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Upcoming Changes to the IMDG Code for 2015

by Barbara Foster on March 10, 2014 at 8:00 am · in Barbara's Blog, IMDG Code (Sea), Regulation Updates, Regulations

IMDG 2015 changes

By the end of this year, the International Maritime Organization (IMO) will publish the next revision to the International Maritime Dangerous Goods Code (IMDG). This revision, to be known as Amendment 37-14, will be optional to comply with starting on January 1, 2015, and will become mandatory on January 1, 2016.

What changes will we expect to see in this new revision? Perhaps not as many as in previous amendments, but there will be a number of significant issues addressed. These include:

  • A clarification that lamps and light bulbs are not to be considered dangerous goods
  • Significant revisions to the requirements for Class 7 radioactive substances
  • Addition of shipping descriptions and packaging instructions for adsorbed gases
  • Clarifications on classifying viscous flammable liquids
  • Clarification on the design and dimensions of various marks, such as the marine pollutant and limited quantity markings, as well as the design and dimensions of labels and placards
  • The lettering of the OVERPACK marking must be at least 12 mm high (Mandatory January 1, 2016)

The Dangerous Goods List, Chapter 3.2, will be altered by dividing column 16 (Stowage and segregation) in two, creating column 16a, Stowage, and 16b, Segregation. Codes for appropriate stowage and segregation will be assigned for each shipping description (these codes will be explained in Chapter 7.2).
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A New Year, New Requirements for Identification Numbers

New shipping name labels sizes are required as of January 1, 2014

As the start of a new year approaches, it’s time for parties, resolutions – and to check our dangerous goods/hazmat procedures, and see what’s changing. If you are a shipper of non-bulk packagings, one thing to watch out for is the new size limit for identification numbers that will be introduced in many regulations for 2014.

Identification numbers (which cover UN numbers, NA numbers and ID numbers) are the main way for packages to be identified as to their contents, in a format that does not depend on language. In the past, incidents have occurred because these numbers were marked on dangerous goods packages, but were not large enough to be seen easily. Therefore, the United Nations has, in the UN Recommendations for Dangerous Goods, established minimum size requirements.

The size minimums are:

  • For packages with a capacity of 5 Litres or net mass of 5 kilograms or less, the size should be “an appropriate size,” based on the size of the container.
  • For packages containing more than 5 Litres or kilograms, up to  a maximum capacity of 30 Litres or net mass of 30 kilograms, the letters and numbers of the marking must be at least 6 millimeters (1/4 inch) tall.
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Transport Canada Unveils Proposed Amendment to Safety Standards

by Barbara Foster on December 16, 2013 at 8:00 am · in Barbara's Blog, Regulation Updates, Regulations, Transportation of Dangerous Goods

On November 16, Transport Canada published proposed changes to certain safety standards in the Transportation of Dangerous Goods (TDG) Regulations. These changes can be found in Canada Gazette I, and may be accessed online at http://gazette.gc.ca/rp-pr/p1/2013/2013-11-16/html/reg5-eng.html.

It may appear at first that these are merely technical changes and updates. Transport Canada says that the main reason for the amendment is that some of the standards need their references updated to the most current version, and some of them need to be introduced for the first time. However, if the amendment is finalized in Gazette II, some of the implications are significant for Canadian shippers and carriers.

The principle points behind this amendment are:

  1. Several new standards must be introduced in order to enhance compliance with the UN Recommendations in their current form. This means including standards for packagings such as cylinders (which currently have a TC (Transport Canada) specification), and UN-specification portable tanks. This will ensure that Canadians are using the most harmonized, as  well as the most modern, packaging standards.
  2. A number of the existing standards referenced in TDG are not referenced in the most current version. For example, the current regulation has a reference for CSA Standard B339-08, “Cylinders, spheres, and tubes for the transportation of dangerous goods”, last amended in February 2005. The amendment will update this reference to the version published in March 2008.
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Transfer of Dangerous Goods

by ICC Compliance Center on February 28, 2013 at 4:29 pm · in Jim's Blog, Regulations, Safety

The Alberta government has issued Industrial Railway Circular No. 1 (Guideline for the Transfer of Dangerous Goods to or from a Railway Vehicle).

Although only a 7 page document, there are 11 sections:

  1. General
  2. Exceptions
  3. Notification/site selection
  4. Primary selection criteria
  5. Additional selection criteria
  6. Approvals
  7. Inspections
  8. Training
  9. Documentation
  10. Notification
  11. Regulatory requirements

The guideline falls under the Railway (Alberta) Act and applies to companies that intend to transfer dangerous goods to or from a railway vehicle. This circular does not apply to Class 1 Explosives. These must be handled under the Federal Handling of Carloads of Explosives on Railway Trackage Regulations.

Railways that intend to construct or connect railway track to a service provider or construct railway works must have approval from the provincial government. Site selection is done in accordance with sections 4 and 5, and if the criteria cannot be met, the application may still be considered if an equivalent level of safety can be demonstrated.

The guideline suggests a dangerous goods transfer track/rack should meet minimum distances from residences, commercial establishments, schools, hospitals, recreation centres, etc..

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Dangerous Goods Class

Distance

2.1

100 m

2.2

50 m

2.3

250 m

2.3

450 m

3   excluding inhalation hazard materials

50 m

4.1  molten sulphur

100 m

5.1   excluding inhalation hazard materials

50 m

6.1   excluding inhalation hazard materials

Part 4 Dangerous Goods Safety Marks Amendment

by ICC Compliance Center on December 10, 2012 at 8:00 am · in Jim's Blog, Regulations

Transport Canada published in Canada Gazette, Part I, the amendment titled “Part 4 Dangerous Goods Safety Marks”. Notable changes include:

  • introduction of overpacks
  • modifications to the use of the DANGER placard
  • introduction of new safety marks (3)
  • new proposal for placarding large means of containment

Let’s start with the overpacks. Currently under TDG, overpacks are not recognized although they are being used. And this is causing enforcement issues. TC considers an overpack to be a large means of containment. The definition for overpacks will be added to section 1.4 of TDG. Safety marks for overpacks is covered in section 4.10.1. As part of this section, when the overpack has a capacity ≥ 1.8 m3, then safety marks must appear on two opposite sides of the overpack.

The new safety marks to be introduced are:

All the safety marks are in the UN Model Regulations, ICAO Technical Instructions, IMDG Code and 49 CFR.

The requirements for placards will undergo a major change. The table in TDG section 4.15 is replaced. Placards will be required on both ends and sides of a large means of containment. The subsidiary placard requirements do not change. UN numbers on a placard or orange panel will be required when an ERAP is required, or the dangerous goods are liquids or gases in bulk. IBCs (intermediate bulk containers) will be permitted to only have 2 placards with UN number on opposite sides, or a label and UN number on each side. This will remove the need for equivalency certificates. However, placards with UN numbers will be needed on the outside of the truck.
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REGULATORY TRAINING | PLANT AUDITS | SDS SERVICES | LABELING SOLUTIONS | TRUCKING PLACARDS & SECURITY SEALS | WORKPLACE SIGNS & TAGS | UN CERTIFIED PACKAGING

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