Transport Canada Consults on Revised Packaging Standard TP14850

A draft version of the 3rd Edition of Transport Canada’s TP14850- Small Containers for Transportation of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 & 9” is available for public review and comments will be considered when received by October 13.

Transport Canada began planning the review in Q3 2015 and announced the formation of a Technical Committee in a public notice in early 2016.

The Committee was formed in April; consisting of participants representing interests from production, marketing, distribution, sales, use and/or regulation of dangerous goods packaging. The Committee met initially by phone and, following the review of a preliminary draft, followed up with a meeting in Ottawa in May to provide input for the aforementioned first draft.

The intent of the 3rd Edition is to incorporate updates from the 19th (2015) Edition of the UN Recommendations and possibly prepare for inclusion of aspects of the 20th Edition expected in 2017.

Some features of the first draft, in addition to the harmonization with the 2015 model UN Recommendations, include:

  • clarification of the requirements for packaging distributors to provide instructions on assembling and closing packages;
  • removal of some redundant provisions that are already in the regulations;
  • clarification of special cases and expanding some Substance Specific Provisions (SSP) removing the need for certain Equivalency Certificates (e.g. UN3268);
  • locating SSP within the packing instruction (PI) applicable to the UN number, similar to the UN Recommendations & Continue Reading…
OSHA Update
OSHA Clarifies How to Handle Small Container Labels

After a couple years of head-scratching on how to label small vials and bottles with all the required information, OSHA has released some clarification on how to do so. Unlike WHMIS and the EU, OSHA never released exceptions on how to properly label small containers. Small containers are considered to be in the scope of 5 mL vials or 50 mL bottles. One thing OSHA made very clear is that NIST linking, numbering system and EU exceptions cannot be used. Each label, no matter the size of the bottle, must contain all the required information.

OSHA recently released guidelines on how workplace labels can be handled with such small containers. While pull-out labels, fold back labels, or tags can be used, there are cases where even these smaller labels can be too large for the container or not cost effective. Thankfully, OSHA understands that and has cleared up how to handle this.

If you have a small container that the above mentioned labels are just too large to fit on the actual container, there is an accommodation that can be used.

Minimum Label Information

The actual container can have a label that consists, at minimum, the following information:

  • Product identifier
  • Appropriate pictograms
  • Manufacturer’s name and phone number
  • Signal word
  • A statement indicating the full label information for the chemical is provided on the outside package

The outside package for the bottle/vial must consist, at minimum, the following: