What is REACH?

REACH stands for Registration, Evaluation, Authorization, and restriction of Chemicals. This United Nations (UN) law took effect June 1, 2007 and falls under the ECHA (European Chemicals Agency). REACH requires the registration of approximately 30,000 chemical substances produced in or imported into the European Union (EU). It places greater responsibility on industry to develop information on and manage the risks that chemicals may pose to human health and the environment.

The main goals of REACH are to ensure a high level of protection of human health and the environment from the risks that can be posed by chemicals, the promotion of alternative test methods, and the free circulation of substances on the internal market and enhancing competitiveness and innovation. REACH places the burden of proof on companies. To comply with the regulation, companies must identify and manage the risks linked to the substances they manufacture and market in the EU. They have to demonstrate to ECHA how the substance can be safely used, and they must communicate the risk management measures to the users.

REACH impacts on a wide range of companies across many sectors, even those who may not think of themselves as being involved with chemicals, Including: Chemical Manufacturers, Importers, downstream users (customers) and companies outside the EU. The responsibility for fulfilling the requirements of REACH, such as pre-registration or registration lies with the importers established in Continue Reading…

Minimum Height of UN Numbers on Packages

Are my eyes getting better with age or did something change? Something changed.

New to the regulations this year is a statement regarding the size of text on labels for dangerous goods. Both IATA (Air) and IMDG (Marine) have made changes to reflect the UN Model Regulation that become mandatory as of January 1st, 2014. Please reference “UN Model Regulations: 17th Edition; Section 5.2.1.1 (Vol 2. pg. 139)”, “IATA: 54th Edition; Section: 7.1.5.5 – Size (pg. 619)” and “IMDG Code: 2012 Edition; Section: 5.2.1.1 (Vol 1. pg. 244)” to find the following information.

As of January 1, 2014, mandatory size for “UN number” and letters “UN”:

Letter height requirements

Some things to note:

  1. The way this is written is such that the UN number and letters “UN” MUST be at least the size specified above whereas other package markings SHOULD be that minimum size.
  2. Other package markings include the proper shipping name, technical name, the word “Overpack”, and any other markings.
  3. For IMDG, cylinders marked in accordance with the 2010 version of IMDG are acceptable until no later than July 1st, 2018 (and only if marked by December 31st, 2013), otherwise the sizing requirements must be followed.

Letter height requirements

DGTA

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

We’re Ready When OSHA Is!

ICC is ready for GHS

In January 2011, OSHA proposed that in August of this year, they would publish the final rule to align the current Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The more recent DOL Spring semi-annual regulatory agenda released in June revisits the scheduling of the release of the HCS revision to an unspecified date in September of this year. September has now come and gone, and we are still without a final rule from OSHA.

This leads to the question of “If not now, then when?”. It is probably a safe assumption that OSHA’s lack of implementation of GHS to date will be a major topic of discussion at the October 1st – 5th Society for Chemical Hazard Communication (SCHC) fall conference in Washington, DC. Many health and safety professionals, myself included, will be impatiently waiting for word of a revised deadline.

At ICC, we have been preparing for the new requirements so that we are ready when OSHA is. Updates and products related to GHS can be found on our website at: http://www.thecompliancecenter.com/regulations/ghs.htm

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…

GHS Implementation – A Quick Guide for International Suppliers

Slowly but surely, the Globally Harmonized System (GHS) is becoming "the way things are done" for hazard communication around the world. Many countries have already implemented internal versions of the GHS. Others, such as the United States and Canada, are on the verge of introducing their own. How does one keep track of who’s doing what? Here’s a list of some of the most vital resources for those concerned about hazard communication worldwide.

  • The UN "Purple Book" (Globally Harmonized System of Classification and Labelling of Chemicals). This document is the basis of the GHS around the world. It is developed by the UN Subcommittee of Experts on the Globally Harmonized System (UNSCEGHS). The GHS Subcommittee has been tasked with producing biennial updates to this document; currently, the book is in the third revision (2009-2010). You can obtain a downloadable PDF version of the Purple Book at unece.org. The download is free and you do not have to register. Hard copies are available through our online store (US | Canada).
  • UN Guidance documents. Although the Purple Book is, at first glance, written in reasonably clear language, some of the sections are very technical. The UN has provided some guidance documents that can help readers understand the rules in more general terms. These guides include:
Government of Canada

Canada Gazette, Part II, EXTRA Vol.143, No. 3 is the proclamation proroguing Parliament to March 3, 2010. As a result of this proclamation, the Government of Canada virtually comes to a standstill: Parliament does not meet, committees are suspended, etc. In other words, TDG Amendment 8 is delayed yet again.

I often get the impression the international community is beginning to look at Canada as a banana republic. Schedule 1 of the TDG Regulations is at the 11th Edition of the UN Recommendations and everyone else is working on the 15th Edition. And we are not making any headway.

If you received a shipment marked UN3471 and looked it up in Schedule 1 of the TDG Regulations, you will notice that it is not listed. Do you know where to go to see if it is a valid UN number?

So, Prime Minister—once Parliament resumes on March 3, what are your plans to get the government working? Are you going to direct the Minister of Transport, John Baird, to get the lead out and publish Amendment 8? Will Minister Baird direct Marie-France Dagenais to expedite amendments to fix Amendment 6 and bring Canada into line with the international community, i.e. 15th Edition of the UN Recommendations? Why is this so hard?

Prime Minister—New Year’s resolution for you: I’m sure you have heard of Mike Holmes’ slogan, "Make It Right"; how Continue Reading…

2010 Vancouver Olympics

Transport Canada has posted on its website two (2) proposed interim orders that will cover the Vancouver Olympics. The first one is titled "Interim Order Respecting the Transportation of Dangerous Goods Into, Through or Within Controlled Access Zones". This proposed interim order, once approved by the Governor in Council would expire on March 4, 2010. The order sets boundaries which creates the access zones.

Zone 1 is the downtown core and dangerous goods requiring an ERAP, in class 1.1, 1.2 and 1.5, and in class 7 may not move into, through or within. Any placarded vehicle is only allowed access between midnight and 0600.

Zone 2 covers the Whistler/Sea to Sky Corridor and only during the midnight to 0600 can placarded vehicles and dangerous goods under ERAP move within the zone.

For zones 3 to 12, the time restriction is midnight to 0600 for dangerous goods that require placards and ERAP.

Further information can be found at: http://www.tc.gc.ca/eng/tdg/olympics-controlledaccesszones-322.htm.

The second proposed interim order is titled: "CBRNE Response Program for Orphaned releases of dangerous goods". This proposed interim order gives the Minister the authority to have an emergency response assistance plan (ERAP) holder implement their plan for the purposes of a security (read terrorist) incident involving orphaned dangerous goods.

This proposed interim order would make use of industry’s expertise and response capability during the Vancouver Olympics and the G8 conference which is to Continue Reading…

ERAP

Some questions for you to ponder regarding ERAPs:

  • does your company have an emergency response assistance plan (ERAP)?
  • has it been reviewed by Transport Canada?
  • do you use a third party provider to provide the technical information?
  • do you use a third party provider to respond to the incident site for remediation?

If you are using a third party for incident response, have you:

  • recently audited the provider?
  • ensured that they have the proper tools to handle your products?
  • provided training on your products?
  • ensured that they have the proper equipment, i.e. UN specification packaging, correct specification tankage, hoses, couplings, etc.?
  • checked that they are following the closure instructions for the UN specification packaging?
  • checked to make sure that they are providing the right technical information?
  • checked to make sure that they can respond to wherever the incident is?

Keep in mind that when there is a dangerous goods incident involving an ERAP, it is the ERAP holder who is held responsible for the emergency response.

Are YOU prepared for any emergency?

Placarding

TDG 4.15(2) is up for discussion again. Transport Canada is stating that a change to the regs is being considered and it should harmonize with 49 CFR.

Transport Canada is also suggesting that the "inspector community" should take the least restrictive of options available in TDG, i.e. return to using the DANGER placard.

Is anyone at Transport Canada, MACTDG or NCWG talking to emergency responders? Just what does the DANGER placard tell them?

And if the shipping document is destroyed and the driver transported to hospital, how is the public safety served by use of the DANGER placard?

How about a novel idea? Now that the author of "Clear Language" is gone, adopt the UN Recommendations.