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 ICAO Technical Instructions, the IMDG Code or the UN Recommendations is used as permitted under section 1.10 of Part 1, Coming Into Force, Repeal, Interpretation, General Provisions and Special Cases.
For example, as the consignor, you have an IBC (1,500 L) of sodium cyanide solution, UN3414 to ship. As UN3414 is not listed in TDG, you go to the model regulations for the classification. But the model regulations don’t have an ERAP index, so how do you determine if an ERAP is required? Or, you have 2 x 20 L drums of iodine, UN3495, to be shipped and you use the TIs for your classification. The TIs don’t have an ERAP index, so how do you determine if an ERAP is required?
To determine if an ERAP is required for your shipment where the classification is not in TDG, go to: http://www.tc.gc.ca/eng/tdg/clear-newerapnumbers-87.htm and scroll to the table at the bottom of the page to see if your product is listed and what the ERAP index is. Please bear in mind that all the requirements of Part 7 apply to the numbers listed in this table.
by Suzanne Levac on January 10, 2012 at 8:00 am · in Suzanne's Blog
During the holiday season, we bought ourselves a new cell phone. Once back home, we wondered what to do with our old cell phone. We found out that mobile phones and accessories contain a variety of toxic materials including lead, nickel, mercury, manganese, lithium, zinc, arsenic, antimony, beryllium and copper. Most of these metals are highly toxic to humans and the environment. There are several metals and chemicals in cell phones that are very hazardous to health.
Here is a description of the ill effects of each of these metals and chemicals that are present in cell phones – a reason why you should give your old phone for recycling, and not throw it in the garbage bin.
The effects of lead poisoning are well known. If absorbed into the bloodstream in sufficient quantities lead, which is used in the circuit boards of mobile phones, causes serious liver and kidney damage in adults, and neurological damage in children.
Nickel, a substantial quantity of which is present in handset batteries, causes cancer. Similarly, mercury (not mentioned in the table) is another dangerous substance found in batteries, especially in older devices. Even a small amount of mercury can harm humans adversely. Though the use of mercury has been reduced in cell phones to a great extent, it is present in fairly large quantities in older phones.
Magnesium induces neurochemical changes and has been identified as a contributing factor to developing Alzheimer’s. Manganese, as the table shows, is used in making circuit boards and case of mobile phones.
Although Li-ion batteries are free of heavy metals (lithium has a low atomic number), lithium’s high instability can create environmental problems. When exposed to water, which is present in most landfills, the metal can burn, causing underground fires that are difficult to extinguish.
Zinc is good for health in small quantities and is often used in medicines. However, zinc products contain another metal called cadmium. This is because zinc and cadmium are chemically similar and often occur together in nature. Exposure to high levels of cadmium over a long time can lead to kidney failure.
Arsenic compound Gallium Arsenide is used in LEDs. Arsenic is a well known poison. When the concentration of Arsenic in water increases beyond 10 parts per million it becomes dangerous. In fact, Arsenic poisoning is common in our part of the world.
Antimony, used mainly as a fire retardant, is known to be very poisonous, and the effects of antimony poisoning are similar to those of arsenic poisoning.
Beryllium, used for cooling (heat sink), is corrosive to tissue and can cause a chronic life-threatening allergic disease called berylliosis in some people.
Copper fortunately is non toxic and is in-fact necessary for a healthy life. Apart from copper, cell phones also contain small amounts of precious metals like iridium, silver and gold, which make it attractive for recycling companies to be in this business.
Basel Convention on the Control of Transboundry Movementsof Hazardous Wastes and their Disposal, Mobile Phone Partnership Initiative. Mobile Phone Partnership Initiative
How to discard cellphones
Today, most major handset manufacturers such as Samsung, Nokia, Apple and LG run mobile recycling programs. You can simply walk into the store of any of these companies and give your old phone, and you can be sure the phone will be recycled properly. Or ask your municipality for any recycling program they may have in place for mobile phones.
The Canadian Auditor General’s office has raised concerns about how dangerous goods are transported in Canada, in a report that may have far-reaching effects on Transport Canada, as well as the transportation and chemical industries. The conclusion in the report that “Transport Canada has not designed and implemented the management practices needed to effectively monitor regulatory compliance with the Transportation of Dangerous Goods Act, 1992” has already become a major news story, raising public concern. But how valid are these concerns?
Scott Vaughn, Commissioner of the Environment and Sustainable Development, this week issued his report on the performance of Transport Canada and the National Energy Board. The report, issued as the 2011 December Report of the Commissioner of the Environment and Sustainable Development found, among other areas of concern:
Transport Canada lacks a consistent approach to planning and implementing compliance activities. In particular, it has not established a “risk based” approach to monitoring companies involved in transporting dangerous goods.
There is a lack of follow-up on reported deficiencies. Corrective action is not consistently taken when violations are discovered. Documentation of corrective actions is often missing or incomplete.
The system for approving and overseeing Emergency Response Assistance Plans (ERAPs) is slow, and many plans are given merely “interim” approvals, but never progress to full approval (some have been designated interim as long as ten years).
Inspectors lack detailed guidance on how to enforce and monitor compliance.
The report identifies some significant areas of concern, and Transport Canada has committed to addressing these issues. However, it should be pointed out that most of the issues raised by the Commissioner are not related to actual incidents, but the day-to-day administrative procedures of the department. In general, Canada’s record in safe transportation of dangerous goods is still very good. The number of accidents related to non-compliant dangerous goods is low, and most incidents are dealt with quickly and appropriately, due to the hazard communication requirements of the regulations.
Companies involved in the transportation of dangerous goods in Canada should watch the developments from this report carefully. As the government tries to address these concerns, we may see improvements for industry, such as speedier approvals, but there may also be a downside. Will the criticism of Transport Canada’s enforcement procedures result in inspectors taking a more “hard-nosed” approach during investigations?
Christmas time is almost upon us again. Many of us like to decorate our homes for the Christmas season with traditional plants and flowers. The poinsettia is always a big favorite; it’s bright red leaves just scream Christmas. We hang mistletoe so we can kiss our beloved. We like to decorate window sills and banisters with holly and ivy. And last, but certainly not least, many of us like to put a large real Christmas tree in the middle of our living rooms.
Poinsettas
There is some controversy, mostly from those who sell flowers, whether or not poinsettia’s are poisonous. Actually, the flower itself is not poisonous but the sap that comes out of the leaves can cause skin and mouth irritation, and vomiting. If a pet or child ingests any of the plant, it can be treated by washing with soap and water.
Mistletoe
The berries of the mistletoe plant are extremely poisonous. It is recommended that you remove the berries if you plan to have the plant around your house. The berries can cause excessive salivating, vomiting, diarrhea, excessive urination, heavy breathing and a fast heart rate.
Holly
Like mistletoe, the berries on the holly plant are poisonous. They are not as poisonous as mistletoe berries and many birds do live on them but they can cause gastric intestinal distress, vomiting and diarrhea in small children and pets. If you think a pet or child has ingested the berries, contact your doctor or vet immediately.
Pine trees
If you bring a real Christmas tree into your home you must be aware of the dangers, to pets especially. It is inevitable that the needles will fall off a pine tree. If your pet ingests the pine needles there is a danger of their internal organs being pierced by the needles. It’s probably safest to buy an artificial tree. They don’t drop needles, they don’t dry out, and they are not a fire hazard.
Don’t be afraid of decorating your homes with Christmas plants and flowers. Just taking a few precautions can ensure that you and your family and your pets will have a wonderful holiday season.
As a Christmas enthusiast, I enjoy stringing Christmas lights around trees and small plants to give my home a warm glow for the holiday season. These lights mesmerize children and adults alike in a stunning display of twinkling color. But we forget the risks that Christmas tree lights pose when used inside the home. We can steer clear of such hazards by taking preventive measures against potentially threatening situations.
Real Tree Fire Hazards
Christmas tree lights have a reputation of sparking electrical fires on Christmas trees. According to our local fire administration, a short in one light of the electrical light string often ignites a fire on the family tree. However, fires are less likely to break out on well-watered Christmas trees than dry ones. Therefore, Christmas tree owners have to keep their trees well-watered to reduce the chance of an electrical light fire.
Choking Hazards
Children seldom consider the consequences of getting tangled up in Christmas tree lights. Toddlers and small children may get the electrical light cords wrapped around their necks and suffocate if not placed under adult supervision. Parents can prevent this occurrence by making sure their small children are never left alone in a room with boxed or partially strung Christmas tree lights, as children might use them as toys or attempt to string the lights themselves.
Pre-lit Tree Risks
Christmas tree lights don’t need loose cords to pose a threat. In the United States the Consumer Product Safety Commission has recalled some pre-lit trees. According to the commission, some buyers experienced electrical shocks and fires resulting from exposed wiring, wires that were too short and electrical cords that were not plugged in all the way. While not purchasing pre-lit trees is the only way to prevent such issues, individuals can take some precautions by placing the tree in a well-ventilated area where it is not likely to quickly spread fire to furniture, pillows or gifts within close proximity.
Fake Tree Dangers
Even though real trees and pre-lit trees seem to pose the most threats in the home, artificial trees are equally as vulnerable to Christmas tree light risks. According to the National Christmas Tree Association, fake trees are likely to catch fire when decorators overload electrical sockets with Christmas tree lights. Did you know that even flame retardant or flame resistant artificial trees can eventually succumb to a fire, as their resistance wears off when completely consumed in flames? By following the instructions on Christmas tree light packaging, owners can determine how many light strings they can safely connect before posing a threat to their homes.
