Regulatory Helpdesk: November 13, 2017

Top 4 Questions from the Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Here are some highlights from our helpdesk last week. Check back weekly, the helpdesk rarely hears the same question twice.

WHMIS Label Size Requirements

Q. Is there were size requirements for WHMIS labels?

A. No, the HPR does not mandate a size requirement other than saying it has to be legible. But, what does legible mean? As a general rule of thumb, which we have developed from reviewing many different labeling regulations is 10 mm for one side of the pictogram, and 2 mm for the font size (1.6 mm for a worst-case scenario).

IATA Special Provision

Q. What does  IATA’s Special Provision A191 mean?

A. It was determined that SP A191 means if you have a manufactured article with less than 5 kg of mercury in it (like a thermometer) then you don’t need the Class 6.1 label for mercury’s subsidiary hazard and you don’t have to list the 6.1 subsidiary hazard on the shipper’s declaration.   From what we can tell that only applies to UN3506 which is Mercury contained in manufactured articles.

Quantity Limits – TDG (Canada)

Q: What does the quantity limit in TDG Columns 8 & 9 represent in terms of Passenger conveyance restrictions- package, consignment, …?

A: Good point which many find confusing. The answer is in the often-overlooked Continue Reading…

Applying for an Equivalency Certificate in Canada

So, you want to bend the rules? What happens when you have a scenario where following the regulations to ship your dangerous goods becomes impractical to the point of impossibility?

This blog entry will speak to what the process is for applying for an Equivalency Certificate in Canada as per the Transportation of Dangerous Goods Clear Language Regulations.

Generally when people ship dangerous goods, the process becomes a matter of reading and complying with everything the regulations state. However, below are some scenarios where following exactly what the regulations state is… shall we say… less than ideal.

Scenario 1)

Al wants to ship some large batteries for equipment within Canada with classification:

               UN 2794, Batteries, Wet, Filled With Acid, Class 8, P.G. III

His dilemma is that when a new battery is commissioned, the outer package is generally discarded due to space limitations. In many cases these batteries were installed prior to the packaging requirements of Part 5 of the TDG Regulations.

Al wants to ship this without UN approved packaging.

Scenario 2)

Bill wants to ship a MRI machine that contains liquid helium, classification:

               UN 1963, Helium, refrigerated liquid, Class 2.2

His dilemma is that his MRI machine is what contains the Helium and it is not in an approved means of containment. He requires the helium to remain in his equipment during transport in order to keep the magnet cool.

Bill wants to ship this Continue Reading…

Changes to Special Permit 9275 Affect US Ethanol Shippers

The US organization COSTHA (Council on Safe Transportation of Hazardous Articles) is petitioning the Pipelines and Hazardous Materials Administration (PHMSA) regarding changes to a Department of Transport (DOT) special permit widely used by industry. These changes may add requirements to US shippers of small packages containing ethanol.

The permit in question, DOT-SP 9275, exempts the transportation in of small packages of liquids and solids containing ethanol from the provisions the Hazardous Materials Regulations (HMR) of 49 CFR. In effect, if certain packaging safety considerations are met, the package may be transported by ground with no labels or other hazard communication, such as shipping papers.

In the latest consideration of this special permit, PHMSA has proposed that the packages should, at a minimum, be marked with the name of the company responsible for the shipment, and the words “Contains Ethyl Alcohol, exempted quantity”. In their letter of petition dated June 14, 2011, COSTHA has submitted to the DOT that these markings will increase the cost of preparing packages, and that there is no justification from studies of such shipments to indicate that safety will be improved by including these markings. Shippers using this special permit include many companies in the cosmetics, food and pharmaceutical industries.

Note that this special permit only applies to shippers within the United States, so should not have a significant effect on Canadian shippers of small Continue Reading…