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 were papers that were presented by Belgium, China, Korea and DGAC that were rejected:
- China proposed a limited quantity for alcohol
- Korea: 1) prohibit metal packaging for Li batteries, 2) separate wet batteries from Class 3, 3) allow the use of the UN number on limited quantity packages, 4) the overpack marking should be a minimum of 65 mm in height
- DGAC: wanted specific packaging and storage rules for Class 4.3
- all the above were rejected as these proposals should be presented to the UN not the IMO
Dave Evans (Purolator Canada) and Duane Pfund (PHMSA) brought us up to date with the changes in Canada. Amendment 8 is still at Justice. Linda Hume is off on medical leave and will retire in February 2012. Transport Canada has met with PHMSA recently and both signed a memorandum of understanding regarding compressed cylinders. Both parties have agreed to circulate proposed changes with each other.
Geoff Leach returned to go over the top 5 feedback points regarding training programmes. His first question was “what is feedback?”. Feed back is: Knowledge of the results of any behavior, considered as influencing or modifying further performance.
- if you don’t know where you’re going, how do you know which route to take? you need objectives
- talking vs asking: why ask? a) to test understanding & acceptance, b) to stop switching off, c) stop participants from being passive
- why are we here? be specific – illustrate by using an example, i.e. ValueJet
- reading vs teaching
- visual aids – Geoff did an exercise of reading a list of items vs showing a list of pictograms
Chris Egloff, Americase, did a presentation of shipping oxygen cylinders or generators by air. This only applies to the US, but also applies to shipments leaving the US, entering the US, intra US or US flagged aircraft. FedEx requires the use of the ATA300 package. One issue of note is the number of cylinders per case. The regulations do not say you can or can’t have multiple cylinders in a package. The shipper would need to refer to the manufacturer for clarification. Boeing 787s do not have oxygen generators on board, rather, the aircraft has a 10k cylinder in the cabin. A 10k cylinder is a 10,000 psi cylinder.
Gene Sanders lead a session on classification questions – how not to write them. He talked about wisdom vs experiences and introduced Emily.
- M – measured
- L – learning
- E – exercise
Gene does not say that the course will end with a test, quiz or exam, but says that Emily (MLE) will show up at the end of the session.
At the end of the day’s sessions, Geoff Leach was the honorary Duckmaster at the Peabody, see http://www.youtube.com/watch?v=7YNrCvBqDPo to see Geoff in action.
On Friday morning, Duane Pfund presented Bob Richard with a PHMSA inspection shield for his years of service at PHMSA. We were also regaled with some stories about Bob.
Three inspectors from PHMSA told us that inspections are random subject to a priority list. The regulations pertain to shippers, carriers, freight forwarders, 3rd party labs, SP holders, fillers and shippers of aerosols, cylinder re-qualifiers, nurse tanks, package manufacturers and high hazard entities (TIH). The biggest question is “why me?”. The inspectors show up if there has been a complaint, if the party is high risk (TIH), ongoing investigations, observations or there has been an incident history. Inspectors will observe the various processes, use of test equipment, training, records, closure instructions, shipping papers and MSDSs.
Some consistent problems encountered: no training records, failure to train, package closures, improper marks and labels, incorrect shipping papers, failure to register with PHMSA, and lack of security plans. Stats for 2010: 1,650 inspections, 42% OK – no further action required; 57% non-compliant and 1% waiting for test results.
Donna Lepik (CHEMTRC/TRANSCAER), David Binder (Tanner Industries) and Bill Burke (Dupont) did “Soup to Nutz”. This presentation dealt with the development of the TRANSCAER anhydrous ammonia training programme. To view this programme, go to http://www.transcaer.com/aa-tour. If you work with anhydrous ammonia, there is a wealth of information here.
For dangerous goods trainers, this is the symposium that you need to attend.