OSHA Flammable
“Light My Fire” – Calculating Flash Points for Flammable Liquids

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…

Safety Data Sheets (SDS)
SDS Research for OSHA HazCom 2012

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…

UN Performance Packaging – Filling Limits

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:

For liquids:

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…

ERAP – When?

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…

4th Revised Edition of the ‘Purple Book’ (GHS) – What’s new

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…