ICC's Regulatory Helpdesk
Regulatory Helpdesk: July 30

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…

IATA
IATA 800 Series of Special Provisions

Learning New Regulations

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…

TDG Update – Regulations Amending the Transportation of Dangerous Goods Regulations (Update of Standards)

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…

Changes for IATA & IMDG Code for 2013

Based on the information available to date, the following are some of the changes that will be in the 2013 editions of the IATA Dangerous Goods Regulations and the IMDG Code.

  • lithium ion batteries > 100 Wh but < 160 Wh may be carried as spare batteries in carry-on baggage
  • portable electronic devices containing batteries should be in carry-on baggage and be protected to prevent short circuits
  • medical devices or equipment that contains or may contain infectious substances are not subject to the regulations provided that the item is packed so that there will not be any leakage
  • packages containing medical devices or equipment must be marked “Used Medical Device” or “Used Medical Equipment”
  • lithium cells and batteries must be of a type proved to meet the UN Manual of Tests and Criteria
  • dangerous goods list additions:
    • UN3496 batteries, nickel metal hydride
    • UN3497 krill meal
    • UN3498 iodine monochloride, liquid
    • UN3499 capacitor
    • UN3500 chemical under pressure, n.o.s.
    • UN3501 chemical under pressure, flammable, n.o.s.
    • UN3502 chemical under pressure, toxic, n.o.s.
    • UN3503 chemical under pressure, corrosive, n.o.s.
    • UN3504 chemical under pressure, flammable, toxic, n.o.s.
    • UN3505 chemical under pressure, flammable, corrosive, n.o.s.
    • UN3506 mercury contained in manufactured articles
  • dangerous goods list deletions:
    • UN3492 toxic by inhalation liquid, corrosive, flammable, n.o.s.
    • UN3493 toxic by inhalation liquid, corrosive, flammable, n.o.s.
  • the excepted quantity code for the various silanes has changed to E0
  • special provision 240 applies to vehicles powered by batteries, such as, scooters, e-bikes, wheelchairs, etc. Hybrid vehicles must be consigned under one Continue Reading…