ICC's Regulatory Helpdesk
Regulatory Helpdesk: May 7

IATA declaration, limited quantity labels, training requirements, and placarding

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.

Listing Overpack on a Declaration (IATA)

Q. Caller needed to clarify what should be listed on an IATA declaration for an overpack.  I have 2 overpacks of the exact same thing. The overpack is 2 drums inside an outer overpack box. Each drum holds 18.9 L. I have it listed as “Overpack Used x 2”. For the alphanumeric identifier for each it is “Box 1” and “Box 2”. How do I list the “total quantity per overpack”?
A. Take a look at Figure 8.1.L. It shows multiple identical overpacks. The example shows 200 boxes each with a weight of 0.2 kg in each overpack. It then lists the total quantity per overpack as 40 kg, which is the result of the 200 boxes multiplied by the 0.2 kg.

For her question then it would be 2 drums multiplied by the volume of 18.9 L. The total quantity per overpack is then 37.8 L.

Limited Quantity Labels

Q. Caller was on our website and had a question about LQ marks/labels. He has a distributor in Canada that will be shipping fire extinguishers to a location in the US from Canada. They use the LQ label in Canada 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…

Countdown to WHMIS 2015 Deadline: Training Requirements

WHMIS 2015 update man working at oil refinery

WHMIS 2015 Training Requirements

Next in our WHMIS 2015 countdown series, we will discuss training requirements under the new regulation.

With the WHMIS deadline fast approaching and workplaces updating their labels and safety data sheets, one must not forget that employees will need to understand what the changes all mean.

In Canada, if a workplace uses hazardous products, then the worker must be educated and trained on the hazards of those products. This would apply to workers who are exposed to the products during their day to day work routine, anyone who stores, handles or disposes of hazardous products, supervisors or managers who meet the above criteria, and anyone involved with emergency response.

Education vs Training

What is the difference between education and training? Let’s look at the definitions, courtesy of CCOHS:

Education
Refers to general or portable information such as how WHMIS works and the hazards of the products. For example, you will learn about the hazard classes (e.g., why a product is called a corrosive, and what information you can find on labels and SDSs).
Training
Refers to the site- and job-specific information to employees that will cover your workplace’s procedures for storage, handling, use, disposal, emergencies, spills, and what to do in unusual situations.

Suggested topics for education and training include:

  • Information on the supplier label, such as the signal word, hazard and precautionary phrases and pictograms; what do they mean?
  • Information on the workplace Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 16

WHMIS 2015 concentration ranges, training, overpacks, segregation and non-DG in DG packaging

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.

New WHMIS 2015 Concentration Ranges

Q. There is a very specific list of approved concentration ranges listed in the CA regulations.  We had previously set up our ranges to be .1-10%, 10-20%, 20-30%, etc. (groupings of 10) and always included the “trade secret” caveat after our concentration list. Would this still be considered “compliant” for Canada, meaning using our ranges vs. their list of ranges?
A. There is a Regulatory Impact Assessment file that was sent out to stakeholders by Health Canada a couple days before the new amendment appeared in the Gazette II.

Under the comments received section of that file was the following:

Use of the prescribed ranges

One stakeholder agreed with the proposed amendment as it read in the context of the CGI publications, but asked for the following clarification: can smaller ranges be used if they (1) fall within an existing range, e.g. using 3.8-4.5% rather than 3-5% (as listed), or (2) when combining up to three prescribed ranges, e.g. combining ranges (e), (f), and (g) would be 5-30% but using 6-28% instead. Health Canada clarified that the prescribed concentration ranges are Continue Reading…

TDG Methanol Classification
Big Change in Methanol Transport Classification (TDG)

TDG Update - Man Staring in to warehouse

New Transport Canada Update Means Big Changes for Many Companies

Recently, Transport Canada posted on their FAQ web page, a few questions regarding shipping mixtures of Methanol.

The first three FAQs are for the most part, not surprising, with one exception in Question 2. These FAQ’s appear as follows (these FAQ’s are directly from their website): (keep reading, the biggest surprise is coming).

Question: How do I classify a product that contains methanol as the only dangerous good?
Answer: As per Section 2.3 of the TDG Regulations, when the name of a dangerous good is shown in Schedule 1, that name and the corresponding data for that shipping name (class, subsidiary class(es), packing group (PG)) must be used. Therefore, when methanol is the only dangerous good in the product and it meets the criteria for Class 3, Flammable Liquids, it should be transported as UN1230, METHANOL, Class 3 (6.1), PG II. Note that PG II is the only packing group available for methanol as per Schedule 1 of the TDG Regulations. Note: Subparagraph 1.3(2)(d)(iv) of the TDG Regulations allows a person to indicate the word “SOLUTION” or “MIXTURE” and also the concentration of the solution or mixture after the shipping name, as applicable.
Question: Tests results for a solution containing methanol as the only dangerous good indicate that its packing group should be III. How do I choose the proper shipping name?
Answer: Even if a dilution would lead to a Continue Reading…
How to Ship My Motorcycle

Riding motorcycle on dirt road

I need to ship my motorcycle. What do I need to do?

Normally around this time of the year we start to get calls about shipping a motorcycle as folks are planning their vacations and motorcycle adventures.

To be honest, I enjoy receiving these motorcycle inquiry calls because it always had to do with someone either visiting our beautiful country and now returning back home or they will be traveling to a beautiful destination and need to ship their bike. It gives me a chance to chat with them about their travels, too! Which is exciting, as I am a world traveler myself. I thoroughly enjoy speaking to them about their travels and adventures before I get into discussing the “exciting” world of shipping dangerous goods.

Here’s All that is Involved with Shipping a Bike:

We can help you! It is a simple procedure and it involves very little stress.

1. You will need to complete the “Motorcycle Declaration Form”

This can be completely electronically in the comfort of your home. This form can be downloaded here (Kel-Ex Vancouver) or here (ICC Repacking). It’s a simple document which gives us the details of your bike (i.e., shipper and consignee address, how it will be packaged, weight, confirmation that the fuel tank will be drained to less than ¼ tank upon drop off). In most cases motorcycles are dropped off “as is” meaning Continue Reading…

Regulatory Helpdesk: December 4, 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.

IMDG Editions

Q. What edition of the IMDG should I be using?
A. The customer would still need the 38th edition to get him through all of next year. The new 39th edition will be published at the end of 2018 but it can’t be used at all until Jan 1, 2019. Even then the 38th is still a viable option.
IMDG Transition Timeline

Placement of the Consignor’s Certification Statement

Q. Can the Consignor’s certification appear on a second page or on the back of the shipping document?
A. Yes, if there is no other non-DG information intervening when using the phrase in TDGR 3.6.1(1)(a). This phrase requires that the certification appear below the information specified in 3.5. The Transport Canada FAQ page indicates that the “consignor’s certification may appear on the back of the shipping document as long as it is after the information required under Section 3.5“.

Limited Quantities Under IMDG

Q. Can limited quantity provisions be used to ship under the IMDG Code?
A. Yes, but you should have IMDG Code training or consider a re-packing service if you are not trained, since the requirements are not the same Continue Reading…
Repacking Dangerous Goods
Everyone’s Favorite … Shipping Lithium Batteries!

Lithium Batteries, Laptop battery

Complying with the Regulations

Sometimes we try to find an economical solution to comply with regulations. If it works, great, but sometimes – actually most times – it comes back to bite us in the behind.

Last week a customer of ICC’s came in panicking to get help. He has previously used us a few times for our repackaging service. Let’s call him Bob. Bob told me he and his team took an online training course which certified them to ship lithium batteries via air. Bob’s shipper packaged up a lithium battery shipment and had sent it out. Bob just found out that it was rejected by the carrier. I asked Bob which UN# they used and he said UN3481. Asked him which (packing instruction) section and he said “what?”. I said, “In Packing Instruction 967, which section do you fall under?” He said, “What’s a packing instruction?”. I grabbed my IATA regulation and told him, “You guys used this book to do the course, yeah?” and he inferred that the course didn’t require use of a book and no, they didn’t use any books. I asked Bob if they took training with ICC and he said, “no”. Bob said they took training with another company and paid $50 as it was the cheapest training they could find. I told him that was his first mistake.

Carrier Conundrum

Bob said Continue Reading…

Graduation Cap
ICC Teaches A Dangerous Goods Course in Europe

Teaching DG Training in Switzerland

Going to Switzerland!

This September, ICC was offered an interesting opportunity – presenting a class on North American hazardous materials regulations in Switzerland! So, I gathered my passport and computer, and set off for Europe.

The course was organized by SAFETY Training Plus GmbH, a well-known provider of dangerous goods training in Germany and Switzerland. However, SAFETY Training Plus found that many of its customers were looking for help with shipments to North America. Although European and North American regulations are usually based on the UN Recommendations for the Transport of Dangerous Goods (better known as the Orange Book based on its cover), a number of variations still exist between the various countries and regions.

For example, a European shipper to the United States might be puzzled about why a product not classified as an environmental hazard under the EU regulations (ADR/RID) or the International Maritime Dangerous Goods Code (IMDG) for ocean would have to be treated as such for entry into the U.S. Surprise! It’s the Hazardous Substance rule, involving a list of over a thousand chemicals that are classified as environmentally hazardous in Title 49, U.S. Code of Regulations (49 CFR). Another shipment may hit a snag entering Canada due to Canada’s requirement for an Emergency Response Assistance Plan. This requirement usually applies to high-risk goods in large means of containment, but may sometimes affect smaller materials Continue Reading…

Training … Are You Up to Speed?

Training is needed in everything we do. Whether it is work, play or home we are constantly learning or being trained on something. We train our children for adulthood. We train our athletes how to run plays or moves. We are trained at our places of employment on how to do our jobs properly. Training in all aspects of life is in place to help us do things properly, help us succeed and help keep us safe.

In the workplace, how do we know just what type of training we should be getting? Obviously, it is going to change from site to site based on the type of business you work for. Regardless of the type of business, all workplaces are required by the OSH Act to provide a safe place to work. As per OSHA there are relevant types of training needed for different types of industry. These industries listed below with their appropriate regulation could be required:

If an industry doesn’t fall under a specific regulation like construction, they would follow the general industry standard. OSHA just updated their “Training Requirements in OSHA Standards” booklet. In this booklet OSHA gives a guide to all training requirements for employers, safety and health professionals, training directors and others to comply with Continue Reading…