I admit it. I am a hazmat nerd. I’m not sure exactly when I realized it. Maybe it was the first time I recited a section of 49CFR from memory during a class. Maybe it was when I decided to keep a copy of the ERG in my car so I could identify the UN numbers on placarded trucks. Regardless of when it happened, I now embrace my hazmat nerdiness… even my Facebook profile lists my occupation as “Hazmat Nerd”. Obviously, this is a great benefit when I’m on the job. I have a knack for remembering obscure requirements and knowing where to find them in the appropriate regulation. I enjoy hunting down the answer to tough questions or unusual situations. I like having customers who think of me as their go-to source for their questions.
One aspect of being a hazmat nerd is that I am always noticing things that relate to my job, even when I’m not at work (hence the ERG in my glove compartment). There was the time that I was doing some geocaching (my obsession…I mean hobby) in Buffalo. I had parked the car and jumped out to go find a cache. On my way, I had to dodge some large puddles due to a recent downpour. As I approached one of the puddles, I noticed something odd. There was a Flammable Liquid placard floating in it! Most people would have just walked past it. Not the hazmat nerd! I took a closer look…mainly to see if it was one of our placards. Then I took a picture, because who wouldn’t want to see a picture of a placard in a puddle? I continued on my way, trying to figure out what circumstances would result in a placard floating in a puddle in the middle of a sidewalk. I still wonder about that…
Another time, I pulled up to a gas station and saw 2 IBC’s of paint sitting alongside the building. Once again, they would have gone unnoticed by most people. I however, took a picture!
On one of my many road trips, I made a stop for some fuel for both myself and my car at a truck stop. While walking around to stretch my legs, I came across something I had not seen before…a stop for leaking hazmat vehicles. It made sense that there would be such a thing and I’m wondering why I don’t see them more often in my travels. It’s good to know that drivers do have designated areas where they can go if there is leaking hazmat. Of course I had to take a picture… what kind of hazmat nerd would I be if I didn’t?
I always notice placards on trucks when I’m driving. I even notice empty placard holders on trucks, especially when there is a more than just one or two. Imagine my delight when I was driving behind a truck with eleven placard holders on the back of it! I couldn’t wait until we got to a red light so I could take a picture (not surprising by now, I’m sure). By the way, eleven is my current record for number of placard holders on a single side of a vehicle.
I could go on with my work related, off-the-job hazmat spotting, but I’ll stop here. I will continue to notice these things and have my camera at the ready to document them. And I am proud to say that I am a hazmat nerd!
I always cringe when someone asks me what I do for work. Not because I dislike my job (in fact, I’m one of the few people I know who truly enjoys their work) but because it’s so complicated to explain what I do! Sure, I could simply say I’m a Regulatory Specialist and let them stare at me blankly and try to figure out what that means, but they usually expect more of an explanation.
After going through the explanation for a new acquaintance yesterday, I got to thinking that many of our customers may not know exactly what ICC’s Regulatory Specialists do either. Some of my “regular” customers only deal with one aspect of my expertise, and are often surprised when they learn how many hats I really wear on a regular basis. After 8 years on the job, I have collected many responsibilities to keep me on my toes.
Training – One of the main duties of the Regulatory Specialist (RS) at ICC is to deliver training classes to our customers. For me, this includes the US 49CFR Hazmat regulations, the IATA Dangerous Goods Regulations and the IMDG Code. These classes can take place at our training centers, the customer’s facility, a hotel, or even via an online webinar. Not only do we conduct the training, but we also develop the presentations and quizzes that are used. We have to ensure that all of the information is accurate, up to date and gives the attendees enough information so that they can follow along and learn how to use the applicable regulations.
MSDS – Lately, my main focus has been related to our MSDS services. We provide expertise on MSDS reviews, reformatting and authoring for many areas of the world. Currently, I am able to complete work for the US and Canada but will hopefully be able to add the European Union to my knowledge base soon. With the impending OSHA Hazcom standard update to the Globally Harmonized System (GHS), I have been preparing myself for the changes that are going to take place. Writing an MSDS is no simple task, there is research involved, as well as interpretation of the information once it is found. There isn’t a simple “formula” that can be applied to spit out a finished MSDS. Sometimes it’s difficult to explain why a 6 page document can take several weeks to complete.
Help Desk – We pride ourselves on our customer service at ICC. One of the things that sets us apart from the competition is our regulatory help desk. If our customers have questions related to the regulations and how they apply to their products, they can call and speak to a regulatory specialist to set them straight. I have reviewed shipping documents, assisted in packaging selection, clarified requirements, spoken to carriers and provided help in countless other ways. Many customers that I have built relationships through the years love having the “phone a friend” option to fall back on when they get stuck, confused or completely lost with the regulations.
Internal Education – Just as our customers rely on our expertise, our coworkers come to us when they have questions. Whether it’s a customer relations associate who wants to know about a new label that we offer, our packaging specialist needing advice on a new design, or a business development manager who needs a unique solution for a customer, we get ideas and problems bounced off of us on a regular basis.
Product Development and Review – As regulations change, so do the products that we offer. The regulatory specialists are involved in ensuring that all new products meet the applicable regulations. In addition, when an existing product has to be reprinted or remanufactured, we perform a review to make sure that there are no regulatory changes necessary. We also review our existing products as the regulations change.
All of these tasks keep me busy and make every day at the office different. I have learned a lot since my first days at ICC, and there is still more to add. Even this list is not complete; there are always those miscellaneous requests and tasks that come across my desk. All in a day’s work for this regulatory specialist!
by Barbara Foster on October 5, 2011 at 8:00 am · in Barbara's Blog
Online shopping – whether from large internet companies such as Amazon, to individual vendors on sites such as eBay – has grown, well, explosively, in the past few years. But with this growth has come a headache for shippers, receivers and regulators. How do you handle online purchases of product that may actually be classified as dangerous goods (or, in the US, as hazardous materials)?
Often, people are not aware that common consumer products may be considered hazardous for transportation. These include:
Aerosol sprays
Cosmetics, such as nail polish remover or perfumes
Flammable liquids, such as paints and adhesives
Smoke detectors containing radioactive sources
Fireworks
Refrigerants (including those in equipment)
Fire extinguishers
Goods with internal combustion engines
Lithium batteries, including batteries packed in or with electronic equipment
There are, of course, provisions in various regulations such as the US Hazardous Materials Regulations of 49 CFR (Title 49 of the Code of Federal Regulations), and Canada’s Transportation of Dangerous Goods (TDG) Regulations. Small packages of dangerous goods can often be shipped more easily under the provisions for Limited Quantities or Consumer Commodities. These provisions, however, do vary from country to country.
In addition, the regulations for shipment by air are much more stringent. Shipments by carriers who specialize in fast delivery may need to comply with the system for air transportation from ICAO (International Civil Aviation Organization), and IATA (International Air Transport Association). These may require additional packaging, labeling or paperwork, and in some cases will completely prohibit the transportation of goods that can be legally transported by ground.
If you plan on selling products online that may be considered dangerous goods or hazardous materials, here are some things you will need to do:
Consult your national transportation regulations. These will identify what qualifies as dangerous goods, as well as any exemptions or special cases that you can use to reduce the regulatory burden when shipping them
Consult with your carrier. Most national postal services will have restrictions on transport of dangerous goods, so simply boxing up those aerosol cans and popping them into the mail may be against the law. Here are some sources for information on typical carriers for online purchases:
The United States Postal Service has an online guide to hazardous materials mailability rules at http://pe.usps.com/text/dmm300/601.htm#1064962
If using the services of an online store such as eBay, consult their terms of service. eBay will allow some hazardous materials to be sold through their website, but only if the listing clearly describes the hazardous nature of the product, and specifies a shipping method that meets regulatory and postal service requirements
International shipments require knowledge of other country’s regulations. Many countries will have restrictions or licensing requirements for various types of dangerous goods in addition to the actual transportation regulations. Do not assume that just because your national regulations permit a shipment, that the countries of transit or the receiving country will also do so
Determine if the shipment will be cost-effective. It may be more money than it’s worth in extra shipping costs to ship, say, a small can of spray paint or spare lithium batteries with a larger shipment. Consider shipping without the hazardous components, and let the customer supply those at the other end
If you purchase dangerous goods online, some suggestions include:
Only purchase from reputable suppliers, who indicate that they are aware of the regulations, and prepared to meet them
Check your national regulations for any specific responsibilities that you will have to meet as a receiver (such as training), or government registration of materials such as explosives or radioactives
Be aware of other regulations that may affect the shipment. For example, verify that the product is legal in your country, and meets applicable safety standards. (That great deal on white paint might just contain an unacceptable level of lead pigment in North America.)
Be prepared for delays. That great deal on perfume may not arrive right on time for Valentine’s Day
The new online world has created many opportunities for retailers, both large and small. However, the regulations for transporting dangerous goods still apply, just as they have always done. Make sure that you take them into consideration before bidding on that “can’t miss” deal on your favourite shopping site.
If you have questions about transporting hazardous materials or dangerous goods, contact us here at ICC (1-888-442-9628 (USA) or 1-888-977-44834 (Canada)).
On September 13, 2011, PHMSA published the current 180-day special permit application list in the Federal Register. Under 49 U.S.C. 5117(c), PHMSA is required to give notice to the public of Special Permit applications which have been under review for issuance or renewal for longer than 180 days. The list includes initial Special Permit applications as well as modification, renewal, and party status requests. The reason(s) for delay and the expected completion date for action on each application is provided in association with each identified application. The full notice can be viewed at: http://www.gpo.gov/fdsys/pkg/FR-2011-09-13/pdf/2011-22942.pdf
PHMSA also published HM-244D, a corrections document in the September 13, 2011 Federal Register. PHMSA annually reviews the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180) to identify typographical errors, outdated addresses or other contact information, and similar errors. In the final rule, PHMSA is correcting typographical errors, incorrect CFR references and citations, inconsistent use of terminology, misstatements of certain regulatory requirements, inadvertent omissions of information and outdated transition dates. The full Final Rule can be viewed at: http://www.gpo.gov/fdsys/pkg/FR-2011-09-13/pdf/2011-23167.pdf
Many workers are unaware of chemicals that create potential hazards in their work environment, making them more vulnerable to exposure and injury.
What is a chemical?
All matter is composed of chemical elements. Chemicals that put people at risk in the workplace are known as hazardous materials. A wide variety of man-made and natural chemicals used in industry and manufacture can be hazardous. These include pharmaceuticals, pesticides, polymers, acids and petrochemicals to name a few. Other substances not commonly regarded as chemicals or hazardous materials may also put people at risk in the workplace, these include such substances as sawdust, brick dust, cleaners and paints. Risk levels can vary according to substances. Some chemicals may cause irritation, allergic reactions or sensitization; others may be flammable, corrosive or explosive. In some cases, chemicals can cause sickness and even death. The effects caused by hazardous materials are not always immediate. Some may put users at risk months and even years after contact, especially if the exposure was extensive.
Increasing awareness is believed to be the most effective way of preventing and reducing sickness and injury from hazardous materials. What potentially hazardous materials are being used in your workplace? They may be obvious, like pharmaceuticals, pesticides and industrial chemicals. They may be solid, liquid or gas. They may be ordinary substances such as paints or cleaning agents. Question the role of any hazardous material in the workplace. Is the chemical really necessary? How hazardous is the substance, and how could it constitute a hazard? If it could enter the body, would it be through the skin, stomach, lungs, or other avenues? What precautions are necessary for its safe handling, use and storage? Are these precautions being taken? How hazardous is the substance?
In Canada and the US, information on chemicals in the workplace must be provided with each product. Containers must be labelled with the required information so that the substance may be used safely. The information has to come from the supplier or importer.
MSDS’s are Material Safety Data Sheets that are provided in addition to the required labelling. The supplier or importer is responsible for providing this document for each product, with details on the identity of the substance, health hazard information, and precautions for safe use and handling. If an MSDS is not supplied, ask for one ~ they should be supplied on request.
Make The Job Safe
Chemicals and hazardous materials in the workplace need not be dangerous if used safely. Awareness of possible risks, even from ordinary substances, can help save sickness, discomfort and lost productivity. Information is the key to awareness of hazardous substances, with proper information and training, safe precautions can be taken. Co-operation and consultation will benefit both employer and employee, and lead to safe and effective use of chemicals in the workplace.
ICC has become a leader in providing supplies and services to hazardous materials shippers throughout North America and around the world. Whether you need training programs, labels or MSDS services, your one stop shop is ICC The Compliance Center Inc.
