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.
- 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.
- 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.
- Trial and error. Continue Reading…
In 1983 the science fiction film “War Games” was released. The film is set in America at the height of the Cold War where the threat of nuclear war is a topic of much speculation. The plot surrounds a hacker named David, his access to the supercomputer with artificial intelligence called War Operation Plan Response (WOPR) and a friendly game of “Global Thermonuclear War”. This game among others on WOPR was designed to teach the artificial intelligence strategy and planning. A classic line from this movie is, “Shall we play a game?” which is uttered by WOPR.
Apparently, OSHA is following in these same footsteps. OSHA has released a game. (Note: Unity Player required to play)
“OSHA’s Hazard Identification Training Tool is an interactive, online, game-based training tool for small business owners, workers and others interested in learning the core concepts of hazard identification. After using this tool, users will better understand the process to identify hazards in their own workplace.”
The point of the game/tool is to find and name various workplace hazards. The goal is for managers and workers to be proactive in preventing injury and illnesses on while on the job. There are four scenarios including Manufacturing, Construction, OSHA Visual Inspection, and Emergency Room. It is recommended start with OSHA Visual Inspection Training. To keep the game/tool from getting “stale”, OSHA had it designed to alter the scenario Continue Reading…
Dancing for Safety
Trying to maintain workplace safety is never easy. Companies write best practices, policies and guidelines regularly to keep workers safe. Where there is often a breakdown is in having people actually follow those practices, policies and guidelines. As a former educator, engaging students and having them work with me rather than against me could be challenging. Even though my subject matter was science and my students were high school students, the data is clear. Music is a powerful tool to help with learning, driving concepts home and strengthening the mind.
So, to get workers involved with their own safety perhaps the 1980s song “Safety Dance” by the band Men Without Hats can be used. (Click here to hear the song) Granted the lyrics are not exactly written for workplace safety but the rhythm of the song and the chorus can be used to ask some basic questions every employee should ask every day.
What are the basic safety questions that can keep someone safe? Various websites are dedicated to worker safety and tips for maintaining it. Below is a list of my top five.
- What is my work area?
This is important to know in case there is electrical equipment, hazardous chemicals or machinery in your area that could impact how you do a job. Be aware of any changes in the area and be sure Continue Reading…
Electrical Safety Month is over, but Safety is Important Year Round
May marked the time of year for National Electrical Safety Month. What did you and/or your employer do to participate? Many Employers held toolbox talks on electrical hazards in their facilities or about the job performed by employees in the field. They may have done refresher training for their employees or, more simply, handed out an OSHA quick card.
Electrocutions are one of the fatal four for the construction industry. Among the General Industry Standards, multiple electrical standards made the top 10 most frequently violated and cited standards in 2014. The cited standards include: control of hazardous energy (lockout/tagout), electrical wiring methods for components and equipment, and electrical systems design under general requirements.
Working with electricity can be dangerous if someone is not trained properly. Most jobs require the use of an energy source. Electricity is the most typical type of energy usage. Such professions as engineers, linemen, electricians, and others work with electricity directly, including overhead power lines. Even though it may be indirect, office workers may also be exposed to electrical hazards.
OSHA’s electrical standard for general industry in the 29 CFR regulations for general industry in Subpart S, or starting at §1910.301. As a reminder on some of handling basics when dealing with live energy, you should use equipment that is approved to meet OSHA standards. You should not Continue Reading…
That is a question that we Regulatory Specialists sometimes receive in the form of:
“Do I have to train my employee(s) in TDGR (Canadian Transportation of Dangerous Goods Regulations)/HMR (US Hazardous Materials Regulations) who are only… (serving customers, working the showroom, stock picking, etc., etc.)”.
The short answer to this question, especially over the phone, is: “Maybe.”
Definitions in both sets of regulations are quite broad in addressing what is considered under the jurisdiction of “transportation” when it comes to DG/Hazmat. HMR 49CFR§171.1, 171.8 & 172.700 to 704 and TDGR 6.1(1) & 1.4 (carrier, handling, in transport, offer for transport) deal with this topic in the US and Canada respectively.
Handling, for example, in TDGR “means loading, unloading, packing or unpacking dangerous goods in a means of containment for the purposes of, in the course of or following transportation and includes storing them in the course of transportation. “
Unlike 49CFR, however, the TDGR provides a plethora of special cases (Part 1, 1.15 et al) and special provisions (Schedule 2 as referenced in Schedule 1)- 26 of the former and 32 of the latter at last count- that exempt persons from the Part 6 training requirements (As an aside, this exemption approach seems somewhat ironic- how does a person know how to comply with the conditions of exemption if the person hasn’t been trained?).
Apart from these exemptions, Continue Reading…
O. Reg. 297, the regulation requiring all workers in Ontario under the jurisdiction of the Occupational Health and Safety Act (OHSA) to be trained in their fundamental duties and rights under the Act, takes effect July 1, 2014.
The regulation, published in November 2013, followed from a review panel recommendation resulting from an investigation into the death of 4 workers who died when a scaffold collapsed on a building in 2009. The objective of the regulation is to ensure that all workers covered by the OHSA, including supervisors are aware of the requirements.
It is worth noting that a Supervisor is a person who has “charge of a workplace or authority over a worker”. Consequently even those employees who don’t have direct reports may still meet the definition of a supervisor under the OHSA.
All workers (the definition includes managers and supervisors) must receive documented training in: the duties/responsibilities of the various workplace parties- i.e. workers, supervisors, employers, Ministry of Labour and Workplace Safety & Insurance (WSIB or ‘workers’ comp.’) Board/Agencies; common workplace hazards, WHMIS and occupational illness (including the latency concept).
In addition, Supervisors must also be aware of: how to recognize/assess/control/ hazards; how to evaluate the effectiveness of hazard controls; and sources of information related to occupational health and safety.
The Ministry has indicated on their website that a supervisor who completes the basic Supervisor’s awareness course before July Continue Reading…
Many people these days are calling themselves regulatory specialists, dangerous goods experts, or health and safety experts. The dangerous goods/hazardous materials field is a detailed, comprehensive topic requiring hands-on experience and a strong technical understanding of topics directly related to the industries we serve.
Finding the right training company is critical to ensuring that the processes and procedures you need to continue operating remain uninterrupted. Here are some questions you should consider when looking for trainers with the ‘right stuff’:
We’ve got the right stuff. Contact us today and find out more!
Download our Regulatory Specialists Bio (PDF) and learn about our team
1) What are their qualifications?
- What education and knowledge do your instructors have?
Meet our regulatory staff »
2) What experience do they have?
- How many Fortune 500 or multi-national companies have they helped train?
- How many satisfied customers have they trained over the years?
- What associations do they belong to?
- How do they find out about pending regulatory changes?
3) What other avenues do they offer?
- Can they provide the products and services that they are teaching you to use properly?
4) What is their approach to training?
- Are they offering the same course to everyone?
- Where can they train?
- Are they educated in training adults?
- Do they have an online option?
View our training locations and accommodations »
5) Are they the only person that will be working with you?
- Are they a one-person business?
- Do they have a team of experts supporting Continue Reading…
OHSA implemented GHS as part of its Hazard Communication System (29 CR 1910.1200) back in March of 2012. The full conversion is not until June 2016, but there is a phase in process that you should already be aware of. The first deadline set by OHSA was December 1, 2013. This was sort of a basic-training for employees to learn what information is on GHS labels, SDS sheets and how to recognize the new pictograms. Imagine opening the back of a truck, ready to unload its contents into your facility and you see these strange labels on your drums. These are MY drums aren’t they? They have strange looking labels on them, with familiar but slightly different pictograms, along with a few new ones. You reach for the MSDS to see just what the heck you are looking at, only to find something called a SDS. Hey, what happened to the “M”? Wow, there is a lot of information on this SDS. Quit looking for the “M” and Behold! The future.
Learning a new language can sometime s be difficult, but understanding GHS is not. The first training deadline was just a fair warning, saying “Hey! I’m here, and this is what I look like. Oh, and by the way, you are going be seeing a lot more of my kind in the future” That’s right. Did I mention, it the law? Yes, this short introductory training is required. This Continue Reading…
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…
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…