ICC Compliance Center
Ed Mazzullo Honored at 40th DGAC Annual Summit and Exposition
Ed Mazzullo Honored at 40th DGAC Annual Summit and Exposition

If you’ve ever applied for an interpretation from the U.S. Department of Transportation, or even looked one up online, chances are you’ve found a solution to your problem in a letter signed by Edward Mazzullo, longtime Director of the Office of Hazardous Materials Standards of the U.S. Department of Transportation (DOT). Mr. Mazzullo’s commitment to clarifying the complexities of the Hazardous Materials Regulations, as well as his career devoted to developing and improving regulatory standards, has resulted in him being awarded the George L. Wilson Award by the Dangerous Goods Advisory Council (DGAC) at its 40th Annual Summit and Exposition in Arlington, VA.

Each year, DGAC, a major organization for the education of the private and public sectors on transport of dangerous goods issues, presents the George L. Wilson Award to an individual, organization or company that has demonstrated outstanding achievement in the field of hazardous materials transportation safety. Previous winners include former members of the DOT, but also representatives of industry, and international representatives such as Linda Hume-Sastre, who labored for many years on the Transportation of Dangerous Goods Regulations for Transport Canada. Even CHEMTREC, the well-known emergency information service, has received the award.

DGAC presented the award to Mr. Mazzullo at a lunch attended by many hazardous materials professionals who have benefitted from his guidance through the years. We applaud his long service, and dedication to Continue Reading…

Lockout Tagout
What Does Oct 17, 2016 Mean to You?

October 17, 2017 is the deadline for Transport Canada’s Air Cargo Security (ACS) Program.

What is the ASC program?

It is a cargo security program that:

  • meets the highest aviation security standards;
  • reduces risks to the safety and security of the travelling public; and
  • keeps goods moving in and out of Canada efficiently.

Business must apply to participate in the program in order to screen, store, transport, tender or accept secured air cargo.

Companies must choose a category that best suits their role in the supply chain. These categories include:

  • Known Consignor – originates air cargo that has been made secure through a screening process applied at the time of packing.
  • Certified Agent – stores, transports and/or accepts cargo that an authorized Air Cargo Security Program participant has screened and made secure.
  • Regulated Agent – screens cargo on behalf of others to make it secure and subsequently stores and/or transports the secure cargo.
  • Account Consignor – originates cargo and has it screened by an authorized participant in the Air Cargo Security Program to make it secure.
  • Authorized Cargo Administrator – directs the movement of secure cargo without coming into contact with it (i.e., provides logistics services without screening, storing and/or transporting the secure cargo).

Participants must submit an application to Transport Canada which will be vetted, followed by an inspection and ongoing oversight.

It should be noted that this program is completely Continue Reading…

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.

Changes to Reporting – Surface Transport

The section on reporting accidental releases, Part 8, called “Accidental Release and Imminent Accidental Release Report Requirements,” has been removed from the regulations and replaced with a new Part 8 titled simply “Reporting Requirements”.

First, the amendment removes the definitions for “accidental releases” and “anticipated accidental releases” and replaced them with definitions for “releases” and “anticipated releases”. This means that the reporting requirements will now cover intended releases as well as those that occur by accident.

Next, Transport Canada has adjusted the quantities of a release that would trigger reporting. For road, rail and water transport, these changes include:

  • The limit is lowered to any amount for Class 1, Explosives; Class 2, Compressed Gases; Classes 3, 4, 5, 6.1, or 8, in Continue Reading…
Toxic
The Zika Virus — Public Health Crisis and Regulatory Puzzle

Zika virus – the name itself sounds exotic and dangerous. It is believed to be a serious risk for pregnant women. And it’s due to arrive in North America. Just how great a danger is this virus, and how should research and medical facilities prepare for the regulatory burden?

First of all, Zika is not a new virus. It has been known since the 1950s in equatorial Africa and Asia, but only recently has it appeared to migrate to new territories, including South and Central America, the Caribbean and Mexico. It is primarily a mosquito-borne illness, transmitted by the Aedes genus of mosquitos. Possibly climate change has increased the populations of these mosquitos in the areas where Zika is spreading. Aedes mosquitos are found in some parts of the U.S., and although they are not currently believed to be in Canada, they may spread as the climate warms. Person-to-person transmission by body fluids is possible, but this would be relatively rare compared to the mosquito vector.

Zika is classed in the Flaviviridae family of viruses, along with dengue fever, West Nile virus and the notoriously dangerous yellow fever. However, compared to these, Zika is usually a mild affliction. According to the Centers for Disease Control (CDC), only one in five persons infected with the virus shows any symptoms at all. For those who do fall ill, the symptoms Continue Reading…

TDG
Know Your Exemptions – the 500 Kilogram Exemption (TDG Section 1.16)

Like most regulations based on the UN Recommendations for the Transport of Dangerous Goods, Canada’s “Transportation of Dangerous Goods Regulations” (TDG) includes a number of exemptions. These provide easier and more cost-effective ways for shipping low-risk materials. However, each exemption needs to be carefully studied. If you don’t comply with all the requirements, you are not entitled to any part of the exemption.

One of the most misunderstood exemptions in TDG is found in section 1.16, the “500 Kilogram Exemption.” The provisions in this section originated in a long-ago series of permits intended to make shipment of small quantities of dangerous goods easier. Over the years, changes to this section have reduced its effectiveness; it still may be a helpful exemption in certain specific cases, but it must be used appropriately.

The first myth about the 500 kilogram exemption is that it is a total exemption from all requirements of TDG. This is far from the truth. At best, the exemption relieves the shipper from Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks) and Part 5 (Means of Containment). All other requirements of TDG will still apply. This includes, for example, the requirement that the carrier and all handlers must be TDG-certified. At one point, receivers were exempted from Part 6, Training, but this relief was removed in an amendment several years ago.

Obviously, the exemption only applies Continue Reading…

TDG
TDG Amendments Takes Effect

Have You Made Your TDG Updates Yet?

The holiday rush for 2014 is over. Our parties have been held, and our gifts are unwrapped and appreciated. But if you’re a dangerous goods shipper or carrier, you can’t relax just yet. New requirements from Transport Canada become mandatory, January 15, 2015. So, it’s time to make sure that everything in in compliance with the new system.

Back on July 2, 2014. Transport Canada issued two amendments to the Transportation of Dangerous Goods Regulations (TDG). One was called the Safety Mark Amendment, and the second was the Update of Standards Amendment. Both will have important effects on dangerous goods shipping procedures, and will need to be addressed immediately if you want your shipments to remain in compliance.

If your organization hasn’t already done so, it will need to review these amendments and make all necessary changes as soon as possible. Here are some of the most critical changes:

  • Non-bulk packaging must now be selected for ground shipment using a standard published by Transport Canada, called Transport Canada Standard TP14850E, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and, 9, a Transport Canada Standard.” Note that this is available as a free download from the Transport Canada site at http://www.tc.gc.ca/publications/en/tp14850/pdf/hr/tp14850e.pdf
  • Consignors of dangerous goods must keep on file a “proof of classification” for all dangerous goods they offer Continue Reading…
Applying for an Equivalency Certificate in Canada

So, you want to bend the rules? What happens when you have a scenario where following the regulations to ship your dangerous goods becomes impractical to the point of impossibility?

This blog entry will speak to what the process is for applying for an Equivalency Certificate in Canada as per the Transportation of Dangerous Goods Clear Language Regulations.

Generally when people ship dangerous goods, the process becomes a matter of reading and complying with everything the regulations state. However, below are some scenarios where following exactly what the regulations state is… shall we say… less than ideal.

Scenario 1)

Al wants to ship some large batteries for equipment within Canada with classification:

               UN 2794, Batteries, Wet, Filled With Acid, Class 8, P.G. III

His dilemma is that when a new battery is commissioned, the outer package is generally discarded due to space limitations. In many cases these batteries were installed prior to the packaging requirements of Part 5 of the TDG Regulations.

Al wants to ship this without UN approved packaging.

Scenario 2)

Bill wants to ship a MRI machine that contains liquid helium, classification:

               UN 1963, Helium, refrigerated liquid, Class 2.2

His dilemma is that his MRI machine is what contains the Helium and it is not in an approved means of containment. He requires the helium to remain in his equipment during transport in order to keep the magnet cool.

Bill wants to ship this Continue Reading…

Emergency Response Requirements for Shipping Papers

What information do you need on a shipping paper or an emergency response situation? Depending on the country you are shipping from, the answer can vary.

Canada

The Transportation of Dangerous Goods Regulations, Part 3, (1) 3.5(f) and (2) outlines the requirements for the shipping document.  These requirements include:

Having the words “24 hour number” followed by an active 10-digit telephone number xxx.xxx.xxxx,

  1. Being able to reach the consignor immediately, and
  2. Providing technical assistance without breaking the connection. An outside agency that is registered with the emergency response provider may be used.

USA

The requirements outlined in the 49 CFR  [172.201(d) and 172.604(b)(1)&/or(2)] states that if the shipper is using an Emergency Response Information provider or an agency on their behalf, a 24-hour telephone number and name of the person or contract number must be added to the Emergency Response Shipping paper.

Recently, an FAA inspector visited a customer of ours and the Emergency Response information on the shipping document was something they checked.  As part of their audit, they called the number listed on the form to verify that the contract number was indeed valid.

Remember, during a transport emergency, first responders rely on this information to react to the situation quickly and to react with the correct protective and fire-fighting measures.

Do you need a 24-hour emergency response service?

24-hour emergency number

ICC has a 24-hour phone number available in the USA, Canada and internationally.

Call us today: Continue Reading…

New Limited Quantity Mark

Transport Canada announced at the COSTHA annual forum that they are moving quickly to update the regulations to permit the use of the new limited quantity mark:

New limited Quantity Mark

Click here to see our limited quantity labels.

Marie-France Dagenais, Director-General of the Dangerous Goods Directorate at Transport Canada told the forum that equivalency certificates will be issued to shippers that apply for them, to allow them to use the new mark. It is expected that an amendment on dangerous goods safety marks will be published in the Canada Gazette, Part I, sometime in June of this year.

Regulatory news

Some topics that were discussed at the last Regulatory Affairs Committee meeting of the Canadian Association of Chemical Distributors (CACD www.cacd.ca).

  • The CACD board of directors has approved a new standing committee – Health and Safety; there will be more news about this committee as it comes together
  • CACD has re-branded and launched its new website at its 25th anniversary AGM which was held in St. John’s NF this past June
  • the Auditor General will be reviewing the TDG directorate and will include the emergency response assistance plan (ERAP) programme in the review; the objective is to determine if the programme has value to Canadians; in general, experience has shown that emergency responders do not make use of ERAPs.
  • the MACTDG met in May at which Amendment 12 was discussed and CACD’s response to this amendment were presented
  • the security group of Transport Canada may be announcing that they will harmonize with the US regarding security issues, which we will hear more about later this year
  • CACD’s voice has been heard (along with others) regarding the Generic Products Regulations that Health Canada and Environment Canada buried in the mercury containing products regulations; the government has withdrawn the proposed legislation
  • the Consumer Product Safety Directorate (CPSD) of Health Canada has formed a new team to implement GHS; this team will be reviewing the decisions made by the CIC (Current Issues Committee), for example: