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Dangerous Goods Industry Survey Identifies Compliance Challenges

Labelmaster (a U.S.-based provider of labels, packaging and technology related to the transport of dangerous goods and hazardous materials), recently announced the results of its annual 2018 Global Dangerous Goods Confidence Outlook. Sponsored by Labelmaster, International Air Transport Association (IATA), and Hazardous Cargo Bulletin, the survey was conducted to gain insight into how organizations around the globe approach dangerous goods shipping and handling, and the challenges they face.

“Shipping dangerous goods is complex and high-risk, and those responsible for compliance have an increasingly critical job,” said Rob Finn, vice president of marketing & product management at Labelmaster. “In an effort to better understand today’s dangerous goods landscape, Labelmaster, IATA and Hazardous Cargo Bulletin partnered to gather insights from dangerous goods professionals across the globe. We found that while many organizations have the necessary infrastructure, training and processes to ensure compliance across their supply chains, a large number do not.”

The survey covered personal profile information, including: respondent location, most common DG hazard class materials handled, contact role, etc.; training and DG enforcement concerns; compliance challenges; use of technology; comparison to the 2017 survey results; and other leading industry concerns.

Here are some of the key results from the survey:

Keeping up with regulations and ensuring compliance is challenging: Regulatory compliance is critical to an organization’s ability to maintain a smooth supply chain. Yet with growing volumes and types of DG, increasingly complex supply chains, and more extensive regulations, many industry professionals find it challenging to do their jobs effectively and efficiently. In fact:

  • 51 percent find it challenging to keep up with the latest regulations.
  • 15 percent were not confident that they can ensure DG regulatory compliance across their entire organization, and 13 percent were unsure.
  • 58 percent feel that even if they follow the regulations perfectly there is a chance their shipments will be stopped.

When asked to rank their greatest challenge to compliance: budget constraints (28 percent); company leadership not aware of risk (21 percent); insufficient or ineffective training (19 percent); lack of technology (17 percent); difficulty in keeping up with changing regulations (15 percent).

Compliance technology and training is often inadequate: Those responsible for DG face an uphill battle – not only in meeting evolving regulations, but also in overcoming inadequate infrastructure and training. Technology is critical to the supply chain, and significantly improves efficiency, speed, accuracy and more. And even with a number of technology resources available, 28 percent of dangerous professionals are still doing everything manually. Furthermore, 15 percent believe their company’s infrastructure ability to quickly adapt to regulatory and supply chain changes is “lagging behind the industry,” 65 percent said it is “current, but need updating” and 21 percent believe it is “advanced – ahead of the industry.”

The need for improvement extends to training as well. One-quarter of respondents feel their company’s training does not adequately prepare people within the organization to comply with dangerous shipping regulations. In many cases, the scope of employees being trained needs to be expanded. In fact, 67 percent of respondents believe dangerous goods training should be extended to other departments across their company.

An organization’s attitude towards compliance impacts its level of investment: An organization’s attitude towards dangerous goods compliance has a direct impact on how much a company invests in compliance resources. Unfortunately, their attitude towards compliance often does not reflect its true value. According to the survey:

  • 16 percent indicated that dangerous goods compliance is not a major priority for their company.
  • 54 percent wish their companies would understand that supply chain and dangerous shipping management could be a differentiator.
  • 27 percent think their company’s investment to support dangerous goods compliance is “not adequate to meet current needs.”
  • 28 percent believe their company complies “only because regulations mandate it, and adhere to minimum requirements,” while 48 percent believe their company “goes beyond requirements,” and 23 percent view compliance as a “competitive advantage.”

    Which Type of Technology Companies Use to Ship Dangerous Goods

Dangerous goods professionals desire additional support: Investment in infrastructure and training is critical to enabling DG professionals to do their jobs effectively and efficiently, and whether their budgets have increased, decreased or stayed the same, DG professionals desire additional support. When asked how they would prioritize financial support from their organization: more effective training (42 percent); technology for better supply chain efficiency and compliance (29 percent); wider access to the latest regulatory resources and manuals (18 percent); additional headcount (12 percent).

Finn added, “The risk associated with shipping and handling dangerous goods is greater than ever and industry professionals responsible for managing it need the proper technology, training and regulatory access to ensure they are moving goods in a secure, safe, compliant and efficient manner. Unfortunately, obtaining the necessary budget and resources likely requires buy-in from executive leadership, which can be an uphill battle. So how do you get that buy-in? It starts with changing the conversation around dangerous goods management.”

Changing the Conversation with Senior Leadership

Changing the conversation means reframing the overall view of dangerous goods management within an organization. This begins with dangerous goods professionals quantitatively demonstrating how their compliance program can reduce costs and increase revenue to make a positive contribution to the company’s bottom line. Simply put, it is defining your company’s “total value of compliance,” which takes into account three factors:

  • The cost of maintaining compliance throughout the supply chain, such as expenses for people, compliance products, software & technology, reporting, training, etc.
  • The cost of non-compliance due to errors and lapses, such as penalties, carrier refusal and delays, fines, remediation, higher insurance costs, etc.
  • The opportunities of higher level compliance-enabling differentiation, revenue growth and faster cash flows, such as faster product deliveries, increased brand equity, the ability to offer a wider range of products, etc.

This Total Value of Compliance (TVC) framework helps dangerous goods  companies make compliance a powerful, revenue-positive aspect of their business. To learn more about the total value of compliance, download a TVC technical brief and schedule a free assessment, visit www.labelmaster.com/tvc.

To read the full report, visit www.labelmaster.com/dg-compliance-outlook.

About Labelmaster

Labelmaster helps companies navigate and comply with the regulations that govern the transport of dangerous goods and hazardous materials. From hazmat labels and UN certified packaging, hazmat placards and regulatory publications, to advanced technology and regulatory training, Labelmaster’s comprehensive offering of i software, products, and services help customers remain compliant with all dangerous goods regulations, mitigate risk and maintain smooth, safe operations.  To learn more, visit www.labelmaster.com.

 

Hazmat University launches Hazardous Material Online Training

The U.S. Department of Transportation requires anyone whose job involves the performance of any task regulated by the U.S. Hazardous Materials Regulations to undergo hazardous materials shipping training. Likewise, all employers must provide their employees with relevant training applicable to their job function. Hazmat University offers online training programs that can be completed on your desktop, laptop, tablet, or smartphone 24/7.

“When transporting hazardous materials/dangerous goods in commerce, compliance is a primary concern. Compliance is achieved through well maintained training programs by the hazmat employer. Training is an essential component of any shipping operation to achieve safety in the transport of hazardous materials,” said Sonia Irusta, Vice President of Bureau of Dangerous Goods, LTD.

Hazmat University recognizes the need for anyone entrusted with the handling of dangerous goods to be trained on the dangerous goods regulations and to be able to perform their job functions when handling dangerous goods.

Hazmat University makes certain their training programs are exemplary and features are excellent and easy to access. Listed below are the four reasons Hazmat University is your one-stop-shop for hazardous material shipping training.

A Variety of Training Options

  • A wide range of classes that suit a variety of needs such as different modes of transportation including ground, air and sea.
  • Classes cover a wide range of regulations including: 49 CFR Hazardous Materials Regulations, the International Air Transport Association Dangerous Goods Regulations, and the International Maritime Dangerous Goods Code.

Regular Updates

  • Hazmat University updates based on “The Hazardous Materials Regulations” multiple times each year which keeps lesson plans and materials for online content up-to-date.
  • Anyone handling hazardous materials is required stay on top of any amendments and regulatory changes made.

Everything is Online

  • All courses are offered online to relieve the stresses of travel, parking and changing schedules.
  • Lessons can be accessed from anywhere at any time whether at home or in the office.

Start Immediately

  • Begin your training from the moment that you finish placing your order.
  • Your enrollment codes come with your order confirmation, so there is no delay in getting started.
  • Certificates are issued instantly upon completion.

Hazmat University provides specialized courses in the transportation of dangerous goods by air, ground, or vessel, and training for specialized needs, such as lithium batteries, general awareness, segregation, and others.

Better Response to Dangerous Goods Incidents Demanded by Community

As reported in the Terrace Standard, leaders in the Regional District of Bulkley Nechako in the interior of British Columbia have called for Canada’s railway operators to improve their response to incidents involving dangerous goods being carried by rail cars.

The Directors of Regional District of Bulkley Nechako are considering a resolution that calls for the provincial government to take the lead in talks with CN Rail to beef up response capabilities.

Canada’s Transportation Minister, Marc Garneau, has told his department to investigate railway incidents in Canada.  As reported in the Globe and Mail, derailments, collisions and other railway incidents soared in the first four months of 2018.

“The volunteer fire departments in the Regional District of Bulkley Nechako do not have the equipment, manpower, or expertise to respond to a notable dangerous goods event in a populated area,” notes background material prepared by regional district staffers for the directors.

“Increased training along will not increase local response capability to any notable degree. Also, many populated areas … are not serviced by a fire department.”

The background material adds that the regional district “and member municipalities are expected to response to a dangerous good incident, with CN Rail being prepared to respond to a dangerous goods event within 12 to 24 hours of being notified. Most of their response resources are located in Alberta.”

The resolution proposal builds on an earlier one which called for fire chiefs and local officials to have full information on the nature of dangerous goods being transported their their areas of jurisdiction.

But regional district staffers then noted that many areas of the province have a limited capacity to deal with a dangerous goods emergency.

“In staff’s opinion, CN Rail needs to play a lead role in developing rail emergency response strategy that is appropriate for northern British Columbia and other areas of the province where local response capacit, and CN Rail response capacity, is not adequate,” indicates the background material.

The new proposed resolution comes at a time of increased rail traffic on the part of CN Rail as the shipment of goods and material to and from port facilities at Prince Rupert increases.

Regional district directors June 7 approved of the new resolution during a committee of the whole session last week and it will be presented during the regional district’s regular meeting tomorrow.

Resolutions forwarded to Union of B.C. Municipalities conventions, if adopted, are then used as topics of discussion with senior governments.

Train Derailment (Photo Credit: (Transportation Safety Board)

 

New ASTM International standard supports hazardous materials packaging

A new ASTM International standard helps with pressure testing certain containers that are used to transport hazardous materials.  The standard will help meet requirements of entities that regulate and support global trade. According to ASTM International member Larry Anderson, current regulations are limited in describing how to perform such a test.

Specifically, the new test method provides instructions for performing hydrostatic pressure testing on intermediate bulk containers (IBCs). “This guide provides the detail on how to conduct pressure testing on IBCs and will provide a more consistent process for container manufacturers, test labs, and regulatory agencies,” says Anderson, who works at TEN-E Packaging Services, Inc., which assists companies with packaging testing and the certification of dangerous goods.

The new standard aims to help manufacturers pass performance tests and qualify their container designs to meet requirements of the U.S. Department of Transportation’s Title 49 Code of Federal Regulations, as well as the United Nations recommendations on the transport of dangerous goods.

The new standard (soon to be published as D8134) was developed by ASTM International’s committee on packaging (D10).

 

How to Document Weights on Dangerous Goods/HazMat Transport Paperwork

International Air Transport Association (IATA), International Maritime Organization (IMO), Tile 49 of the U.S. Code of Federal Regulations (49 CFR), & Transportation of Dangerous Goods (TDG) Documentation

No one wants to talk about their weight. Ever. In the world of transport though, you have no choice. You are required to list on your transport paperwork some sort of weight, mass, or volume. The trick is to know which regulation requires what. Should be the net weight or gross weight? Is it per package or per packaging? Sadly, depending on the regulation, the answers to those questions may differ.

Before getting started, be sure you understand what all of those terms mean. I tend to default to the IATA regulations when it comes to definitions. These are found in Appendix A. Take note that these terms are also defined in the other regulations, too. In 49 CFR check in §171.9. For IMDG they are in 2 places – Volume 1, Chapter 1.2 and Volume 2, Appendix B. TDG defines them Part 1.4.

Definitions:

Package

The complete product of the packing operation consisting of the packaging and the contents prepared for transport.

Packaging

A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.

Means of containment

The road or railway vehicle, aircraft, vessel, pipeline or any other contrivance that is or may be used to transport persons or goods.

Net quantity (or weight)

The weight or volume of the dangerous goods contained in a package excluding the weight or volume of any packaging material; or the weight of an unpackaged article of dangerous goods (e.g. UN3166).

Gross weight (or gross mass)

The weight of a packaging plus the weight of its contents.

Now that we know or remember those specific terms, let’s see what each regulation has to say in regards to the paperwork. These are known as shipper’s declarations, dangerous goods form, shipping papers, or a transport document.

IATA – Section 8 Documentation:

For this regulation, a shipper needs to review §8.1.6.9.2. In particular, Step 6 paragraph (a) provides the information we need for our shipper’s declaration.  You are required to list the net quantity of dangerous goods in each package (by volume or weight as appropriate) for each item of dangerous goods that has a different UN/ID number, shipping name or packing group along with the appropriate units of measure.  Since this is an international regulation, those units must be in metric.

IATA does one step further. Certain entries of the Dangerous Goods List in the column for the maximum net quantity per package there will be the inclusion of the “G”. For example, look at ID8000 for Consumer Commodity or certain limited quantity listings. This “G” indicates the shipper must give the gross weight of each package. To avoid confusion for the carriers this “G” must also be included after the unit of measure.

IMDG – Chapter 5.4

Under IMDG, the weight description needed is in §5.4.1.5.1.  Here it says, the total quantity of dangerous goods covered by the description (by volume or mass as appropriate) for each item bearing a different proper shipping name, UN number or packing group shall be included. At the end of that section is the notation to specific the unit of measure and that abbreviations for those may be used.   Again, this is an international regulation, so the units must be metric.

Take note, the use of the word “shall” is a mandatory requirement.

49 CFR – §172.200 Subpart C for Shipping Papers:

In 49 CFR, or as most of us call it DOT, a shipper needs to read §172.202 paragraph (a) subparagraph (5) closely. Here you see the total quantity of the hazardous materials must be indicated (by mass or volume) and it must include an indication of the applicable unit of measure on a shipping paper. Interestingly enough, §171.10 says the unit of measure is to be compatible with international standards which is metric.

49 CFR lists the “customary” units in parentheses throughout but they are not the regulatory standard. We all know the US has yet to convert fully to the metric system. However, it is a good idea to make the changeover now when it comes to our hazardous materials’ shipping papers.

TDG – Part 3 Documentation:

Here a consignor (shipper) is in a unique situation.  Section 3.5 (1)(d) simply tells a consignor that for each shipping name, the quantity of dangerous goods and the unit of measure used to express the quantity must be on a shipping document.  It does go on to say the units used must be metric.  There is not a differentiation between net and gross mass for Canadian transport.

Keeping all of these requirements straight as a shipper making shipments via ground, air, ocean and between the US and Canada can be difficult. Notice I’ve included nothing about how explosives should be listed. They have their own set of rules in each regulation. Hopefully, this blog will clarify one part of your role as a shipper. If you ever have questions or find your self in need of training, reach to us today.

 

The article was first published on the Compliance Center website.

About the Author

Paula Reavis has the following degrees: BS in Science Education, BA in Chemistry, MA in School Counseling Certification.  She is also a National Certified Counselor.  Ms. Reavis has 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 the Compliance Center in 2014, and is currently the Trainer. 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.

Five New U.S. Hazmat Rules to Look for in 2018

By Roger Marks, Lion Technology Inc.

Ask a U.S. dangerous goods (DG) professional to name the most challenging part of his or her job, and you’re likely to hear about dense regulatory standards that overlap and seem to change on a near daily basis.

As dangerous goods shippers, freight forwarders, and carriers roll into 2018, new rules for hazmat air and vessel shipments are already in effect.  In addition, U.S. DOT’s Pipeline and the U.S. Hazardous Materials Safety Administration (PHMSA) plans to start finalizing new hazmat rules as soon as February 2018.

Here, we’ll review the new U.S. DG air and vessel requirements that are mandatory now and review five new or changing U.S. DOT hazmat rules most likely to hit the books as Final Rules this year.

New IATA DGR Rules for Air Shippers

For hazmat air shippers, the 59th Edition of the International Air Transport Association’s Dangerous Goods Regulations, or IATA DGR, is in effect as of January 1, 2018.  The 59th Edition of the IATA DGR includes stricter requirements for lithium batteries shipped by air, a re-ordered list of Class 9 materials in Subsection 3.9.1, and a new Appendix I that details changes planned for air shippers in 2019.

Just before January 1st, IATA published the first Addendum to the 2018 DGR, which includes additional updates for air shippers and airline passengers.  IATA uses these addendums to make ongoing revisions to the current DGR before the publication of the next edition.

2016 IMDG Code Mandatory as of January 1st

Compliance with the latest International Maritime Dangerous Goods Code, or IMDG Code, is also mandatory as of January 1.  Updates made in the 2016 edition, compliance with which was voluntary throughout last year, are now officially in force.  These include new dangerous goods marking and labeling criteria; new packing instructions for certain shipments of engines, lithium batteries, and aerosols; and adjustments to the IMDG Code Dangerous Goods List.

The U.S. DOT, along with other federal agencies, recently released a semiannual agenda of rulemaking activities, many of which will impact hazardous materials professionals in 2018. The five rulemakings below, in progress now, are all scheduled to be published as final rules before Fall 2018.

  1. Enhanced Safety Provisions for Lithium Batteries by Air (RIN 2137-AF20

Expected in February 2018, this Interim Final Rule will harmonize the 49 CFR hazmat regulations with evolving international standards for shipping lithium batteries by air.  International requirements already in effect under the latest IATA DGR will now be adopted into 49 CFR and include:

  • Prohibiting lithium-ion cells and batteries as cargo on passenger aircraft;
  • Limiting state-of-charge to 30%; and
  • Limiting the use of alternate provisions for small cells or batteries by air.

Lithium battery requirements are one area of the hazmat regulations that have changed rapidly in the past decade and will continue to evolve as regulators and industry learn more about the potential and hazards of these batteries.

Melted mobile phone caused from lithium battery explosion

  1. Response to Industry Petitions—RIN 2137-AF09

Under regulations found at U.S. 49 CFR 106.95, interested parties may petition US DOT to amend, remove, or add hazmat regulations to enhance safety, streamline the CFR text, or boost efficiency for shippers and carriers.  In 2018, PHMSA plans to address 19 such petitions from hazmat stakeholders to provide clarification and/or relief within the hazmat shipping regulations.

Petitions to be addressed include an increase to the service life of certain hazmat tank cars and removing the emergency response number requirement for shipments of excepted quantities of hazardous materials.

This final rule is also expected in February 2018.

  1. Miscellaneous Amendments Pertaining to DOT Specification Cylinders (RIN 2137-AE80)

The U.S. DOT will address various petitions from industry stakeholders pertaining to the manufacture, maintenance, and use of DOT specification cylinders.  The rulemaking will also incorporate two existing hazmat special permits into the U.S. 49 CFR Hazardous Materials Regulations (HMR).

DOT expects to issue this final rule in April 2018.

 EPA’s Electronic Hazardous Waste Manifest System

Technically speaking, this one is a U.S. EPA rulemaking — but it does have consequences for hazmat shippers.  The Hazardous Waste Manifest is a shipping paper required for the transport of hazardous waste, and hazardous waste is regulated in transport as a hazardous material by US DOT.

On January 3rd, 2018, the U.S. EPA published a final rule to guide the process of setting and collecting fees from users of the electronic Manifest system.  Rollout of the long-planned e-Manifest system will begin in earnest on June 30th of this year, when the U.S. EPA plans to implement the system for collecting domestic hazardous waste manifests and domestic shipments of State-only regulated hazardous wastes.

As for how it will work, the U.S. EPA has determined that charging user fees to treatment, storage, and disposal facilities (TSDFs) and State-only waste receiving facilities is “the most effective and efficient means” of collecting user fees to fund the administration of the e-Manifest system.

  1. Oil Spill Response Plans for High-Hazard Flammable Trains

    High Hazard Flammable Train

    (RIN 2137-AF08)

This year, the U.S. DOT will promulgate a Final Rule to expand the applicability of oil spill response plans for trains transporting Class 3 flammable liquids in certain volumes and orientations across the train.

The bolstered requirements will apply to High-Hazard Flammable Trains, or HHFTs. A “High-Hazard Flammable Train” is a train carrying 20 cars of a Class 3 flammable liquid in a continuous block or 36 or more such cars across the entire train. Crude oil production and transport volumes have risen significantly in the past decade:  In 2009, 10,800 rail car loads of crude oil traveled by Class I railroad.  By 2015, that number had skyrocketed to over 400,000.1

The U.S. DOT plans to issue this final rule in July 2018.

These likely won’t be the only changes for U.S. hazmat shippers in 2018.  But, by identifying the future regulations or updates that may impact operations, shippers, brokers, and carriers can avoid confusion and panic when DOT finalizes the new rules.

 

Footnotes

  • *See 79 FR 45019

_____________________________

About the Author

Roger Marks is a researcher and writer at Lion Technology Inc., a provider of 49 CFR, IATA DGR, and IMDG Code dangerous goods training in the US.  Now in his 7th year at Lion, Roger creates content to inform and empower EHS professionals, and closely monitors developing regulatory actions that impact hazmat shipping, hazardous waste management, environmental compliance, and OSHA workplace safety.  Find nationwide public workshops, 24/7 online training solutions, and live webinars at www.Lion.com.

This article is republished and first appeared on OHS Online.

 

Transport Canada amends TDGR – Marine Requirements and other miscellaneous changes

As reported by the Compliance Center, the December 13, 2017 edition of the Canada Gazette II contains the expected rewrite of Part 11 “Marine” requirements of the Transportation of Dangerous Goods Regulations (TDGR). In addition, there are related changes in other parts, as well as some unrelated miscellaneous changes in other areas.

Marine Amendment

The most wide-reaching change, although perhaps of relatively minor significance to the general regulated community, is the replacement of the term “ship” with “vessel”. This, among other changes, is to update the TDGR to current Canada Shipping Act (CSA, and related regulations) terminology. Many aspects of Part 11 related to the CSA had not been updated since 2008.

Note: Interestingly, the referenced definition of “vessel” in the CSA includes all “means of propulsion”:
http://laws-lois.justice.gc.ca/eng/acts/C-10.15/page-1.html#h-2

This differs from the TDGR definitions for road and rail vehicles which expressly exclude “muscle power” as a means of propulsion. 

Other definition changes include elimination of the reference to “short run ferry”, previously defined in TDGR Part 1.3 as operating between points “not more than 3 km apart”. TDGR 1.30 special case exemption now refers only to “Ferry,” but describes within the exemption that it’s applicable to operating between two points “not more than 5 km apart.

The definition of an “inland voyage” now cites the CSA Cargo, Fumigation and Tackle regulations (CFTR):
http://laws-lois.justice.gc.ca/eng/regulations/SOR-2007-128/index.html

; which, in turn, defer to the Vessel Certificate regulations (VCR):
http://laws-lois.justice.gc.ca/eng/regulations/SOR-2007-31/

Other aspects of dangerous goods vessel shipment are also found in these CSA regulations.

One more definition that’s been changed to a citation is the one for a roll-on/roll-off (ro-ro) ship. The vessel is still referred to as a “ship”- since the definition cites the IMDG Code. For those without ready access to the IMDG, the current Ed. 38-16 version reads, in Chapter 1.2 (s. 1.2.1 Definitions):

“…Ro-ro ship (roll-on/roll-off ship) means a ship which has one or more decks, either closed or open, not normally subdivided in any way and generally running the entire length of the ship, carrying goods which are normally loaded and unloaded in a horizontal direction.”

Additional requirements now apply also to ferries regarding passenger vessel limitations, location of shipping documents and incident reporting.

Vessel Restrictions & Exemptions

Schedule 1 Column 8 restrictions regarding carrying DG on passenger vessels is further clarified by TDGR Part 1 sections 1.6 and new special case 1.10.

Gasoline and propane now have a Part 1 special case exemption 1.30.1 to facilitate fuel deliveries and reduce the need for equivalency certificates.

UN3156 is also now permitted in 25 L quantities on passenger vessels.

Mercurous chloride (calomel) is no longer included in the s. 1.46 special case exemption list.

The requirement to mark the flash point on packages with Class 3 contents (s. 4.13) has been removed as it was never an IMDG requirement.

IMDG v. TDGR

Additionally, the often-confusing reference to “Home Trade Voyages” in determining the applicability of the IMDG Code, versus the “standard” TDGR extension of ground requirements, has been replaced by a direct, simplified explanation. Voyages where the vessel (oops – I almost said ship!) is within 120 nautical miles – i.e. 222 km- from shore are considered non-IMDG unless the vessel travels south of the ports of New York or Portland, Oregon, or to another foreign destination. Thus, vessel transport of dangerous goods to St. Pierre and Miquelon (territories of France), despite being within 20 km or so from Newfoundland, require compliance with IMDG.

Inland (mostly “fresh water”) voyages between Canada and other countries – e.g. Great Lakes or rivers to the US – remain excluded from mandatory IMDG compliance. Conversely, vessels registered in Canada but transporting between two foreign destinations, remain under IMDG requirements.

Other Amendments

Changes not directly related to Part 11 topics include correction of some typographical and miscellaneous errors in the TDGR or website html information.

Examples include re-entering the PG II information for UN1790, UN2734 on the website; editing SP 159 to clarify that the new Class 9 Lithium Battery label illustration is only used for labels and not used for placarding purposes – standard Class 9 placards are used (as is the case in air, ocean and US 49 CFR); and updating ICAO references in Part 12.

The Table in 5.16 has been repealed due to the updates in the referenced CSA standards.

Transition:

The changes are effective as of the December 13th CG II publication date and have a transition period of 6 months for mandatory implementation. The CGII document which includes a discussion of the changes in the RIAS (Regulatory Impact Analysis Statement) is found at:

http://canadagazette.gc.ca/rp-pr/p2/2017/2017-12-13/html/sor-dors253-eng.html

 

Changes to the International Maritime Dangerous Goods (IMDG) Code

The International Maritime Dangerous Goods (IMDG) Code or International Maritime Dangerous Goods Code is accepted as an international guideline to the safe transportation or shipment of dangerous goods or hazardous materials by water on vessel.  A Corrigenda was published earlier this month that makes some changes to the 38-16 version. Note that this version becomes mandatory for use starting January 1st, 2018.

A summary of the key changes is as follows:

  1. The words “marking” and “markings” have all been replaced with “mark” or “marks” through the entire code.
  2. The new Class 9 Hazard Label for Lithium Batteries also received some clarification in Chapter 5.2.2.2.1.3 in that the number of vertical stripes must be 7 at the top and the bottom must have the symbol and the number 9. Words describing the hazards are not permitted on this label.
  3. Special Provision 384 that speaks to the new Class 9 Hazard Label was revised to clarify that there is no placard equivalent to this new label. If needed, the normal Class 9 placard should be used.

The International Maritime Dangerous Goods (IMDG) Code was adopted in 1965 as per the SOLAS (Safety for Life at Sea) Convention of 1960. The IMDG Code was formed to prevent all types of pollutions at sea.

The code also ensures that the goods transported through marine transport are packaged in such a way that they can be safely transported. The dangerous goods code is a uniform code. This means that the code is applicable for all cargo-carrying ships around the world.

The dangerous goods code has been created as per the recommendations of the United Nations’ panel of expert on transport of dangerous goods along with the IMO (International Maritime Organisation). This recommendation by the UN was presented as a report in the year 1956 after which the IMDG Code was started to be drafted in the year 1961.

 

Are North American Hazmat Truckloads Safe?

This past summer, commercial motor vehicle enforcement personnel in Canada and the United States conducted more than 62,000 driver and vehicle safety inspections on large trucks and buses during the Commercial Vehicle Safety Alliance’s (CVSA) 30th annual International Roadcheck.  19.4 percent of commercial motor vehicles inspected (Level I, II or III Inspections) were placed out of service.  4.7 percent of all drivers inspected (Level I, II, and III Inspections) were placed out of service.  7,713 inspections were conducted in Canada; 54,300 were conducted in the United States.

International Roadcheck is a three-day enforcement event when CVSA-certified inspectors conduct high-volume, large-scale, high-visibility roadside inspections of large trucks and buses. Commercial motor vehicles and their drivers were checked at inspection sites, weigh stations and roving patrol locations along roadways in North America throughout the 72-hour enforcement initiative.

Of the 2,267 vehicles carrying hazardous materials/dangerous goods that received a Level I Inspection, 12.8 percent were placed out of service for vehicle-related violations.  The top three vehicle violations related to the transportation of hazardous materials/dangerous goods were for loading and securement (40.4 percent of all out-of-service hazardous materials/dangerous goods violations), shipping papers (22.7 percent) and placarding (20.8 percent).

Hazardous Materials Transportation Placards on rear of a Fuel Tanker

Of the drivers inspected that were carrying hazmat loads, 1.9 percent were placed out of service for driver-related violations.  The top three driver-related violations were for hours of service (32.3 percent of driver out-of-service violations), wrong class license (14.9 percent) and false log book (11.3 percent).

Each year, International Roadcheck places special emphasis on a category of violations. This year’s focus was cargo securement. While checking for compliance with safe cargo securement regulations is always part of roadside inspections, CVSA highlighted proper cargo securement this year as a reminder of its importance. Cargo securement violations (not including hazardous materials/dangerous goods loading/securement) represented 15.7 percent of all vehicles out of service violations during 2017 International Roadcheck.