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 Continue Reading…
The Next Revolutionary War?
For many, this transition period to OSHA HazCom 2012 from the Hazard Communication Standard of 1994 can best be summarized by Thomas Paine’s famous quote, “These are the times that try men’s souls.” While it was used in the pamphlet The American Crisis to deliver the ideas of the Revolution to the people of early America, there are many in the throes of classifying chemicals, substances and mixtures that feel this quote applies to daily life.
There is pressure on SDS authors, either internally or externally, to “get it right”. How can we be sure our classification is accurate? Did we cover all the hazards? Did we use the correct data? Should we check other sources? These last two questions can be the most difficult to answer.
To be a “good” SDS writer, never stop at just one source of data. Since OSHA chose not to use the exact language out of GHS Revision 3 and only selected certain building blocks when developing HazCom2012, care should be taken when utilizing classifications from other world areas. One has to remember that many other world areas did the same thing. Using classifications derived under another country’s system could lead to some over-classification, or under, depending on which country’s system is used.
A prime example of this would be Toluene. A straightforward colorless, insoluble, liquid chemical used mostly as a solvent, Continue Reading…
David Bowie’s 1971 album “Hunky Dory” included the song “Changes” which was released in January 1972. While being recognized as one of Bowie’s most well-known songs, it never made it in into the “Top 40”. One of the lyrics from that song is
“Ch-ch-ch-ch-Changes / (Turn and face the strain) Ch-ch-Changes”.
Those lyrics are most appropriate given the release of the UN ECE Secretariat’s publication of the changes to the 5th Revised edition, which will lead to the creation of Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Sixth Revised Edition.
Here is the link to published changes document.
Six of the changes coming to Revision 6 are as follows:
- Desensitized Explosives. A new hazard class for Revision 6 which carries the definition of “solid or liquid explosive substances or mixtures which are phlegmatized to suppress their explosive properties in such a manner that they do not mass explode and do not burn too rapidly and therefore may be exempted from the hazard class “Explosives” (see Chapter 2.1; see also Note 2 to paragraph 188.8.131.52).” This new class will have four categories and include its own label elements, H phrases and P phrases.
- Pyrophoric Gases. Chapter 2.2 entitled “Flammable Gases (Including Chemically Unstable Gases) is changing to “Flammable Gases”. While the title change is not necessarily newsworthy, the inclusion of the hazard class pyrophoric gases” is. This hazard class now Continue Reading…
Transport Canada published in Canada Gazette, Part I, the amendment titled “Part 4 Dangerous Goods Safety Marks”. Notable changes include:
- introduction of overpacks
- modifications to the use of the DANGER placard
- introduction of new safety marks (3)
- new proposal for placarding large means of containment
Let’s start with the overpacks. Currently under TDG, overpacks are not recognized although they are being used. And this is causing enforcement issues. TC considers an overpack to be a large means of containment. The definition for overpacks will be added to section 1.4 of TDG. Safety marks for overpacks is covered in section 4.10.1. As part of this section, when the overpack has a capacity ≥ 1.8 m3, then safety marks must appear on two opposite sides of the overpack.
The new safety marks to be introduced are:
All the safety marks are in the UN Model Regulations, ICAO Technical Instructions, IMDG Code and 49 CFR.
The requirements for placards will undergo a major change. The table in TDG section 4.15 is replaced. Placards will be required on both ends and sides of a large means of containment. The subsidiary placard requirements do not change. UN numbers on a placard or orange panel will be required when an ERAP is required, or the dangerous goods are liquids or gases in bulk. IBCs (intermediate bulk containers) will be permitted to only have 2 placards with UN Continue Reading…
UN Packaging codes reveal necessary information about a package’s specifications. They provide concise answers to questions of:
what it can hold, how much, where it was authorized, when it was made, etc.
The UN packaging code, however, doesn’t always tell the whole story…
Although there may be other test levels achieved, these may not be reflected on the packaging itself. For example, take a steel drum that has successfully passed the most stringent tests (PG I), and is marked accordingly with the ‘X’ performance level. This package, in all probability, can/has also passed the less rigorous tests required to meet both the ‘Y’ and ‘Z’ performance level. (Referencing a testing certificate, a test report, or the registration of a successfully tested package, will confirm this.)
So what does this all mean?
Filling limits for single or composite packaging, containing less hazardous material for which they were tested & marked (e.g. PG III material in a PG I packaging), can be re-calculated as per below.
Provided all the performance criteria can still be achieved by the higher relative density product, the following will apply:
a. A packing group I packaging may be used for a packing group II material with a specific gravity not exceeding the greater of 1.8, or 1.5 times the specific gravity marked on the packaging.
b. A packing group I packaging may be used for a packing group III material with Continue Reading…
One of the conundrums of the Transportation of Dangerous Goods Regulations (TDG) is the requirement to have an ERAP for a UN number that is not listed in Schedule 1 of TDG.
The problem we run into is that Schedule 1 is only up to the 11th Edition of the UN Recommendations on the Safe Transport of Dangerous Goods (model regulations). In section 1.3.1, item 39 in the table of standards indicates that TDG is at the 14th Edition of the model regulations. But since the 13th Edition of the model regulations, the UN has issued over 130 new classifications.
But section 1.10 of TDG states:
A person may use the appropriate classification set out in the ICAO Technical Instructions, the IMDG Code or the UN Recommendations to transport dangerous goods within Canada by a road vehicle, a railway vehicle or a ship on a domestic voyage if these Regulations or the document from which the classification is taken does not forbid their transport.
This means that if the consignor cannot find a classification in TDG, then the consignor can use a classification from the model regulations, ICAO Technical Instructions (TIs) or the IMDG Code. And this is where the conundrum lies. TDG section 7.1(12) states:
Any substance that would require an ERAP if its classification were determined in accordance with Part 2, Classification, requires an approved ERAP if its classification from the Continue Reading…
At the United Nations, the Sub-Committee of Experts on the Transport of Dangerous Goods (TDG) have unanimously granted observer status to the Dangerous Goods Trainers Association (DGTA).
This means, that as a non-governmental agency (NGO), DGTA will be able to contribute and comment on proposals and changes to the model regulations. Members of DGTA will be able to share their vast wealth of knowledge and experience with this regulatory body.
Dr. Bob Richard (Labelmaster) was insturmental in writing up the application and presenting at the UN. The chair of DGTA, Leif Soderman (Optimal Assistans Sweden), will be representing DGTA at the TDG meetings.
For more information on the DGTA, please go to www.dgta.org
So, what’s going to be coming in TDG in the next year?
Well, let’s start with an Equivalency Certificate for limited quantities. Members of the Canadian Paint and Coatings Association have an Equivalency Certificate (http://www.tc.gc.ca/tdg/permits/htm/10832-eng.htm) for the use of the new limited quantity mark. If Transport Canada is not going to have this in a very near future amendment, then why don’t they issue the Equivalency Certificate to all shippers?
Amendments 8, 9 & 10 have come into force this year. Amendment 11 was sent to the Minister on October 20 and it deals with correcting errors in Amendment 6. The next step for Amendment 11 is a consultation phase.
Amendment 12, which was reviewed last June, is a large amendment with emphasis on placarding and introduces the overpack. The comment review was completed in June and it may go direct to Gazette II.
Amendment 13 will deal with the standards and Part 5 Means of Containment. This proposal has been at Justice since June and its next stop should be Gazette I.
Amendment Q will be an update of Schedule 1 and 2. Amendment 12 was to take us to the 17th Edition of the UN Recommendations on the Safe Transport of Dangerous Goods, so why would a separate amendment be needed for the Schedules? Interesting that Schedule 3 is not listed in this proposal – typo? The next step Continue Reading…
I am beginning to feel like Peter Mackay of Hazardous Cargo Bulletin (HCB) – doing this in two parts. Cheers Peter!
The Thursday session continued with Richard Bornhorst, USCG, on Amendment 35 of the IMDG Code. This amendment is at the 16th Edition of the UN model regulations, but does not include the revised EHS/GHS criteria. Some of the new issues with this Amendment are:
- the new limited quantity mark
- new Chapter 5.5 on fumigated containers, including a fumigation certificate
- UN3166 Engines, has two new special provisions 961 & 962
- new TIH n.o.s. entries UN3488 – 3494, such as sour crude oil
- training record retention
- monitoring equipment as part of a CTU does not need to be declared
Some proposals for Amendment 36 are:
- revised EHS/GHS criteria
- adopt the 17th Edition of the UN model regulations
- revision of Chapter 7 – simplified stowage and packing requirements for Class 1 based on vessel type
- books to be published every 4 years with amendments every two years
- new illustrations
- new guidelines for packing CTUs
- revised circular on CTU inspections that contain dangerous goods; 56,000 CTU inspected worldwide in last year with 51,000 in the US alone
Bob Richard then continued the presentation on:
- DSC 16 (Sub-committee on dangerous goods, solid cargoes and containers) on fibre bulk containers (FBCs) – these will be restricted to a stacking height of 3, and restricted on long distance roll on, roll off (RoRo)
- batteries tested prior to 2014.01.01 will be grandfathered
- there Continue Reading…
In June of 2011, the fourth revised edition of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS, Rev.4) was issued.
The changes in the latest revision include two new hazard categories : chemically unstable gases and non-flammable aerosols. These new categories account for hazards not previously addressed where special precautions are needed when handling, storing or transporting these items. Acetylene, a commonly used welding gas is an example of a ‘chemically unstable gas’. Acetylene is unstable and can explode without an ignition source at pressures as low as 25 psi (172 kPa). For that reason, Acetylene is normally sold ‘dissolved’ in porous Acetone to allow for higher pressures. Additionally, a non-flammable aerosol, still presents a pressurization hazard and can explode if heated, even though it is not technically ‘flammable’.
The 4th Revised Purple Book provides additional clarification of some of the hazard criteria, such as for gases under pressure or mixture cutoffs for Category 1 Carcinogens; and further rationalization of precautionary statements, such as ‘P251 – Do not pierce or burn, even after use’ for non-flammable aerosols as well as flammable aerosols.
Also added, is a new special labelling arrangement for materials that are only corrosive to metals and not corrosive to the skin and eyes. The new option for the Competent Authority is to allow the hazard pictogram for the ‘Corrosive to metals’ category to Continue Reading…