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20 Years Ago

by Karrie Monette-Ishmael on September 12, 2012 at 1:39 pm · in Karrie's Blog, Regulations

Time flies. Can you believe that it has been 20 years since RSPA (now PHMSA) published docket HM-126F regarding training?

Final rule HM-126F is now incorporated into the 49 CFR regulations Part 172 Subpart H. Subpart H stipulates that:

  1. A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart
  2. Employees may not perform functions without appropriate training
  3. Training may be provided by the hazmat employer or other public or private sources
  4. A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the topics covered

Hazmat employee training must include the following:

  1. General awareness/familiarization training
  2. Function-specific training
  3. Safety training
  4. Security awareness training
  5. In-depth security training

Often times both function-specific and in-depth security training is better done onsite by the employer. It is the employer’s responsibility to certify that the hazmat employee can perform their job, and do so safely.

For more than 25 years, ICC has provided companies with training that complies with these regulations. We offer training that complies with the general awareness/familiarization, security awareness, safety and some function specific topics.

Ask us about our scheduled public training for ground, air or ocean at our facilities across North American. We also offer GHS training, and new OSHA compliant safety training.

Call 888.442.9628 for more information. Have a problem? We have a solution.

The Rulemaking Process

by Karrie Monette-Ishmael on August 6, 2012 at 8:00 am · in Karrie's Blog, Regulations

Have you ever been curious about how a rulemaking is published?  Have you ever wondered how you can participate in the rulemaking process?

We came across a link we want to share from The Office of the Federal Register. When you follow this link https://www.federalregister.gov/learn/tutorials, then scroll down to Tutorials, you will see A Guide to the Rulemaking Process containing answers to the questions below.

Gavel and books

Before the proposed rule

What gives agencies the authority to issue regulations?

How does an agency decide to begin rulemaking?

When can the public learn that an agency plans to start a rulemaking?

How does an agency involve the public in developing a proposed rule?

What is the role of the President in developing a proposed rule?

The proposed rule

What is the purpose of the proposed rule?

How is the proposed rule structured?

What is the time period for the public to submit comments?

Why do agencies re-open comments or issue multiple proposed rules?

Do agencies have additional options for gathering public comments?

Why should you consider submitting electronic comments?

Before the final rule

How do public comments affect the final rule?

What is the role of the President in developing a final rule?

The final rule

How is the final rule structured?

When do final rules go into effect?

Can an agency issue a final rule without publishing a proposed rule?

What are interim final rules and direct final rules?

After the final rule

How are final rules integrated into the CFR?

How is Congress involved in reviewing final rules?

Does the regulatory process continue after rules are published?

What are interpretive rules and policy statements?

When do the courts get involved in rulemaking?

ICC prides itself on keeping customers up-to-date on Hazardous Materials, OSHA and EPA regulations with advance, proposed and final notices published in the Federal Register.

Emergency Response Requirements for Shipping Papers

by Karrie Monette-Ishmael on August 1, 2012 at 8:00 am · in Karrie's Blog

What information do you need on a shipping paper or an emergency response situation? Depending on the country you are shipping from, the answer can vary.

Canada

The Transportation of Dangerous Goods Regulations, Part 3, (1) 3.5(f) and (2) outlines the requirements for the shipping document.  These requirements include:

Having the words “24 hour number” followed by an active 10-digit telephone number xxx.xxx.xxxx,

  1. Being able to reach the consignor immediately, and
  2. Providing technical assistance without breaking the connection. An outside agency that is registered with the emergency response provider may be used.

USA

The requirements outlined in the 49 CFR  [172.201(d) and 172.604(b)(1)&/or(2)] states that if the shipper is using an Emergency Response Information provider or an agency on their behalf, a 24-hour telephone number and name of the person or contract number must be added to the Emergency Response Shipping paper.

Recently, an FAA inspector visited a customer of ours and the Emergency Response information on the shipping document was something they checked.  As part of their audit, they called the number listed on the form to verify that the contract number was indeed valid.

Remember, during a transport emergency, first responders rely on this information to react to the situation quickly and to react with the correct protective and fire-fighting measures.

Do you need a 24-hour emergency response service?

24-hour emergency number

ICC has a 24-hour phone number available in the USA, Canada and internationally.

Call us today: USA – 888.442.9628 · Canada 888.977.4834
to get more information or to request a quote.

What Is a CAS Number?

by Karrie Monette-Ishmael on July 19, 2012 at 8:00 am · in Karrie's Blog

Here at ICC Compliance Center and depending on your application, we may ask you for a CAS number. When we create labels on demand for your exports, among other services, we will ask you to provide us with the chemical name and CAS number and then we are able to provide as few as 100 GHS compliant labels  and/or a compliant SDS.

Compliant GHS Chemical Label:

Compliant GHS chemical label

A CAS number or CAS Registry number is a unique identifier for every chemical substance dating back to 1957. The Chemical Abstracts Service (CAS) is the responsible entity that is responsible for assigning a unique number to every chemical described in scientific literature.

A CAS number itself has no meaning. Its primary use is to avoid confusion between chemicals with similar names, or individual chemicals that may have multiple names. It is also used to identify the chemical when a generic or trade name is used.

A CAS Registry Number is separated by hyphens into three parts, the first consisting of up to seven digits, the second consisting of two digits and the third consisting of a single digit.

In short, the CAS number can be particularly useful in database searches because it allows you to search a database and easily pull every record for that particular substance or chemical. For example, “Methanol” is known by multiple names such as methyl alcohol, methyl hydrate, hydroxymethane and wood alcohol but this chemical can be identified as one specific substance using the CAS number, which is 67-56-1.

Give us a call today at 888.442.9628 for all your GHS labeling and SDS requirements and remember to provide us your CAS numbers.

Canada Adds 14 Substances to Domestic Substance List

by Karrie Monette-Ishmael on July 16, 2012 at 8:00 am · in Karrie's Blog, Regulations

The Department of the Environment, under the Canadian Environmental Protection Act, 1999 has published an amendment in the Canada Gazette Order 2012-87-03-01, amending the Domestic Substance List. The order adds 14 substances to the Domestic Substances List and modifies the information on one substance.

http://www.gazette.gc.ca/rp-pr/p2/2012/2012-07-04/html/sor-dors125-eng.html

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