ICC’s 2020 Regulatory Resolutions

Here it is – January 2020.  The time when all holiday decorations are put away and people make resolutions for the coming year.  Things we would like to change about ourselves, our workplace or our home.  We’ve all heard them.  I’m going to work out more.  There will be more family time.  We will eat healthier.  I’ll be kinder to my co-workers.  That one is mine in case you were wondering. 

Now at this point you are asking how does resolution making have anything to do with transportation of dangerous goods?  Well, I asked our Regulatory Team what their “regulatory resolutions” would be.  In other words, if they had the power, what changes or resolutions would they make to a regulation.  Oddly enough, with their responses, not a single regulation escaped a “resolution”!  Some of the items listed below were mentioned on more than one person’s list.

49 CFR:

  • Resolve to get rid of the combustible liquids.No one else in the world regulates these.
  • All lithium batteries should be transported as fully regulated with UN Specification Packaging and paperwork.No more exceptions. 
  • Resolve to adjust the packaging recertification requirements.Align them more with Canada’s.  As long as the components and specifications do not change there should be no need to re-test UN packaging every 2 years.  49 CFR should allow packaging manufacturer’s to simply send in an application for certification every 5 Years.  This would certainly save on costs!

TDG:

  • There should be a 90-day time limit for training like what is found in 49CFR.No more working under a trained person forever.
  • Limited Quantity shipments should require training.They are still considered Dangerous Goods just like in the other transport regulations.
  • All shipping documents should have a mandatory signature requirement.Again, all of the other regulations have this.
  • Change some of the wording to better match what is in other transport regulations.Get rid of “means of containment”.
  • Include a segregation or separation chart similar to what is in the other regulations.
  • Orientation arrows should be re-introduced and required for all liquids in Canada.This one may come true.  This is in a proposed amendment.  We could be pleasantly surprised.  Stay tuned to our blog posts to see what happens. 
  • Align TDG’s Marine Pollutants with one either the UN Model Recommendations or 49 CFR rather than having their own system.

IATA:

  • Amend Section 2 to say lithium batteries are NEVER be carried in checked baggage.Carriers don’t allow it anyway so just make it a blanket statement.
  • Further explain what is meant by “responsible person” for infectious substances in Class 6.2

IMO / IMDG Code:

  • Create a standardized, formatted transport document similar to what is used in IATA.
  • Provide examples of completed transport documents indicating some of the additional wording and notations required.

UN Model Recommendations:

  • Clarify what is meant by “informational telephone number” on the Lithium Battery Handling Mark.Here again is another one that could change in the near future.  This requirement could be going away as there is a white paper submitted on this topic.  Until then, explain what the number is supposed to really be.

It is quite a list and these are things that were at the forefront of our minds.  Perhaps you have some to add to the list.  Mention them in the comments. 

Despite the length of the list, these are things that we often get questions about via our helpdesk or in our trainings.  Given it is the new year, now is the time to look at your training, packaging, shipping needs to see how ICC can help.  Visit our website (www.thecompliancecenter.com) or give us a call today.  The numbers for Customer Service are 888-442-9628 in the US and 888-977-4834 for Canada.

Paula Reavis

Paula Reavis

Degrees: BS in Science Education, BA in Chemistry, MA in School Counseling Certification: National Certified Counselor Paula Reavis comes to us with a teaching background and several years of experience in Hazard Communications. She is knowledgeable in HazCom2012, WHMIS (old/new), 49 CFR, IATA, IMDG and TDG. She started with the company in 2014, and is currently the Trainer for the US. She is active in several associations including NACD, IHMM and SCHC where she served as chair of the Membership and Awards Committee. She is based in St. Louis, Missouri.