Canada!
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 & the IMDG Code practise;
  • requiring Transport Canada “acceptance” of alternative leakproofness testing procedures;
  • consideration of using plastic containers beyond the 5-year limit when the use is under the control of a fleet operator registered with Transport Canada;
  • mandating a periodic (5 year) retest by manufacturers of prototypes from production of approved containers

Following the comments received on the first draft of the 3rd Edition of TP14850, the Committee will meet again in Q4-16 to review the comments and provide input for a 2nd draft. The 2nd draft is expected to be released for additional public comment in the Spring of 2017. The objective is to release the final 3rd Edition in October 2017.

To obtain a copy of the first draft click here »

Motorcycles – Yes, They are Dangerous Goods

If you are feeling “Born to Be Wild” – Steppenwolf and looking to race down life’s highway on two wheels this summer, but short on time, or looking for an even better adventure across the pond, fly your bike and meet it there.

Wait! You can’t just show up at the airport and check in your motorcycle. Did you know that a motorcycle is considered to be a dangerous good? Under the IATA regulations, a motorcycle is classified as UN 3166, Vehicle flammable liquid powdered, hazard class 9; and therefore needs a shipper’s declaration form.

What does this mean to the average motorcycle enthusiast? It means that you need to seek the advice of a dangerous goods consultant, who specializes and can assist in providing instruction on the preparation of the motorcycle, and provide the proper signed shipper’s declaration.

According to Air Canada, some of the requirements at time of tender include:

  • The fuel tank must be drained as far as practical; and fuel must NOT exceed ¼ of the tank capacity
  • All batteries must be installed and securely fastened in the battery holder of the vehicle and be protected in such a manner as to prevent damage and short circuits
  • Spare key, to be left in the ignition
  • Alarm (theft-protection devices, installed radio communications equipment or navigational systems must be disabled
    Air waybill number (booking number)
  • Saddle bags may be filled with equipment, parts, etc. An itemized list of the content of the saddle bags must be provided at time of tender.
  • Personal effects such as a clothing, toiletries and luggage cannot accompany the motorbike. (Dangerous goods such as lubricants, spray paints etc. must be left behind)

ICC Compliance Center offers declaration services across Canada, and can work with you to find a consultant in other countries as well. Contact us at least 2 weeks before you plan to start your adventure.

Have fun and contrary to the opening statement, no racing! Simply stay safe enjoy the sun on your face and the wind in your hair!

Transport Canada Amends TDG Reporting Requirements

On June 1, 2016, Transport Canada issued an amendment to the “Transportation of Dangerous Goods Regulations” (TDG) under the Transportation of Dangerous Goods Act. This amendment substantially revises the requirements for reporting spills of dangerous goods during transportation. It also addresses changes to air shipment of lithium ion batteries and makes various minor corrections and changes. The “Reporting Requirements and International Restrictions on Lithium Batteries Amendment” reflects concerns that the previous requirements for reporting spills, called “accidental releases,” was inefficient and didn’t allow the reporting parties to evaluate the risk to the public when deciding if a release had to be reported.

Continue reading “Transport Canada Amends TDG Reporting Requirements”

Canada!
Transport Canada Issues Protective Direction 36

On April 28, 2016, Transport Canada issued its latest Protective Direction. This Direction, number 36, will replace a previous one, Protective Direction 32, with more detailed instructions for rail carriers.

Protective Directions are rules that are not included in Canada’s Transportation of Dangerous Goods Regulations (TDG). Instead, they are announced by Transport Canada, and are published on their website. Usually, these directives are used when Transport Canada believes it’s important to bring in a new rule quickly in order to protect the public. Since amending the regulations can take months or longer, Part 13 of TDG allows them to use this method to respond to important issues with appropriate speed.

Protective Direction 36 requires Canadian Class I rail carriers to either publish information on the carrier’s website, or provide information to designated Emergency Planning Officials (EPOs) of each jurisdiction through which the carrier transports dangerous goods. This information includes:

  • Aggregate information on the nature and volume of dangerous goods that the rail carrier transported by railway car through the last calendar year (broken down by quarter);
  • The number of unit trains loaded with dangerous goods operated in the jurisdiction in the last year (again, broken down by quarter); and
  • The percentage of railway cars carrying dangerous goods that were operated by the rail carrier through the jurisdiction in the last calendar year.

Rail carriers transporting dangerous goods by railway car in a province must, by March 15 of the following year, publish on its website a report in both official languages detailing the dangerous goods shipments, including the percentage of cars that were loaded with dangerous goods, the top ten dangerous goods carried, the percentage of these top ten goods as part of the dangerous goods transported in this province, and the percentage of all residual dangerous goods on the total dangerous goods transported in that province.

Further details are given in the Protective Direction about how the rail carrier must communicate with the designated Emergency Planning Official in each jurisdiction, and how they must provide information to the agency CANUTEC to improve communication during accidents.

Protective Direction 36 replaces the earlier Protective Direction 32, and takes effect on April 28, 2016, the day it was issued. The full text of the Direction can be found at http://www.tc.gc.ca/eng/tdg/safety-menu-1281.html.

Do you have any further questions about Protective Directions? Contact ICC Compliance Center here at 888-442-9628 (U.S.) or 888-977-4834 (Canada), and ask for one of our regulatory specialists.

Public Notice – Transport Canada Standard TP14877 Update

A public notice has been posted by Transport Canada. The info is below:

The Transportation of Dangerous Goods Directorate will begin work on updating the Transport Canada Standard TP14877, “Containers for Transport of Dangerous Goods by Rail”, December 2013. The standard covers large means of containment used in the handling, offering for transport and transporting of dangerous goods by rail. The update will focus on incorporating recent regulatory changes and proposals that have been consulted with the TP14877 Consultative Committee. The TP14877 Consultative Committee is comprised of various key stakeholders with extensive knowledge and expertise in regards to various aspects associated to the transportation of dangerous goods by rail.

Read the full notice »

Canada!
“Sea Change” Amendment to TDG Proposed- Criteria Requiring IMDG Code Clarified

Hot on the heels of the Feb. 2 Transport Canada proposed amendment (“Harmonization Updates”) posting, there was another (Feb. 9) proposal for consultation to clarify the intent of Part 11 regarding marine/ferry shipments.

A major result, if the proposal is adopted, will remove the confusion around when the IMDG Code is mandatory for vessel (updated terminology to replace the noun “ship”) shipments of dangerous goods. This issue has been subject to conflicting interpretations from time-to-time; not just among consignors, but also within the transport and enforcement communities.

This difficulty in making a clear interpretation stemmed from the difference in the intent of the term “Home Trade Voyage” in an obsolete version of the Canada Shipping Act which was quoted (perhaps out of context) in Part 11 of the TDGR.
A literal reading implied that essentially all “salt water” voyages could be considered Class I home trade voyages; requiring use of the IMDG Code.

As proposed, shipments by ferry to, for example Newfoundland or Vancouver Island, will likely clearly be under the provisions of the TDGR, not the IMDG Code. This will be of benefit, particularly to shippers of limited quantity/consumer commodity items which should no longer require a formal dangerous goods document or other considerations unique to the IMDG Code.

Short-Run Ferry qualification criteria may also be expanded to 5 km voyages; and restrictions on fuel transport on passenger ferries may be relaxed based on risk assessments/current equivalency certificate experience.

Comments on the proposal are welcomed by Transport Canada until Feb.28 – see:
http://www.tc.gc.ca/eng/tdg/safety-menu-1262.html

Canada!
Harmonization Continues (No, not that one!) – TDGR Consultation Proposal

…or “Preliminary consultation on International Harmonization Updates to the Transportation of Dangerous Goods Regulations”:

Transport Canada, after a busy 2014/2015, has begun a public consultation on proposed amendments aimed at improving the harmonization between the Transportation of Dangerous Goods Regulations (TDGR) and International/US regulations. The proposed amendments will also update referenced standards on classification, packaging, etc.

TDGR Part 8 Reporting requirements will include the ICAO-based requirement for the Air Operator to notify CANUTEC if DG have been discovered to have been carried in non-compliance without proper notification to the pilot-in-command.

Ambulatory References:

A key feature of the proposal is the move towards citing versions of safety standard/requirement documents in Part 1 “as amended from time to time” rather than referring to a specific issue date or revision. This will simplify things for international trade and reduce potential confusion over which edition must be followed.

Canada-US Reciprocity:

In keeping with objectives established in the 2012 Canada-US Regulatory Cooperation Council action plan:

http://www.trade.gov/rcc/documents/Alignment-of-Dangerous-Goods-Means-of-Containment.pdf ;

the proposal seeks to consider allowing the provisions of Canadian Equivalency Certificates (TDGR Part 14)/US Special Permits to be mutually acceptable between the two countries.

While recognizing the potential beneficial aspects of the change for industry stakeholders; there is concern on other potential impacts, such as for the enforcement community.

The proposal also includes provision for authorizing the interchangeable use of gas cylinders and aerosols (TDGR Part 5).

Catch Up:

As part of the proposal to keep the TDGR current, pending implementation of the above ambulatory references, there several areas to be amended to maintain current with UN Model, ICAO and IMDG regulations.

Schedule 1 and 2: A series of entries require modification to reflect changes in (among others): Class 3 temperature control for stabilized (Primary or Subsidiary) Class 3 substances (53 citations to proposed SP 154); introduction of entries for polymerizing substances (Class 4.1, despite including liquids); separation of listings for internal combustion/fuel cell “vehicles” (UN3166) and “engines”/”machinery” (UN3528-UN3530); separation of polyester resin kits into liquid (UN3269) & solid (new UN3527) based; etc.

The Schedule 2 Special Provisions list will expand from 150 to 167 if the proposals are adopted.

Other changes covered in the proposed additions include introducing the new version of the lithium handling label for shipments exempt from UN standardized packaging (presumably replacing the marking requirements currently found in TDGR SP 34(4)) & the new Lithium Class 9 placard.
Note that these are also mentioned in proposed amended text for Part 4.
However, although the latter also references the intent to require use of a ” … CARGO AIRCRAFT ONLY” label, neither the proposed text nor illustration elaborates on this this.

Incidental changes in Part 4 include adopting the new “Fumigation” sign (with provision for indicating “ventilation date” as adopted in July, 2014 Part 4.21) and specifying a minimum height of 12 mm for “Overpack” markings.

Proposed Special Provisions 159 and 160 provide exemptions for celluloid table tennis balls and safety matches, respectively.

Another exemption added to TDGR Part 1 (Special Case 1.50) would provide relief for hot-air balloonists to transport cylinders that aren’t “TC-certified” between launch sites without needing an Equivalency Certificate.

Fishes Breathe (?) A Sigh of Relief:

Schedule 3, in keeping with the current IMDG Code, would expand the list of “P” (Column 4 Marine Pollutant) entries by 70+ items to “facilitate consistent communication on the presence of marine pollutants…for more safe…transportation.”

That’s a Wrap

Apart from some incidental/administrative changes (due to anticipated, for example adoption of the updated version of CGSB-43.125), the balance of the proposal are minor to correct typos and improve the clarity of the (! “Clear Language”, amended 15 times since 2002- albeit not all for clarification) TDGR.

The preliminary consultation on the proposed amendments is open for comment until February 28, 2016. The summary and a request link for the 45+ page proposed amendment is available at:

http://www.tc.gc.ca/eng/tdg/safety-menu.htm

Stay abreast of changes with our TDG Clear Language binder publication, and TDG amendment service.

OSHA Flammable
“Light My Fire” – Calculating Flash Points for Flammable Liquids

One of the most common tests for determining hazard classification is the flash point. This humble piece of physical information is defined in various ways in various regulations, but generally is the lowest temperature at which the vapours from a flammable liquid will ignite near the surface of the liquid, or in a test vessel. This can be critical for safety, because this temperature will be the lowest possible for the liquid to cause a flash fire if released or spilled. If the material can be handled and transported at temperatures lower than the flash point, the fire risk will be much smaller.

The flash point has become the standard test for classifying flammable liquids. It’s used by the U.S. OSHA (Occupational Health and Safety Act) and HMR (Hazardous Materials Regulations) classification systems, as well as Canada’s WHMIS (Workplace Hazardous Materials Information System) and TDG (Transportation of Dangerous Goods Regulations).

Obtaining a flash point on a new product is usually easy enough. Many laboratories, particularly those that deal with petrochemicals, can perform the test for a reasonable charge. If your company has too many products to make outsourcing practicable, a flash point tester itself is comparatively low cost (as scientific apparatus goes), and a trained person can obtain data quickly and efficiently. However, both of these options do cost money. Wouldn’t it be nice if there were a way to avoid the expense?

For example, toxic materials are usually classified by a test called the LD50 (the lethal dose to 50% of test subjects). This is a more expensive, complicated test, but there’s one beautiful feature for mixtures. You don’t have to do the test if you can calculate it. This calculation basically prorates the LD50s of the ingredients based on their concentrations. While there is debate about how accurate this system is, it’s directly mentioned in the above regulations as an option if testing of the actual product has not been done.

Unfortunately, the same regulations do not directly provide us with a method for calculating a flash point. But OSHA and WHMIS are based on the Globally Harmonized System of Classification and Labelling, and TDG and the HMR are based on the UN Recommendations on the Transport of Dangerous Goods. Both of these documents do include a reference to calculating flash points if directly measured ones are not available.

That’s the good news. The bad news starts when we discover that both the Globally Harmonized System and the UN Recommendations don’t give the specific formula for the calculation. The GHS reference can be found in sub-section 2.6.4.2.2, while the UN Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria places the reference to a calculation in Appendix 6, paragraph 4. At least both of them refer to the same method, one reported by Gmehling and Rasmussen in the journal Industrial & Engineering Chemistry Fundamentals 21, 86, (1982) titled “Flash points of flammable liquid mixtures using UNIFAC”.

When we look up this article, we encounter another road block – like many scientific journals, this one is not free, and the article is behind a paywall. We have a choice; either pay up to read the full article, or see if the formula appears somewhere else.

Oh, and it helps if we know what UNIFAC is. Apparently the acronym stands for “UNIQUAC Functional-group Activity Coefficients” (making it an acronym containing an acronym), and is “a semi-empirical system for the prediction of non-electrolyte activity in non-ideal mixtures.”

A little more digging on the internet comes up with an article summarizing how to calculate various flammability measurements, published by M. Hristova and S. Tchaoushev in the Journal of the University of Chemical Technology and Metallurgy, 41, 3, 2006, 291-296, titled “Calculation of Flash Points and Flammability Limits of Substances and Mixtures.” This can be accessed, with no paywall, at http://dl.uctm.edu/journal/node/j2006-3/04-Hristova-291-296.pdf .

So, we finally have our method to calculate our flash points. Except it’s nothing like the relatively simple method for calculating LD50s. Hristova and Tschaoushev tell us the calculation will take four steps:

  1. Determine the flash point which satisfies an equation relating “the actual partial pressure of component i in a vapor-air mixture” with “the partial pressure in a gas-air mixture with a composition corresponding to the LFL (lower flammable limit) of pure component i”.
  2. Determine the flammability limits at the temperature under study using the Zebatekis equation. (This equation is helpfully included.)
  3. Determine the partial pressure of each component, using the Antoine equation, and
  4. Determine the activity coefficients using the UNIFAC method.

Easy, right?

At this point, it becomes obvious that these calculations are currently of use, perhaps, to physical chemists, but are not yet a workable solution for companies simply trying to determine if their product is in Packing Group II or III. It turns out that the molecular forces in flammable liquids are far too complex to reduce to a simple equation such as can be used for toxic mixtures. Even computer systems that model these mixtures must be taken as provisional, and certainly not nearly as reliable as measured data.

So, the day when we can toss aside our flash point testers and classify flammable liquids based only on the composition is yet to come. To comply with the classification rules for workplace safety or transportation, a measured flash point is still the simplest and most accurate solution.

Do you have any questions about classifying hazardous materials? Contact ICC Compliance Center here at 888-442-9628 (U.S.) or 888-977-4834 (Canada), and ask for one of our regulatory specialists.

When an Ordinary Box Isn’t so Ordinary After All (HazMat Box)

We have all used a fiberboard (or cardboard as most people call it) box to ship something. It may have been a box of gifts for a friend or family member, or a package of merchandise for a client at work. Most of the time, you probably didn’t give much thought to the box other than to make sure it was sturdy enough and big enough to contain what you were shipping. For these typical kinds of shipments, that ordinary box will do just fine. HazMat (or dangerous goods) shipments, however, aren’t ordinary and neither is the box that they need to be shipped in.

The packaging industry is a science in itself, with ever evolving processes, techniques, materials, treatments, and regulations. HazMat packaging is a specialized area of packaging technology, and it has some very specific requirements that must be followed. Even though a HazMat box may look identical to a standard shipping carton, there are some significant “behind the scenes” differences between them!

  1. Material matters! When dealing with HazMat boxes, there are specific tolerances for manufacturing. The combination of materials used to make up the fiberboard has very little wiggle room once the design has been approved and certified. Changes in the material may invalidate the certification and make the boxes non-compliant.
  2. Proven performance! HazMat boxes have to be put to the test before they can be certified for use. These boxes go through drop, stack, vibration, pressure, and other tests to simulate conditions they may encounter during transportation. Additionally, the design has to be re-tested every 2 years to ensure everything is still performing properly. While all packaging should protect its contents, it is extra important for boxes that contain HazMat to be up to the task.
  3. Recordkeeping! The manufacturer of a hazmat box must keep meticulous records regarding the construction, use, testing and any changes made to the packaging. These records are subject to inspection by government officials and can result in fines if violations are discovered.

These are just a few examples of what makes a HazMat box far from ordinary! Keep this in mind when you are selecting packaging for your HazMat shipments. If you need HazMat packaging, or to find out more information, call one of our customer relations centers today at 888-442-9628 in the US or 888-977-4834 in Canada.

Single Packaging
The Carrier Has The Final Say

Have you ever prepared a shipment that you were 100% certain was done according to regulation, only to have it refused by the carrier? The reason may be because carriers can put in place requirements that go above and beyond the regulations and will refuse your shipment if you do not comply. Finding these extra requirements can be simple for air shipments thanks to the Operator Variations listed in IATA Section 2.8.3. However, other modes of transport do not have the variations listed, and even the IATA variations don’t cover every possible extra requirement.

Below are a few ways you can determine if there are additional requirements for your shipment.

  1. Ask your carrier! If you are using a new carrier or shipping a new material with your current carrier, ask them if there are any additional requirements that you should be aware of before you prepare the shipment. Most carriers have dedicated Dangerous Goods agents who will be able to let you know about any extras.
  2. Check the IATA variations even for ground or vessel shipments. Many of the operator variations that are listed in IATA apply to all shipments for that carrier, regardless of the mode of transportation. One common example is FedEx’s FX-02, which requires Division 6.1 material in PG I or II to be in special permit packaging for domestic shipments.
  3. Trial and error. Sometimes, the way we learn about additional requirements is by having a shipment refused the first time we try to ship it. Most times, a carrier will let you know why they refused the shipment so that you know for the future.

Keep in mind, these additional requirements are changing just as often as the regulations are. Make sure that you are always up to date on your training and that you communicate with your carrier to ensure that your shipments are compliant. I always say in my training classes; “If your carrier wants every hazmat package identified with a pretty pink bow, go out and buy some ribbon if you want to use that carrier!”


Is your training up to date? To schedule your training, or to find out more information, call one of our customer relations centers today: 888-442-9628 in the US or 888-977-4834 in Canada.