Packing Groups GHS and TDG why is this a risk to Workers

Those three small numbers are in place for a HUGE reason and do you know the

difference and where that data applies!!!!

It comes to your door in multiple ways

Remember the Schedule 1 in Canada is different than the one in the USA

Having Both Law and Tables handy

• USA tables http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.6f23687cf7b00b0f22e4c6962d9c8789/?vgnextoid=d84ddf479bd7d110VgnVCM1000009ed07898RCRD&

• Canada SCHEDULES• http://wwwapps.tc.gc.ca/saf-sec-sur/3/sched-

ann/schedule1form.aspx

Sounds more and more like GHS but no it is NOT

A hazardous material is any solid, liquid, or gas that can harm people, other living organisms, property, or the environment. Hazardous materials (hazmat) may be radioactive, flammable, explosive, toxic, corrosive, biohazardous, an oxidizer, an asphyxiant, a pathogen, an allergen, or may have other characteristics that render it hazardous in specific circumstances.

Are PACAGING GROUPS the same as PACKING GROUPS

The X Y Z Game

DOT Packing Groups A hazardous material’s Packing Group reflects the level of hazard and determines the mark required on the packaging. Packing Group Degree of Hazard Packaging • Mark I most serious X• II moderate hazard Y • III low hazard Z

PLACARDS & LABELS

Articles MUST be Properly

• Identified• Classified• Packed• Marked• Labeled• Documented• Registered, if necessary• Placarded

Packing Groups

• Packing Group I– GREAT DANGER

• Packing Group II– Medium Danger

• Packing Group III– minor danger

https://www.tc.gc.ca/eng/tdg/clear-part2-339.htm#sec215

Everything starts in a package can you read PACKAGE codes

Solids

Liguids

Regulations Establish Hazard Classes & Packing Groups

Hazard Classes1. Explosive2. Compressed gas3. Flammable liquid4. Flammable Solid5. Oxidizer6. Poison/Infectious Substance7. Radioactive8. Corrosive9. Miscellaneous

Packing Groups• PG I Extreme Hazard• PGII Major Hazard• PGIII Minor Hazard

Each CLASS is VERY Unique

Dangerous Goods are more than just CLASS and Colors they have Groups

9 Classes to learn and multiple learning curves to KNOW

4 through 8 a must KNOW

Canada vs the USA• The United Nations Economic and Social Council issues the

UN Recommendations on the Transport of Dangerous Goods, which form the basis for most regional, national, and international regulatory schemes. For instance, the International Civil Aviation Organization has developed dangerous goods regulations for air transport of hazardous materials that are based upon the UN Model but modified to accommodate unique aspects of air transport. Individual airline and governmental requirements are incorporated with this by the International Air Transport Association to produce the widely used IATA Dangerous Goods Regulations (DGR).

• The USA The Pipeline and Hazardous Materials Safety Administration regulates hazmat transportation within the territory of the US by Title 49 of the Code of Federal Regulations.

• The U.S. Occupational Safety and Health Administration (OSHA) regulates the handling of hazardous materials in the workplace as well as response to hazardous-materials-related incidents, most notably through Hazardous Waste Operations and Emergency Response (HAZWOPER. regulations found at 29 CFR 1910.120.

• In Canada Transportation of dangerous goods (hazardous materials) in Canada by road is normally a provincial jurisdiction. The federal government has jurisdiction over air, most marine, and most rail transport. The federal government acting centrally created the federal transportation of dangerous goods act and regulations, which provinces adopted in whole or in part via provincial transportation of dangerous goods legislation. The result is that all provinces use the federal regulations as their standard within their province; some small variances can exist because of provincial legislation. Creation of the federal regulations was coordinated by Transport Canada. Hazard classifications are based upon the UN Model.

Crack those regs look in Column 5 in Canada this is column 4

Same RISKS just different tables with the same data

NEVER EVER SHIP unit you LOOK IT up!

Certain risk dictate the Packing Group

And UNIFORMED RULES are Applied

Regulations Establish Testing Procedures

• Vibration test– one hour vibration at 1.6 mm lift• Bottom Lift – Two lifts each way with 1.25 x permissible

mass • Stack Tests – 24 hour• Leak Proofness – 5 minutes at 20 kPa PG II & PG III

– Every bottle in production must be leak tested at 20 kPa for PG II & PG III

• Hydrostatic Pressure – IBCs require 10 minutes at 100 kPa in EU; can be less in US & Canada

• Drop Test– 0.67-1.2 meters with IBC at -18°C for PG III compliance

What makes an IBC meet the RPCL?

• Packing Group III compliance– Y or Z on the UN Mark– Meets the testing requirements for PGIII

• Tamper Evidence– Valve handle– Foil Seal on valve– Cap

• One way or check valve– There are no requirements at this time regarding how much back pressure this

check should handle. • Unique Serial Number or other traceability system/device• There is no such thing as a UN rated single use or one-way IBC. To

reuse/refill or not is the choice of the user, not the government, as long as it meets the legal requirements.

GHS HAZARD GROUPS not the same as PACKING GROUPS under TDG

And GHS Categories are not Packing Groups under this either

GHS Physical Hazards• Explosives • Flammable Gases • Flammable Aerosols • Oxidizing Gases • Gases Under Pressure • Flammable Liquids • Flammable Solids • Self-Reactive Substances • Pyrophoric Liquids • Pyrophoric Solids • Self-Heating Substances • Substances which, in contact

with water emit flammable gases • Oxidizing Liquids • Oxidizing Solids • Organic Peroxides • Corrosive to Metals

GHS Health Hazards• Acute Toxicity • Skin Corrosion/Irritation • Serious Eye Damage/Eye Irritation • Respiratory or Skin Sensitization • Germ Cell Mutagenicity • Carcinogenicity • Reproductive Toxicology • Target Organ Systemic Toxicity - Single

Exposure • Target Organ Systemic Toxicity - Repeated

Exposure • Aspiration Toxicity

GHS Environmental Hazards

• Hazardous to the Aquatic Environment • Acute aquatic toxicity • Chronic aquatic toxicity – Bioaccumulation potential – Rapid degradability

GHS Label Elements• Product Identifier• Signal Word (Danger, Warning)• Hazard Statement (for each hazard

class and category)• Pictogram(s)• Precautionary Statement (for each

hazard class and category)• Name, Address and Tele. # of chemical

manufacturer

Signal Words"Danger" or "Warning" are used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category.

• "Danger" for the more severe hazards

• "Warning" for the less severe hazards.

Hazard Statements

• Hazard statements are standardized and assigned phrases that describe the hazard(s) as determined by hazard classification

Hazard Statement Examples• “Causes eye irritation”• “Toxic if inhaled”• “Flammable aerosol”• “May cause cancer”• “May cause respiratory irritation”• “Harmful to aquatic life”• “Contains gas under pressure; may explode

if heated”

Section of the SDS 14 – Transport Information

Provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea:

• UN number • UN proper shipping name• Transport hazard class(es)• Packing group number• Any special precautions which an employee should be

aware of or needs to comply with, in connection with transport or conveyance either within or outside their premises

Don’t forget the risk of SMALL CONTAINERS and What may be inside

Exceptions are not for the faint of heart; they must be earned. You can have two similar chemicals that are the same hazard class, same packing group, same label(s), The Schedule Table can show that, and one of those chemicals can take the exception in Column while the second chemical will find the word “None” in that column. If you ship Acetone, Paint or even Flammable Liquid, N.O.S., they are all Class 3 (flammable), have Packing Group II in Column 5 and only one label (Flammable Liquid) in Column 6. If you look at the Column 8A Exceptions, you will see that they all show the number “150” as in regulations schedule.REMEMBER TO LOOK UP THE RIGHT TABLE FOR THE COUNTRY YOU ARE IN!!!!

Oh those EXEMPTIONS• Another good example would be limited quantities for a Corrosive material. If you look up Paint or Paint

Related Materials, Class 8 or Corrosive Liquid, Acidic, Organic, N.O.S., Class 8 in the 172.101 HMT, you will find the exception in column 8A for both. The regulations will not authorize an exception for Packing Group I Corrosives because they cause full skin destruction in under 3 minutes (the most severe Packing Group), so the word “None” appears in Column 7A for PG I Corrosives.

• Limited Quantities of Corrosives in PG II or III are excepted from hazard class labels (unless offered for transportation by aircraft) and specification packaging requirements when packaged in combination packagings. Limited Quality packagings that conform to the provisions of regulations are also excepted from the shipping paper requirements in regulations (unless a hazardous substance, hazardous waste, marine pollutant or offered by aircraft) and are not required to meet the placarding requirements in 0.

• The combination containers must meet the general packaging regulations in Subpart B, so they should be of good quality because there are no specifications or testing requirements. If the containers were to fail in transportation, the shipper would have little recourse since it is the shipper’s responsibility to insure that the containers are proper and compatible for the hazardous materials being shipped. Many shippers take the Limited Quantity exception, but still choose to use the proper specification container in case there is a packaging issue down the road (pun intended), they could tell the DOT that they had exceeded the Limited Quantity packaging requirements. That way if the container were to fail, it would not be because of subpar packaging.

Remember thatClass' designators indicating the type of hazard a dangerous goods presents, a 'Packing Group' is assigned to dangerous goods according to the degree of hazard they present. These are as follows:

Packing Group I = great danger Packing Group II = medium danger Packing Group III = minor danger

Classes 3 and 4, Divisions 5.1 and 6.1 and Class 8 and some Class 9 substances have Packaging Groups assigned to them. Packing Groups are not assigned to Class 1 'explosives'; Class 2 'gases' and 'gas mixtures'; Class 6.2 'infectious substances' or Class 7 'radioactives.' Packaging Group designators are always written in Roman numerals. For example PG II.

When performance testing a dangerous goods package in order to determine that the design of the package meets the minimum performance criteria required by the UN, and to attain the mandatory UN approval, the Packaging Group of the product to be transported in the package is one of the factors that determines the test protocol. Testing conducted on a package for a P.G. I product is considerably more stringent than the testing requirements for a P.G. III product.

Next do you know the true value of column 7 in the USA when it comes to shipping

risks and restrictions column 6 in Canada

Yes they do max out

And what about OVER PACKED rules