by James Henry, CDGT, CET 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.
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.
The use of the DANGER placard changes as well. The DANGER placard can be displayed in place of hazard class placards when there are 2 or more classes and there are 2 or more small means of containment. The current restrictions for the use of the DANGER placard do not change, but those restrictions now include:
gross mass not to exceed 1,000 kg,
not to include only one hazard class, and
are offered by one consignor at one location.
The 500 kg requirement for placards is found in section 4.16.1 with the restrictions being very similar to the restrictions currently found in the exemption 1.16 500 kg gross mass exemption. If any part of a shipment involves a restriction that is listed, then that amount is not used in the calculation for determining placards. For example, if a shipment consists of 2,300 kg of dangerous goods, with 2,000 kg being sodium, then that shipment will require the hazard class placard with UN number as it requires an ERAP. The remaining 300 kg, being under the 500 kg, will not require placards.
The wording of section 4.22.1 for the Category B mark has been changed to read that the Category B mark replaces the Class 6.2 hazard label.
For dangerous goods that are subject to special provision 23, it will now be required to add the words “toxic – inhalation hazard” next to the shipping name for small packages, and on the large means of containment, in addition to any required placards.
The purpose of this amendment is harmonize with the international regulations as well as with 49 CFR. There may be additional costs to carriers for implementing these changes, but TC is of the opinion that for carriers who do business in the US, they will already have the additional placard holders on their trucks.
Transport Canada has given 75 days for comment from December 1, 2012. Comments are to be sent to:
Genevieve Sansoucy, Legislation and Regulations, Transport Dangerous Goods Directorate, Department of Transport, Place de Ville, Tower C, 9th Floor, 330 Sparks Street, Ottawa, Ontario K1A 0N5 (tel.: 613-990-5766; fax: 613-993-5925; email: TDGRegulatoryProposal-TMDPropositionReglementaire@tc.gc. ca).
by James Henry, CDGT, CET on December 7, 2012 at 1:53 pm · in Jim's Blog, Regulations
Transport Canada published Amendment 11 in the Canada Gazette, Part II on December 5, 2012. In Amendment 6 (February 2008), a number of errors were introduced. This amendment corrects those errors, and brings others into line with some changes to the Act (June 2009).
The changes in this amendment are:
definition of “person” now aligns with the definition in the Act, including the addition of “organization”,
section 1.15 150 kg Gross Mass Exemption has been changed to allow up to 6 aerosols to be transported without complying with Part 5 Means of Containment. However, the aerosols must have a valve protection cap; in addition, special provision 80 has been changed to provide consistency,
section 5.5 Filling Limits goes back to the wording prior to Amendment 6 so as to remove any confusion and misinterpretation regarding standards or safety requirements,
the placarding provisions of the IMDG Code have been placed in Part 9 Road and Part 10 Rail; this allows for the placarding under the IMDG Code which means that placarding requirements are simpler and will reduce if not eliminate confusion,
other changes are of an editorial nature or typo:
in section 2.29(2)(c), 0.2 g/L now reads 0.2 mg/L
in the restricted paragraphs of section 1.15 and section 1.16, the title for Class 4 has been corrected
in section 1.32.1, the shipping name Liquefied Petroleum Gas now reads Liquefied Petroleum Gases
table of contents for Part 2 Classification now shows Category A and Category B instead of risk groups
in part 2, appendix 3, item 3, the word “formerlly” is changed to read “formerly”
section 1.32.2 Gases, Absolute Pressure between 101.3 kPa and 280 kPa now reads 1.32.2 Class 2, Gases, Absolute Pressure between 101.3 kPa and 280 kPa
in section 1.47 UN1044, Fire Extinguishers, Exemption, “and (d)” is added after “Paragraphs 5.10(1)(a)(b)”
Although these changes come into force on December 5, there is a transition period of six months (June 5, 2013) before all the changes become mandatory.
by James Henry, CDGT, CET on September 4, 2012 at 9:40 am · in Jim's Blog
Based on the information available to date, the following are some of the changes that will be in the 2013 editions of the IATA Dangerous Goods Regulations and the IMDG Code.
lithium ion batteries > 100 Wh but < 160 Wh may be carried as spare batteries in carry-on baggage
portable electronic devices containing batteries should be in carry-on baggage and be protected to prevent short circuits
medical devices or equipment that contains or may contain infectious substances are not subject to the regulations provided that the item is packed so that there will not be any leakage
packages containing medical devices or equipment must be marked “Used Medical Device” or “Used Medical Equipment”
lithium cells and batteries must be of a type proved to meet the UN Manual of Tests and Criteria
dangerous goods list additions:
UN3496 batteries, nickel metal hydride
UN3497 krill meal
UN3498 iodine monochloride, liquid
UN3499 capacitor
UN3500 chemical under pressure, n.o.s.
UN3501 chemical under pressure, flammable, n.o.s.
UN3502 chemical under pressure, toxic, n.o.s.
UN3503 chemical under pressure, corrosive, n.o.s.
UN3504 chemical under pressure, flammable, toxic, n.o.s.
UN3505 chemical under pressure, flammable, corrosive, n.o.s.
UN3506 mercury contained in manufactured articles
dangerous goods list deletions:
UN3492 toxic by inhalation liquid, corrosive, flammable, n.o.s.
UN3493 toxic by inhalation liquid, corrosive, flammable, n.o.s.
the excepted quantity code for the various silanes has changed to E0
special provision 240 applies to vehicles powered by batteries, such as, scooters, e-bikes, wheelchairs, etc. Hybrid vehicles must be consigned under one of the following: UN 3166 Vehicle, flammable gas powered or UN 3166 Vehicle, flammable liquid powered, as appropriate. Vehicles which contain a fuel cell shall be consigned under the entries UN 3166 Vehicle, fuel cell, flammable gas powered or UN 3166 Vehicle, fuel cell, flammable liquid powered, as appropriate.
special provision 304 is now about transporting non-activated batteries
special provision 360 is for lithium battery powered vehicles consigned under UN3171
special provision 361 is for electric double layer capacitors with energy storage capacity > 0.3 Wh
special provision 362 is for liquids, pastes or powders that are pressurized with a propellant
special provision 363 is for dangerous goods in equipment where the dangerous goods are in excess of the limited quantity index
new packing instructions for chemicals under pressure (et al) UN3500 – UN3505
the marking of the identification number on packages must be a minimum of 12 mm in height, including the prefix UN, except for packages of < 30 L/ kg, where the info must be 6 mm in height
new warning mark for containers that use dangerous goods for cooling or conditioning purposes
for UN0336 and UN0337, the shipping document must include the classification reference issued by the competent authority
in addition, there are editorial updates – i.e. punctuation changes, spelling corrections, etc. that are too numerous to list.
Please keep in mind that as of January 1, 2013, the IATA Dangerous Goods Regulations, 54th Edition, will come into force – no transition period. The IMDG Code, Amendment 35-10 will still be in force for 2013. Amendment 36-12 is optional for 2013, but becomes mandatory in 2014. In other words, 2013 is the transition period for Amendment 36-12.
by ICC Compliance Center on March 23, 2012 at 8:51 am · in Products, Regulations
UN Packaging codes reveal necessary information about a package’s specifications. They provide concise answers to questions of: what it can hold, how much, where it was authorized, when it was made, etc.
The UN packaging code, however, doesn’t always tell the whole story…
Although there may be other test levels achieved, these may not be reflected on the packaging itself. For example, take a steel drum that has successfully passed the most stringent tests (PG I), and is marked accordingly with the ‘X’ performance level. This package, in all probability, can/has also passed the less rigorous tests required to meet both the ‘Y’ and ‘Z’ performance level. (Referencing a testing certificate, a test report, or the registration of a successfully tested package, will confirm this.)
So what does this all mean?
Filling limits for single or composite packaging, containing less hazardous material for which they were tested & marked (e.g. PG III material in a PG I packaging), can be re-calculated as per below.
Provided all the performance criteria can still be achieved by the higher relative density product, the following will apply:
For liquids:
a. A packing group I packaging may be used for a packing group II material with a specific gravity not exceeding the greater of 1.8, or 1.5 times the specific gravity marked on the packaging.
b. A packing group I packaging may be used for a packing group III material with a specific gravity not exceeding the greater of 2.7, or 2.25 times the specific gravity marked on the packaging.
c. A packing group II packaging may be used for a packing group III material with a specific gravity not exceeding the greater of 1.8, or 1.5 times the specific gravity marked on the packaging.
For Solids:
A single or composite packaging which has been tested and marked for liquids may be filled with solids to a gross mass not exceeding the capacity of the packaging in liters, multiplied by the specific gravity indicated in the package marking, or 1.2 if there is no indication in the marking. In addition,
a. A single or composite packaging which has been tested and marked for packing group I liquids may be filled with a packing group II solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 1.5, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).
b. A single or composite packaging which has been tested and marked for packing group I liquids may be filled with a packing group III solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 2.25, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).
c. A single or composite packaging which has been tested and marked for packing group II liquids may be filled with a packing group III solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 1.5, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).
For more information, please to refer to the applicable regulations:
TDG: CAN/CGSB – 43.150 – 97 – Part II, 13 & 14
49 CFR: Part 173.24 a (b) (1)-(3)
UN Model Regulations (17th Ed.): Part 6.1.3 – Note 3
ICAO: Part 6, Chapter 2, Note 3
IATA: Section 6.0.4.0.3
IMDG Code: Part 6.1.3, Note 3
by James Henry, CDGT, CET on October 14, 2011 at 8:00 am · in Jim's Blog
I am beginning to feel like Peter Mackay of Hazardous Cargo Bulletin (HCB) – doing this in two parts. Cheers Peter!
The Thursday session continued with Richard Bornhorst, USCG, on Amendment 35 of the IMDG Code. This amendment is at the 16th Edition of the UN model regulations, but does not include the revised EHS/GHS criteria. Some of the new issues with this Amendment are:
the new limited quantity mark
new Chapter 5.5 on fumigated containers, including a fumigation certificate
UN3166 Engines, has two new special provisions 961 & 962
new TIH n.o.s. entries UN3488 – 3494, such as sour crude oil
training record retention
monitoring equipment as part of a CTU does not need to be declared
Some proposals for Amendment 36 are:
revised EHS/GHS criteria
adopt the 17th Edition of the UN model regulations
revision of Chapter 7 – simplified stowage and packing requirements for Class 1 based on vessel type
books to be published every 4 years with amendments every two years
new illustrations
new guidelines for packing CTUs
revised circular on CTU inspections that contain dangerous goods; 56,000 CTU inspected worldwide in last year with 51,000 in the US alone
Bob Richard then continued the presentation on:
DSC 16 (Sub-committee on dangerous goods, solid cargoes and containers) on fibre bulk containers (FBCs) – these will be restricted to a stacking height of 3, and restricted on long distance roll on, roll off (RoRo)
batteries tested prior to 2014.01.01 will be grandfathered
there were papers that were presented by Belgium, China, Korea and DGAC that were rejected:
China proposed a limited quantity for alcohol
Korea: 1) prohibit metal packaging for Li batteries, 2) separate wet batteries from Class 3, 3) allow the use of the UN number on limited quantity packages, 4) the overpack marking should be a minimum of 65 mm in height
DGAC: wanted specific packaging and storage rules for Class 4.3
all the above were rejected as these proposals should be presented to the UN not the IMO
Dave Evans (Purolator Canada) and Duane Pfund (PHMSA) brought us up to date with the changes in Canada. Amendment 8 is still at Justice. Linda Hume is off on medical leave and will retire in February 2012. Transport Canada has met with PHMSA recently and both signed a memorandum of understanding regarding compressed cylinders. Both parties have agreed to circulate proposed changes with each other.
Geoff Leach returned to go over the top 5 feedback points regarding training programmes. His first question was “what is feedback?”. Feed back is: Knowledge of the results of any behavior, considered as influencing or modifying further performance.
if you don’t know where you’re going, how do you know which route to take? you need objectives
talking vs asking: why ask? a) to test understanding & acceptance, b) to stop switching off, c) stop participants from being passive
why are we here? be specific – illustrate by using an example, i.e. ValueJet
reading vs teaching
visual aids – Geoff did an exercise of reading a list of items vs showing a list of pictograms
Chris Egloff, Americase, did a presentation of shipping oxygen cylinders or generators by air. This only applies to the US, but also applies to shipments leaving the US, entering the US, intra US or US flagged aircraft. FedEx requires the use of the ATA300 package. One issue of note is the number of cylinders per case. The regulations do not say you can or can’t have multiple cylinders in a package. The shipper would need to refer to the manufacturer for clarification. Boeing 787s do not have oxygen generators on board, rather, the aircraft has a 10k cylinder in the cabin. A 10k cylinder is a 10,000 psi cylinder.
Gene Sanders lead a session on classification questions – how not to write them. He talked about wisdom vs experiences and introduced Emily.
M – measured
L – learning
E – exercise
M-L-E
Gene does not say that the course will end with a test, quiz or exam, but says that Emily (MLE) will show up at the end of the session.
On Friday morning, Duane Pfund presented Bob Richard with a PHMSA inspection shield for his years of service at PHMSA. We were also regaled with some stories about Bob.
Three inspectors from PHMSA told us that inspections are random subject to a priority list. The regulations pertain to shippers, carriers, freight forwarders, 3rd party labs, SP holders, fillers and shippers of aerosols, cylinder re-qualifiers, nurse tanks, package manufacturers and high hazard entities (TIH). The biggest question is “why me?”. The inspectors show up if there has been a complaint, if the party is high risk (TIH), ongoing investigations, observations or there has been an incident history. Inspectors will observe the various processes, use of test equipment, training, records, closure instructions, shipping papers and MSDSs.
Some consistent problems encountered: no training records, failure to train, package closures, improper marks and labels, incorrect shipping papers, failure to register with PHMSA, and lack of security plans. Stats for 2010: 1,650 inspections, 42% OK – no further action required; 57% non-compliant and 1% waiting for test results.
Donna Lepik (CHEMTRC/TRANSCAER), David Binder (Tanner Industries) and Bill Burke (Dupont) did “Soup to Nutz”. This presentation dealt with the development of the TRANSCAER anhydrous ammonia training programme. To view this programme, go to http://www.transcaer.com/aa-tour. If you work with anhydrous ammonia, there is a wealth of information here.
For dangerous goods trainers, this is the symposium that you need to attend.
