Have You Made Your TDG Updates Yet?
The holiday rush for 2014 is over. Our parties have been held, and our gifts are unwrapped and appreciated. But if you’re a dangerous goods shipper or carrier, you can’t relax just yet. New requirements from Transport Canada become mandatory, January 15, 2015. So, it’s time to make sure that everything in in compliance with the new system.
Back on July 2, 2014. Transport Canada issued two amendments to the Transportation of Dangerous Goods Regulations (TDG). One was called the Safety Mark Amendment, and the second was the Update of Standards Amendment. Both will have important effects on dangerous goods shipping procedures, and will need to be addressed immediately if you want your shipments to remain in compliance.
If your organization hasn’t already done so, it will need to review these amendments and make all necessary changes as soon as possible. Here are some of the most critical changes:
- Non-bulk packaging must now be selected for ground shipment using a standard published by Transport Canada, called Transport Canada Standard TP14850E, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and, 9, a Transport Canada Standard.” Note that this is available as a free download from the Transport Canada site at http://www.tc.gc.ca/publications/en/tp14850/pdf/hr/tp14850e.pdf
- Consignors of dangerous goods must keep on file a “proof of classification” for all dangerous goods they offer for transport. Details on what is required for this proof can be found in TDG section 2.2.1.
- Safety marks must be updated to current United Nations standards. For example, the all-yellow Division 5.2 label has been retired; if you are shipping organic peroxides, you must use the new red-and-yellow version for Division 5.2. Also, Marine Pollutant marks must be updated to the new diamond shape, as the older triangle marking is now obsolete.
- The placarding rules have been revamped significantly. For example, certain classes such as Division 4.3, Dangerous When Wet, must be placarded for any amount, rather than using the 500 kg placarding exemption. Also, new restrictions have been put on the use of “Danger” placards.
- Large containers carrying bulk packagings such as tote tanks must now display all class placards and UN numbers that are required on the packagings inside.
- The Limited Quantity provisions of section 1.17 have been updated so that it is no longer necessary to include the words “Limited Quantity,” “LTD. QTY.” or “Consumer Commodity” on shipping papers when offering limited quantities for transport.
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Can someone ship hazardous materials/dangerous goods without using regulatory publications?
This is often a question we ask ourselves when assisting customers. There are so many if’s, and’s, and but’s in the regulations, it’s hard to imagine someone shipping hazardous products without them. The regulations are just large instruction manuals on how to safely ship dangerous materials. We often have customers call and question why their shipment was rejected. After listening to their story, we can usually find the answer right in the regulations. When we tell a customer why their shipment may have been rejected, customers normally see why having a copy of the current regulations is so important. Every company shipping hazardous materials/dangerous goods should have all the regulatory manuals for the modes of transportation which they ship.
“That’s how we have always done it.”
This is something we hear very often, actually.
Just because that’s how you have always done it doesn’t mean it is compliant. The regulations are updated often for a reason – to ensure safety for everyone involved with shipping hazardous materials/dangerous goods. Recently, many of the regulations have been updated to include new UN numbers. The new shipping names and UN numbers will affect the way that companies label and document these products. This could easily become a scenario where “we’ve always done it this way” may lead to penalties or fines.
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The headlines are frightening – Ebola virus, one of the most deadly viruses known, has broken out in several African countries. Medical authorities are concerned that it could spread beyond that region, carried by travellers all over the world. Laboratories in North America and Europe are on alert for patients showing suspicious symptoms. This, in turn, means that samples and specimens must be transported for testing and verification. How can the medical community deal with transportation of such high-risk materials?
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Ebola virus is considered a “hemorrhagic fever,” which affects the blood system. Its virulence is astonishing, with a fatality rate of between 50 and 90 percent. Combine this with the ability to be transmitted through casual contact, and the lack of specific vaccines or treatment, and it’s understandable why Ebola is such a feared disease. Therefore, it is all the more essential that transporters make sure that they comply with all legal and safety requirements.
Ebola virus is one of the few pathogens that is always classed as a Category A infectious substance, even in its uncultured form. The shipping description will be:
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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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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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