With the Globally Harmonized System (GHS) now officially in place as the standard for the labelling of hazardous chemicals across the US, Canada is preparing to adopt the system in 2017. It’s an indication that regulations regarding hazardous warnings have taken a great stride towards standardization.
However, there are aspects to the laws governing the transportation of hazardous goods that are not fully covered by the GHS provisions.
Produced materials simply need to be transported to where they’re required – this is the essential nature of any produced chemicals. The challenge therefore is staying compliant with the rules of the territory where the goods will be travelling through, and the ultimate location where they will be used.
This article will explore the ins and outs of transportation regulations, the web of requirements that need to be respected, and how you can more easily achieve authoring compliance throughout all stages of the transportation process.
The Trials of Transportation
It is important to grasp the intention behind the requirements that a producer is expected to conform with. This is what should be foremost in considerations when the time comes to move a batch of containers out of the production plant and get them on the road.
These containers of produced chemicals will need to be accompanied by both an authoritative Safety Data Sheet document (SDS), as well as the required labelling on each container.
While the SDS document is absolutely essential, the labelling is just as vital. This labelling, which fluctuates in its applicability depending on the format and number of containers being utilized, should be able to answer two specific concerns:
- What exactly is being transported?
- What specific hazards should be anticipated?
The ideal labelling utilized should be informative, while clearly presenting the above two points in the most prominent and effective way.
The application of the GHS to this aspect of labelling is clearly highly useful, because it provides a standardized set of visual images that clearly indicate the primary hazard involved, be it “flammable”, “toxic”, and so on. These can be readily utilised across any combination of labels.
The labelling should also be designed to include as much useful additional information as possible, including a full description of the exact nature of the solution, mix or general contents of the container. It should include the correct UN number to indicate the purpose of the product, as well as any prominent information that would take precedence in an emergency situation.
The challenge built into these needs is that a label, by definition, is restrained by size and legibility. Imparting an extensive amount of information on every label, to the extent where information on the contents is over-provided, dilutes the original intent.
There is also the issue that requirements that change depending on the nation / state where the container is being transported to or via, and what needs to be provided can shift and change quite substantially.
What is needed then, is a rugged solution that can resolve the often competing considerations of:
- Clear Safety Communication
- Clear Content Communication
- Size Limitations and Transport Type Considerations (Truck, Ship, Rail, etc).
- National Health & Safety Authority Requirements (e.g. OSHA)
- National Transportation Authority Requirements (e.g. Department of Transport).
Dealing with Two Authorities
One aspect rears its head time and again whenever dangerous chemical goods are transported, namely the need to respect the regulations of both the health & safety agency, and the transportation agency.
In the United States, this generally refers to the Occupational Health and Safety Agency (OSHA) and the Department of Transportation. In Canada, the involved bodies would be Health Canada and Transport Canada.
For exports going further afield, the governmental bodies vary massively. Exporting to Europe will involve satisfying regulations that stretch across all European Union member states, as well as the health & safety and transport regulations of each individual country.
There are a number of measures that can be taken in a broad effort to satisfy the requirements of both bodies. The most prominent should be an effort to ensure that the label contains elements that can simultaneously satisfy the requirements of both bodies.
Choosing the language and formatting that achieves this can be harder than it looks, when specifics are provided by both bodies.
For example, Transport Canada goes into detail regarding the size of the labels that should be utilised. In that agency’s online guide to Dangerous Goods Safety Marks, it states:
“Each side of a label (for a hazardous goods container) must be at least 100 mm in length with a line running 5 mm inside the edge.” These must run alongside the regulations outlined by Health Canada, which include the specific directions that “Supplier labels must be written in English and French.”
Thus, a producer who does not leave sufficient space on produced bilingual labels to include necessary words in both English as well as French will find themselves caught out.
Specific Pitfalls - Crucial UN Numbers
When it comes to creating the correct labels and placards to accompany your goods, attention will have to be paid to the crucial UN numbers that will be listed on the stickers.
The UN number system is one which specifies the intended use of the materials within any labelled container. It is a method by which better understanding of the purpose of any hazardous exported process is possible just by examining the label. The number is also universally understood, helping to resolve any language issues in the case of the product being exported.
The UN list of applicable numbers stretches from UN 0001 to beyond 3000, and covers a vast array of hazardous substances. The reason for this length is partly attributable to the range of uses that certain numbers can account for.
For example, compressed gas, which counts as a hazardous material, that classed as flammable is classed under a UN number (UN 1954). However, a container of compressed gas that is also toxic and poses an inhalation hazard, will be issued another a separate number (UN 1955). These are the minute differences that are ultimately crucial.
The range of 3,000 plus numbers, and the intricacies of the classifications (often changing number entirely if a certain element is above or below a threshold), means that identifying the correct UN number can be quite the challenge.
By narrowing down the range through pre-analysis of the components, a much smaller set of numbers can be identified for use.
A complete solution like ERA’s SDS Authoring software can automatically carry out this pre-analysis, helping you produce labels with complete confidence in their validity.
Export with Peace of Mind
With the need to secure supply chains uppermost in their minds, producers are always on the lookout for dependable suppliers who can provide what’s needed with no hiccups. The responsibility is even more pronounced should a product need to be shipped overseas.
Manufacturers are therefore obliged to ensure that they have completely locked down their SDS Authoring, with no nasty surprises to come from any overseeing authority.
For more on how ERA can simplify your SDS Authoring and ensure your goods have the labels they need to achieve total compliance (to GHS standards) while on the move, please download the below free PDF guide. For any questions, please feel free to email us via [email protected]