IBC Residue, Choosing Placards, IATA Special Provisions, and Hazard Class Label Size
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. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.
Residue in IBCs (TDG)
Q. Under TDG, do Intermediate Bulk Containers (IBCs) such as tote tanks that contain residues still have to be transported as dangerous goods? Should the placards remain or be removed?
A. Under TDG, packagings or containers that still contain enough residue to pose a hazard during transportation should still be treated as dangerous goods. Unfortunately, the regulations do not give a specific way of judging this, so they should be considered hazardous unless you are absolutely sure they are not. (There is some misinformation that you may come across about how to make this decision. TDG does not specify “triple-rinsing” as a standard for cleaning or declare that an inch or less of residue can be considered non-dangerous. These references may come from other regulations or industry guidelines, but do not apply to TDG.)
So, if your IBC contains a dangerous residue, it should be clearly identified as such for transportation. If it was originally placarded or labelled correctly, just leave those Continue Reading…
Learning a new transport regulation is tough. Even if you are familiar with other modes, learning the intricacies of a new one is difficult. In our courses, we spend a good deal of time going over a basic shipping description (ISHP) and breaking down each part of it.
Time is also spent on UN versus ID numbers, proper shipping names, hazard classes, and packing groups. We also bring in the Dangerous Goods List (DGL) and talk about where to find the ISHP. This leads to a discussion on technical names, aircraft types, and other symbols shown in the DGL. Eventually we land on the topic of Special Provisions in Column M.
We explain these are additional requirements for any given entry or as I like to call it – the curve balls. Some are helpful and relieve parts of the regulation while others complicate it.
Note – If you ship dangerous goods and are having some trouble with the terms used above, you may need training.
New Special Provisions
IATA added some new Special Provisions a few years ago that cause additional stress for new shippers. I am referring to the A800 series. There are 5 special provisions there starting with A801 and going up to A805. So, what is the big deal with these and new shippers? If we take a moment to look at each one, you’ll see why Continue Reading…
On July 2, 2014, Transport Canada issued its amendment regarding updating the Transportation of Dangerous Goods Regulations (TDG) to reflect recent international standards, and to incorporate some new packaging standards. This amendment is intended to harmonize Canada’s regulations more fully with those used for international shipment, therefore simplifying international transport and improving safety. Please note that is a separate amendment from the one issued at the same time regarding safety marks.
The first thing you’ll notice in this amendment is the table in section 1.3.1, Table of Safety Standards and Safety Requirement Documents, has been extensively revised. Many standard references have been updated to more current versions; one of the most significant updates is the new reference to the Seventeenth Edition (2011) of the UN Recommendations on the Transport of Dangerous Goods. Also, some standards have been deleted, such as CAN/CGSB 43.150, “Performance Packagings for the Transportation of Dangerous Goods,” from the Canadian General Standards Board. Instead, new standards such as Transport Canada Standard TP14850, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and 9” have been added. This will bring in a whole new system for selecting packagings for these classes. Other new standards will introduce UN packaging provisions for portable tanks and rail containers.
Not all standards have been updated; note, for example, that CAN/CGSB 43.125, “Packaging of Infectious Substances, Diagnostic Continue Reading…