GHS … Have You Been Trained?

I still find it hard to believe that there are some companies out there that haven’t heard of the Globally Harmonized System of Classification and Labeling (GHS). It’s hard for me to believe this, because in three months’ time everyone who works with hazardous chemicals in the workplace will have to be trained (and no I’m not kidding). December 1st, 2013 is the deadline to have all employees trained on the GHS within OSHA, yet somehow I still show up to companies to train their workers on shipping dangerous goods (this often involves employees who are in the EHS department) and I ask them if they have heard of GHS or OSHA HazCom 2012. To my surprise I still get the blank stares and the question “What is that?”. This really isn’t a bad thing for me because that means I get to help one of our clients avoid fines by informing them about more training they will need, and in many cases they have ICC train them in GHS within OSHA as well.

The GHS is what OSHA has adopted for its new Hazard Communication Standard and it was adopted in 2012 which is why the standard is called OSHA HazCom 2012. This new standard is meant to try and “harmonize” hazardous chemical communications around the globe. Before we go any further I want to Continue Reading…

Shipping Infectious Substances – TDG

Transport Canada has posted a bulletin for shipping infectious substances (RDIMS#8210418).

In the overview, Transport Canada reviews what an infectious substance is: anything that is known or reasonably believed to cause disease in humans or animals. This substance can be in blood, body fluids, body parts, organs, tissue or cultures. The responsibility of the consignor is to: train, classify, package, mark/label, document, placard and have an ERAP in place, if necessary. In addition to the definition found in section 1.4 of TDG (Transportation of Dangerous Goods Regulations), the Public Health Agency of Canada (PHAC) has regulations that apply to lab safety and the import of human pathogens into Canada. Please keep in mind that provincial governments may have additional regulations in place.

Classification of infectious substances is generally done by a medical professional. If you know that what you want to ship is an infectious substance, then it is class 6.2. In TDG, under Appendix 3 in Part 2 is a listing of regulated infectious substances. This list is not exhaustive. If what you want to ship is not on the list, but exhibits the characteristics of an infectious substance, then it is class 6.2.

The authorized shipping names in TDG are:

  • Category A
    • UN2814 Infectious substance, affecting humans,
    • UN2900 Infectious substance, affecting animals
  • Category B
    • UN3373 Biological substance, Category B

UN3291 Clinical waste, unspecified, n.o.s., (Bio)Medical waste, n.o.s., or Regulated medical waste, n.o.s. are Continue Reading…

20 Years Ago

Time flies. Can you believe that it has been 20 years since RSPA (now PHMSA) published docket HM-126F regarding training?

Final rule HM-126F is now incorporated into the 49 CFR regulations Part 172 Subpart H. Subpart H stipulates that:

  1. A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart
  2. Employees may not perform functions without appropriate training
  3. Training may be provided by the hazmat employer or other public or private sources
  4. A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the topics covered

Hazmat employee training must include the following:

  1. General awareness/familiarization training
  2. Function-specific training
  3. Safety training
  4. Security awareness training
  5. In-depth security training

Often times both function-specific and in-depth security training is better done onsite by the employer. It is the employer’s responsibility to certify that the hazmat employee can perform their job, and do so safely.

For more than 25 years, ICC has provided companies with training that complies with these regulations. We offer training that complies with the general awareness/familiarization, security awareness, safety and some function specific topics.

Ask us about our scheduled public training for ground, air or ocean at our facilities across North American. We also offer GHS training, and new OSHA compliant safety training.

Call 888.442.9628 for more information. Have a problem? We have a solution.

ICC’s GHS Hazcom 2012 Training Classes

ICC Compliance Center is excited to announce training dates for courses related to OSHA’s Hazcom 2012 (GHS standard). Classes are scheduled in our Niagara Falls, NY and Houston, TX training centers, and are soon to be scheduled around the country in the fall. We have four classes to choose from: A half-day General Awareness class; a one day “What’s Changed?”; a two day Manager/Supervisor class and a three day GHS Classification class. On-site training classes and webinars will be available soon.

We have four classes to choose from, depending on your interest. A half-day General Awareness, a one day What’s Changed, a two day Manager/Supervisor and a three day GHS Classification class.

Over the past few decades, the United Nations (UN) has been attempting to create a system with similar goals, that would be used (with possible minor modifications) on a world-wide scale. This system is called the Globally Harmonized System, or GHS.

OSHA has responded by modifying the hazard communication standard to reflect many of the concepts found in the GHS. These elements include: classification of hazardous substances, information to be provided on labels, and information to be found on material safety data sheets (or, as the GHS calls them, safety data sheets).

Training is the first deadline in the phased in final rule that was effective May 26, 2012. Training on the new elements Continue Reading…

Onsite Training Comes to Houston

ICC Compliance Center is proud to introduce onsite training in the Houston area. We currently provide various types of hazardous materials/dangerous goods training and certification to meet our customers’ requirements, including live-classroom, web-based or instructor-led webinars and onsite training.

We Bring the Classroom to You

Our regulatory specialists will come to a location of your choice, eliminating any travel expenses for your employees (ex. gas, airfare, hotel, rental car and dining).

Our experienced staff can develop and deliver many types of programs created especially for your company’s individual dangerous goods and hazardous materials requirements (products, modes of transport, shipping systems, etc.), together with practical suggestions for effective implementation.

Customized Onsite Training Gives You Control Over:

  • Course structure
  • Class location, size and audience
  • Class schedule – schedule the training around your company’s workload
  • Confidential information – With only your employees present, sensitive and proprietary issues can be addressed and used as examples during class
  • Course retention – Studies have proven workers are able to learn more when they study together. The effects of a shared training experience continue long after the seminar has ended

Meet ICC’s Trainer in Houston

David Lyle FordDavid Lyle Ford has recently joined our team as a Regulatory Specialist, and specializes in dangerous goods, i.e. CFR 49, TDG, IATA, and IMDG. David came to ICC from a global petrochemical manufacturer where he was responsible for all modes of transport including railroad, highway, sea and Continue Reading…

DGIS VI (Part I)

I attended the sixth Dangerous Goods Instructor Symposium (DGIS VI) hosted by LabelMaster in Memphis TN last week.
Things started on Tuesday evening with the Dangerous Goods Trainers Association (DGTA) meeting. The changes concerning NESHTA, BCSP, IHMM and others were discussed. Bob Richard has suggested the DGTA make application at the UN for consultative status. This would allow DGTA to attend the UNSCOE on TDG as observers or as a NGO (non-governmental organization). The website has been updated, see www.dtga.org/. There was also discussion on which trade shows that DGTA should attend.

Later that night some of us boarded buses to go the the FedEx world hub. Here we were given a tour of the FedEx Memphis Hub (night-side) facilities.

Some interesting points of interest:

  • handles approx. 1.3 million packages daily
  • averages 140 landings per night (every 90 seconds)
  • averages 140 takeoffs per night
  • aircraft unloaded in under 30 minutes
  • fleet of more than 366 aircraft (727s to A300s to 777)
  • 7,000 employees at the hub
  • covers 863 acres
  • approx. 42 miles (68 km) of conveyor belts

Thanks to David Jones of FedEx for arranging the tour.

The Wednesday morning session on the ABCs of Training Objectives. This workshop covered the basics in making brief, concise, clear learning objectives. After lunch, Howard Skolnik of Skolnik Industries did a hands-on session on Writing of packing and closure instructions: an exercise in authorship. Howard gave each table an exercise on writing Continue Reading…

Lithium batteries by air

Shipping lithium batteries has become a confusing issue. Let’s start by asking "what is a lithium battery?". There are two types of lithium batteries – metal and ion (polymer). The lithium metal battery is also termed "primary" which means non-rechargeable. Typically you find these batteries in watches, calculators, cameras, etc. Lithium ion (and polymer) are "secondary" or rechargeable batteries. These are found in mobile phones, laptop computers, satellite navigation units, etc.

As most shippers are aware, ICAO/IATA rewrote the packing instructions for shipping lithium batteries by air for 2009. In the 51st Edition of the IATA Dangerous Goods Regulations for 2010, the packing instructions for lithium batteries have changed again.

First a quick review: the shipping name Lithium batteries is now either Lithium ion batteries or Lithium metal batteries. And for each of these shipping names are two (2) more: contained in equipment or packed with equipment. The shipping descriptions are:

  • UN3090, Lithium metal batteries
  • UN3091, Lithium metal batteries contained in equipment
  • UN3091, Lithium metal batteries packed with equipment
  • UN3480, Lithium ion batteries
  • UN3481, Lithium ion batteries contained in equipment
  • UN3481, Lithium ion batteries packed with equipment

The packing instructions in the 51st Edition of the IATA Dangerous Goods Regulations now consist of 3 sections. Packing instructions 965-970 each consist of: