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ICC Compliance Center Blog



ICC The Compliance Center Blog » 2010 » December

Ready or not…

by Emily Walter on December 17, 2010 at 5:04 pm · in Emily's Blog, Regulations

As we approach the start of another new year, we also approach the start of new regulatory requirements. Both the IATA Dangerous Goods Regulations and the IMDG Code have new editions for 2011. The IATA regulations go into effect on January 1, while the IMDG Code has a 1 year transition period before becoming mandatory. If you ship using either of these regulations, you must ask yourself “Am I ready?”

IATA has made significant changes for 2011, and as a regulatory specialist, I am expecting A LOT of panicked phone calls from shippers (and carriers) who were unaware of the changes. In addition to the typical minor changes that happen on a yearly basis, IATA has completely revamped the limited quantity requirements as well as the packing instructions in section 5. The limited quantity requirements even have a new section number assigned to them. I can’t even begin to imagine how much confusion there is going to be with the new packing instructions!

The IMDG Code changes are not as drastic as IATA’s, but that doesn’t mean there won’t be questions. The limited quantity changes have made their way into the IMDG Code, so people who deal with those shipments are going to have to brush up on both regulations.

If you haven’t already checked out the new regulations, make sure that you do so as soon as possible. And don’t forget, if you do run into any problems or questions with any regulatory requirements, you can give us a call and we will help you out.

Q&A Regarding the New Limited Quantities Markings

by Suzanne Levac on December 15, 2010 at 4:07 pm · in Regulations, Suzanne's Blog

Here are questions and answers regarding the new limited quantities markings that were asked during our webinar on December 7th. If you missed the live session, or would like to review it, it can be viewed here.

Q: Will small package carriers, such as UPS or FedEx, accept the new label?
A: Yes.

Q: On the Shipper’s Declaration, do you still need to put the words “LTD. QTY.” or “Limited Quantity”?
A:  No.

Q: Why is the “Y” marking referenced in the 2010 IMDG Code?
A: This is due to multimodal transportation.

Q: Is that mark useful in ground shipments?
A: It is not required for ground shipments.

Q: If we are shipping according to DOT by ground and IMDG Code by sea, do we use the marking with the “Y” in the center?
A: No, the marking with the “Y” is required only for air transportation.

Q: Do we still put the UN number in the diamond?
A: No, you do not need to put the UN Number in the diamond for shipping by sea (IMDG Code).

Q: Anytime we load any limited quantites on a cargo transport unit meant for marine shipments, must we also mark that cargo unit with the “Y” marking?
A: When you load a CTU meant for marine shipments and it contains only limited quantities, you need to mark it with the new limited quantity marking without the “Y”.

Q: Is the blank diamond for containers?
A: The new diamond marking without the “Y” is for small packages to be shipped by air.

Q: Which version of the new marking should be used for each mode of transport?
A: The new diamond marking with the “Y” is for air shipments. For marine shipments, use the new marking without the “Y”. No new marking is required for ground shipments.

Q: If we use the blank limited quantity marking on the outside of a sea container do we still need to use the spelled out “LIMITED QUANTITY” marking?
A: You will not need to have the “LIMITED QUANTITY” marking, The new diamond marking replaces it.

Q: Will IMDG accept the “Y” version of the marking?
A: Yes, for multimodal shipments.

Q: What about the documentation for IMDG? Is that changing?
A: No.

Q: Will IATA accept shipments that have the blank diamond?
A: No, you must use the version with the “Y” for air shipments.

Q: Are the “LTD. QTY.” or Consumer Commodity markings still acceptable for ground shipments?
A: Yes, for ground shipments.

Q: If we use “LTD. QTY.” labels, do I have to replace it with the new marking? We only ship by ground.
A: If you only ship by ground, you do not need to use the new marking.

Q: IMDG Code 2010 section 3.4.5.3 says the air marking shall be deemed to meet the provisions of the IMDG limited quantity mark. I don’t think it states that the package must be multimodal.
A: Section 3.4.5.2 states that it is for packages containing dangerous goods consigned for air transport.

Q: How will this impact ground transport in Canada?
A: Currently, everything is staying as it was. However, Transport Canada is working on an amendment that will allow the new marking to be used.

Q: Can you review what marking/labels will be needed for Consumer Commodities/ORM-D ID8000 shipments?
A: For air shipments, you must use the “Y” version of the new marking. For sea shipments using the IMDG Code, you must respect the Limited Quantity requirements.

Q: When will IATA require the new “Y” marking to be used?
A: January 1, 2011.

Q: What are the size requirements for the new markings?
A: The standard size is 4″ x 4″ (100 mm x 100 mm), and cannot be reduced to less than 2″ x 2″ (50 mm x 50 mm).

Q: Are there color requirements regarding the “Y” marking?
A: No, there are no color requirements.

MSDS FAQ’s

by Emily Walter on December 10, 2010 at 4:44 pm · in Emily's Blog, Regulations

I was recently asked to give an overview of how MSDS’s are used in the workplace to some of my coworkers. Coming from a laboratory background, I often forget that many people do not know what an MSDS (or Material Safety Data Sheet) is and why they are important in the workplace. For those of you who may not be familiar with what an MSDS is or how and why it is a very important piece of safety equipment in the workplace, here are few highlights.

What is an MSDS?

An MSDS is a document that provides safety information for a product or material. MSDS’s are generally used in a workplace or emergency situation and contains information such as:

  • Hazards of the product
  • Safe use of the product
  • Symptoms of exposure to the product
  • First aid procedures
  • Emergency procedures

Who uses an MSDS?

  • Employees who need to know proper safety and handling information for a product or material they use occupationally in the workplace
  • Employers or employees who need to provide safety training and equipment
  • Employers or employees who need to determine proper storage for materials
  • Emergency response personnel; such as firefighters, first responders, EMT’s and ER personnel
  • MSDS’s are not intended to be used by consumers for household use of products!

How are MSDS’s formatted?

Currently, there is not one MSDS format that is recognized worldwide.

  • The US follows the OSHA requirements (no specific format is required, but the ANSI standard format may be used to comply)
  • Canada follows the WHMIS requirements (a 9 or 16 format is specified, and the ANSI standard format may be used for a 16 section MSDS under WHMIS)
  • EU, Asia, other regions and countries have their own requirements

What about the GHS (Globally Harmonized System)?

The GHS will standardize the format and information required on MSDS’s.

  • GHS specifies a 16 section format that is similar to the ANSI standard format
  • Will allow for harmonized MSDS’s among countries that adopt the GHS into regulation
  • Will make MSDS’s much more internationally recognized
  • There will likely still be country specific information required