by ICC Compliance Center on November 7, 2012 at 3:31 pm · in Uncategorized
Isn’t it good to know that the shipping industry is playing a role in recycling natural resources? While the thought of reusing shipping containers for emergency housing after a natural disaster caught the imaginings of 8th graders I worked with in a recent “Future City” contest proposal, DeMaria Design has brought the concept into reality. DeMaria’s hybrid design for a Redondo Beach container house uses conventional stick-frame construction combined with eight repurposed steel shipping containers to form a two-story home.
“For me as an architect, the challenge has always been how to give my clients the highest level of design while still keeping the projects on budget,” says Peter DeMaria, one of the country’s first architects to incorporate steel cargo containers into residential designs. His Redondo Beach container house, located in Southern California, won the American Institute of Architecture’s Excellence in Design Innovation Award in 2007.
DeMaria tells me that the shipping containers were purchased locally from a Los Angeles area supplier with consideration given to original fabrication, age, condition, and even the previous cargo shipped within the container.
The containers were retrofitted off-site, before being assembled on-site to help further reduce labor costs during installation.
With the large number of shipping operations located around the New York/New Jersey area, this technique may be a worthy consideration in the re-building of the eastern sea board communities affected by Hurricane Sandy.
Redondo Beach Container House
California architect Peter DeMaria transforms eight shipping containers into an award-winning family residence in Redondo Beach, California.
A question we are often asked at ICC Compliance Center is “how small does a dangerous goods shipment have to be to not be regulated?” Not just limited quantity, not just excepted quantity – totally not regulated. Common sense tells us that, at a certain level, tiny amounts of dangerous goods do not pose a hazard during transport. Unfortunately, until recently, this question was not really addressed directly, other than by using other small quantity provisions, such as limited quantities.
However, the UN Subcommittee on the Transportation of Dangerous Goods has been working on this issue, and the question has started to be answered by various regulations based on the UN Recommendations. For example, starting in 2013, shippers by air who use the ICAO Technical Instructions for the Safe Transport of Dangerous Goods (TIs), and the IATA Dangerous Goods Regulations (DGR), will be able to ship very small amounts of dangerous goods as non-regulated under the so-called “de minimis” provisions.
The 54th Edition (2013) of the DGR has a new section, 2.6.10, which establishes the procedures for shipping as a de minimis quantity. The procedure is as follows:
Look up the goods being shipped on the List of Dangerous Goods (Table 4.2), and check the Excepted Quantity code given in column F. If the code is E1, E2, E4 or E5, the goods can be shipped as de minimis, if they meet the following requirements. (If the code is E0 or E3, unfortunately, de minimis is not an option.)
Package the goods as you would excepted quantities, using the instructions in DGR section 2.6.5. Note that, despite this section, intermediate packaging (such as a leakproof bag) is not required if the inner packagings are securely packed in an outer packaging with cushioning material, in such a way that they could not:
be punctured, or
leak their contents
under normal conditions of transport. Also, if they are liquids, there must be enough absorbent material to absorb the entire contents of the inner packagings.
The quantity limits for a de minimis package are:
For inner packagings, not more than 1 mL for liquids and gases, or 1 grams for solids, and
For outer packaging, not more than 100 mL for liquids and gases, and 100 grams for solids.
Finally, review the package testing requirements given in section 2.6.6. Although the package does not have to be UN-specification tested, this section says that the package must be capable of withstanding, “as demonstrated by testing which is appropriated documented,” a drop test and a 24-hour stacking test. These are simple tests that can be done in-house; however, as the section says, they should be documented. Notes of the test, and digital photographs, if possible, should be kept on file regarding the packaging.
Once you have met these requirements, the DGR says that the de minimis package will be “not subject to these Regulations”. So, other requirements, such as dangerous goods shipping papers, or package markings, will not apply.
Do remember that this section is new to the 54th edition of the IATA DGR. Until January 1, 2013, these provisions may not be used.
If you have questions about using de minimis quantities, please contact ICC The Compliance Center Inc. at 1-888-977-4834 (Canada) or 1-888-442-9628 (USA).
by ICC Compliance Center on October 19, 2012 at 8:00 am · in Uncategorized
With the changing seasons, comes a change in weather that may affect your area with storms and natural disasters.
According to The American Red Cross, the internet – including online news sites and social media platforms – is the third most popular way for Americans to gather emergency information and let their loved ones know they are safe.
Through the use of everyday technology; individuals, families, responders and organizations can successfully prepare for, adapt to, and recover from disruptions brought on by emergencies and/or disasters.
If your cell phone is an indispensable part of your daily routine, then you may find emergency information text messages from FEMA (Federal Emergency Management Agency) to be a valuable asset. Use your cell phone’s text messaging capability to receive text message updates from FEMA (standard message and data rates apply).
Here are basic commands to get started:
To signup to receive monthly preparedness tips: text PREPARE to 43362 (4FEMA)
To unsubscribe (at any time): text STOP to 43362 (4FEMA)
by ICC Compliance Center on August 15, 2012 at 2:19 pm · in Uncategorized
August 15, 2012
This Notice of Proposed Rulemaking (NPRM) by the Pipeline and Hazardous Materials Safety Administration (PHMSA) is part of a continuing effort to maintain alignment with international regulations and standards through a biennial process to harmonize the Hazardous Materials Regulations (HMR; 49 CFR parts 171 to 180) with international regulations and standards.
The following are some of the more noteworthy proposals in this NPRM:
• Incorporate Revised Standards: PHMSA proposes to incorporate byreference the newest versions of variousinternational hazardous materials standards including the 2013–2014International Civil Aviation
Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions), Amendment 36–12 to the International Maritime Dangerous Goods Code (IMDG Code), and the 17th Revised Edition of the United Nations Recommendations on the Transport of Dangerous Goods (UN Model Regulations).
Additionally, PHMSA is proposing to update the incorporation by reference of the Canadian Transportation of Dangerous Goods Regulations to include Amendment 8 (SOR/2011–239) issued November 9, 2011, Amendment 9 (SOR/2011–60) issued March 16, 2011, and Amendment 10 (SOR/2011–210) issued October 12, 2011. Finally, in this NPRM PHMSA is proposing the adoption of updated International Standards Organization (ISO) standards.
This proposed rule is necessary to incorporate revisions to the international standards and, if adopted in the HMR, most of which become effective January 1, 2013.
• Expand Packaging Authorizations: Consistent with the amendments adoptedby the UN Model Regulations, PHMSAproposes to adopt changes throughoutthe Part 173 packaging requirements toauthorize more flexibility whenchoosing packages for hazardousmaterials.
• Revise Vessel Stowage Codes: PHMSA proposes to revise, consolidate,and delete various vessel stowage categories and codes referenced in column 10A and 10B of the Hazardous Materials Table (HMT)found in § 172.101. The purpose is to eliminate redundant codes, align with modifications to the IMDG Code and to simplify the vessel stowage requirements by limiting the number of stowage options.
• Adopt Chemical Under Pressure Provisions: This modification would revisethe HMT to include entries for chemicalunder pressure as well as incorporateother safety requirements including butnot limited to packaging requirements,segregation requirements, quantitylimitations, and filling limits into the HMR. These types of products are often incorrectly classified and transported as liquefied gases or shipped under special permits.
• Specify Minimum Size Requirements for Identification Number Markings on Non-Bulk Packages: This change proposes to add specific size requirements for identification number (i.e., ‘‘UN,’’ ‘‘NA,’’ ‘‘ID’’) markings as prescribed in § 172.301 for non-bulk packages. As aligned with the new UN model regulations, this minimum size marking will benefit first responders to identify the commodity associated with a particular package.
• Revise HMT Entries: PHMSA proposes amendments to the § 172.101 Hazardous Materials Table (HMT) to add, revise, or remove certain proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, bulk packaging requirements, passenger and cargo aircraft maximum quantity limits to the HMT to mirror recent changes in the Dangerous Goods list of The 17th Revised Edition of the UN Model Regulations, the IMDG Code, and the ICAO Technical Instructions.
The benefits resulting from the adoption of the amendments include enhanced transportation safety resulting from the consistency of domestic and international hazard communication and continued access to foreign markets by U.S. manufacturers of hazardous materials. Most of the amendments in this NPRM should result in cost savings and ease the regulatory compliance burden for shippers engaged in domestic and international commerce, including trans-border shipments within North America.
The full notice can be read at:
Hazardous Materials: Harmonization with International Standards [TEXT][PDF]
by ICC Compliance Center on August 10, 2012 at 8:00 am · in Uncategorized
On July 6, 2012 President Obama signed into law the ‘‘Moving Ahead for Progress in the 21st Century Act’’. The current highway bill was on its ninth temporary extension and set to expire on June 30. The law reauthorizes the federal-aid highway and transit programs through September 30, 2014.
In addition to ensuring urgently needed road, bridge, transit, and rail improvements will get underway; the Act has provisions applicable to a broad range of programs and issues.
Some of the issues and concerns addressed:
The law initiates improvements to port infrastructure by permitting the full spending of the more than $6 billion surplus in the Harbor Maintenance Fund. The Army Corps of Engineers estimates that needed port channel repairs run in the billions, and that our busiest ports can only use 50 percent of their capacity 95 percent of the time.
The law calls for a National Freight Strategy that can develop an integrated improvement strategy to reduce congestion and fuel costs by ensuring more port containers travel to markets on freight rail.
For highway safety (among others) includes a requirement that commercial trucks use electronic logging devices to record drivers’ compliance with federal hours of service limits, a new clearinghouse to track drug and alcohol test results, and a study of crashworthiness standards for large trucks.
For hazmat, the bill reauthorizes the DOT hazardous materials safety program, and bans a DOT-proposed wetlines regulation until the Government Accountability Office can analyze its costs and benefits. In addition:
Authorizes PHMSA to conduct pilot projects on using paperless hazard communications systems and report later on whether the agency recommends incorporating such paperless hazcom systems into the Hazardous Materials Regulations;
Requires PHMSA to assess methods to collect, analyze and report data on hazmat transportation accidents and incidents.
Directs PHMSA to establish uniform standards for training of inspectors and to train inspectors in all modes on how to collect, analyze, and publish findings from inspections and investigations of accidents or incidents involving the transportation of hazardous material, how to identify noncompliance with the HMRs, and how to take appropriate enforcement action.
The law includes language that amends the authority of DOT to open and inspect hazmat packages en route when the inspector reasonably believes the package presents an imminent hazard.
Increases the maximum civil penalties for violations of the HMRs from $50,000 to $75,000, and from $100,000 to $175,000 where the violation results in death, serious illness, or severe injury to any person or substantial destruction of property, and adds a minimum civil penalty for training violations of $450.
Requires a rulemaking within two years to set out procedures and criteria for evaluating applications for special permits and approvals. Requires a review and another rulemaking within three years to establish a means to incorporate special permits that have been in continuous effect for a ten-year period into the HMRs.
Requires States to submit to DOT a list of the State’s currently effective hazardous material highway route designations and to update that list every two years.