judgement.”

-[Greeno, J.L.; Hedstrom, G.S. & DiBerto, M.: “Environmental Auditing: Fundamentals & Techniques”, 2nd Edition, 1987- Center for Environmental Assessment- Arthur D. Little Inc.]

This contrasts with an assessment:

“Assessment: An appraisal of procedures or operations based largely on experience and professional judgement.”

-[Greeno, J.L.; Hedstrom, G.S. & DiBerto, M.: “The Environment, Health, & Safety Auditor’s Handbook”, Center for Environmental Assessment- Arthur D. Little Inc., 1988 –p.163,164.]

Although assessments may enter into the audit process, they should not be a substitute for the Continue Reading…

Auditing – A Valuable Compliance Tool

Is everything in your workplace safe? Have you complied with all the regulations that apply? Are workers following safe procedures at all times? If you can’t say, “yes” to these questions, you may need an audit.

A safety audit is more than a quick look around. It’s defined as a planned and documented observation and evaluation of the workplace, looking at a specific set of behaviours or information. Audits can be targeted at many different safety issues.

    Common issues targeted:
  • General workplace safety, such as eliminating clutter;
  • Technical aspects, such as fire or electrical safety;
  • Procedures such as machine guarding or lockout; and
  • Regulatory compliance, such as occupational health and safety, or transportation regulations.

Keeping track of your observations is important. Auditors will use a checklist of things to look for, and to evaluate them in an objective format. An example of a checklist for office safety can be found on CCOHS’s website. Note that checklists should identify specific issues, and either judge them on a pass/fail scale, or a more detailed format that may grade performance as excellent/satisfactory/poor/unacceptable.

While there are many resources available, your checklist should be customized for your specific workplace. The safety concerns in an office setting are quite different from those in a manufacturing area. Also, generic checklists may not address the regulations that apply to your workplace. For example, a checklist designed for the United States will include Continue Reading…

Authoring a Material Safety Data Sheet [(M)SDS] For Paint Is Not As Easy As One Would Think

Take a company that manufactures artist’s paints. They could sell hundreds of colors and most are made with the same “base” ingredients. Start adding the colorant, dye or pigment, and all of a sudden you have the potential for hundreds of unique ingredients and the potential for some differences.

What many folks do not understand is that each colorant, dye or pigment may have different hazards. The classification could change from paint to paint. It is imperative that each colorant, dye or pigment is researched to see if it meets any of the hazard criteria. Products may look the same once they are sitting on a shelf, but can be dramatically different in chemical composition.  If something different occurs in the profile of hazards, then (M)SDS needs modified to be accordingly. We also strongly recommend a separate (M)SDS when the hazards are found to be different from the colors.

Add wanting to prepare an MSDS for Canada, the USA or Europe, and you have a variety of different disclosure criteria, cut-off values etc. Something that is regulated in one country may not be in another.

ICC takes pride in ensuring that SDSs we author meet the requirements of the WHMIS, OSHA or European regulations. Contact us for details on how we can help.

Discussion thread at LinkedIn