How Globally Harmonized System (GHS) Affects Transportation of Dangerous Goods (TDG)

On February 11, 2015 the Government of Canada published in the Canada Gazette, Part II the Hazardous Products Regulations (HPR), which, in addition to the amendments made to the Hazardous Products Act under the Economic Action Plan 2014 Act, No.1, modified the Workplace Hazardous Materials Information System (WHMIS) 1988 to incorporate the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) for workplace chemicals. This modified WHMIS is referred to as WHMIS 2015.  What does this mean for the Transportation of Dangerous Goods?

In the US, the DOT says that both OSHA HazCom labeling requirements and DOT’s labelling requirements are in effect.  So if you are in Canada shipping to the US you need to be aware of the labelling requirements.  However, there are some special cases:

  • When small containers are put in a larger container for shipping, the inside containers will contain the GHS compliant label and the larger outer container will be marked with the DOT label.
  • When a large means of containment is shipped, ie: a drum or a tote, should have both labels on it.  (there is a provision that the GHS label should not contain the picture, but this is up for revision).

In Canada, since GHS is brand new as of this recent change, there is nothing official from Transport Canada.  However, the general practise is for Transport Canada to mirror what the US does for convenience of transportation between our two countries.  Transport Canada just released a TDG Bulletin on Dangerous Goods Safety Marks in January 2015 which can be found at:

https://www.tc.gc.ca/media/documents/tdg-eng/Bulletin_-_Safety_Marks.pdf

Here are some important dates you should remember:

US Canada
  • June 1, 2015 – deadline for compliance with the modified HazCom standard.
  • December 1, 2015 – there is an exception for distributors who ship product from manufacturers.  This exception ends as of this date.
  • June 1, 2016 employers must have their communications programs updated and workplace labels as necessary.
May 31, 2017 Manufacturers and importers and distributors can comply with old CPR or new HPR.May 31, 2018 Manufacturers and importers must comply with new HPR, Distributors may comply with old CPR or new HPR.

Nov 30, 2018 Manufacturers, importers and distributors must comply with new HPR

Dec 1, 2018 Employers must also comply with new HPR.

Posted in Chemical Transportation, New DOT Regulations, New FMCSA Regulations | Comments Off

Why is the Price of Fuel Dropping?

fuel pricesAfter many years of rising fuel costs many of us are puzzled at the recent and significant drop in both Gasoline and Diesel Fuel prices over the last 5 months and wonder what’s in store for 2015. This article explores what’s driving this and gives an outlook for 2015.

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FMCSA Suspends Enforcement of the 34-hour Restart Provisions that went into Effect July 2013

After 18 months of lost productivity and groaning from the trucking industry about any potential safety benefits of the rule, the FMCSA has suspended enforcement of 49 CFR 395.3 (c) and (d) effective 12:01am December 16, 2014.

What Changed?

As of July 2013 there were many changes to the Hours of Service regulations but one of the most contentious was the 34 hour restart provisions.  A driver can be on duty only 60 hours in every 7 days and only 70 hours in every 8 days.  This was particularly onerous because once your 7 or 8 day period started you were limited on when you could “reset” it.   Under the new rule you could only reset it once per week and only after being on duty for 168 consecutive hours.

The other issue was that the 34 hour restart must include two periods from 1am-5am.  This rule was an issue for many truckers who liked to get an early start say on Sunday night to avoid the early Monday morning traffic.  They couldn’t start their shift till 5am Monday  if they had finished late Friday night, something that’s typical for truckers to do.

Trucking companies need flexibility, and so do the drivers.  Particularly in long-haul shipments where the driver is sent 3-4 days out for a delivery and then must return with another shipment.  If the re-set provision is flexible, the carrier would have the option to deliver and then put the driver off duty and coordinate a shipment home.  However, under the July 2013 regulations, this would not be possible.  The driver would be on the clock until either the next reset opportunity or the 7 or 8 day period expired.  In many cases this tied the hands of load planners.  Many carriers estimated that the average impact of this rule was a 3-4% impact on productivity.  This is huge in the trucking industry when 3-4% is a typical operating ratio!

Now, this particular provision is not going to be enforced while the FMCSA is studying its impact.  The driver can reset their 7 or 8 day periods any time they like.

Implications

This should provide some ease on long-haul capacity.  With greater options about when the driver can reset their work week, they can better coordinate down time with periods when they are not driving, i.e.: waiting for a load to be ready, coordinating a backhaul shipment, maintenance and repairs, etc.

Theoretically, the industry should get some of that 3-4% productivity gains back.  Time will tell.

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Bulk Chemical Transport Solutions: A Case Study

bulk chemical transportationTransporting chemicals by bulk tank truck requires coordinated logistics. It’s not always about the line haul rate. Here’s a case study of how DSN Chemical Transportation solved a clients ongoing problem with raw material delivery.

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Crosborder Truck Trade

transborder truck trade

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2 Things You Have to do Start Doing because of Transportation of Dangerous Goods Changes.

This July 2014 the Government of Canada updated some key section of the Transportation of Dangerous Goods Act.  This article explains two key things you’re going to have to start doing because of the changes.  The Government cited the reason for the updates was to bring Canadian regulations into compliance with international regulations.

Showing Proof of Classification of Dangerous Goods

If you ship dangerous goods, then you will have to keep records to show proof of how you classified the dangerous goods for a five-year period, and make those records available to the Minister of Transport if required.

“A consignor who allows a carrier to take possession of a dangerous goods for transport or who imports dangerous goods into Canada must, during a five-year period that begins on the date that appears on the shipping document, make a proof of classification available to the Minister on reasonable notice given by the Minister.”

Canada Gazette, Part II, on July 2, 2014

Acceptable proof of classification is defined as a test report, a lab report, or a document that explains how the goods were classified.  An MSDS (Material Safety Data Sheet) is also acceptable if it is accompanied by an explanation under the heading “Transportation Information” that describes how the dangerous goods were classified.

At a minimum, proof of classification must include:

  • The date the goods were classified
  • The technical name of the dangerous goods
  • The classification of the goods
  • If applicable, the UN number.

You Must Certify Your Shipping Documents

Beginning on July 15, 2015, not only do you have to have proof of classification, but the shipping documents must be certified by the consignor or an individual acting on behalf of the consignor and set out that person’s name.  You have the option of using the verbage from the US 49 CFR, the ICAO, the IMDG or the UN standard verbage.  In regulation, it’s defined as:

“I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, are properly classified and packaged, have dangerous goods safety marks properly affixed or displayed on them, and are in all respects in proper condition for transport according to the Transportation of Dangerous Goods Regulations.”

Canada Gazette, Part II, on July 2, 2014

To review the complete list of changes, please visit:  SOR/2014-152 June 13, 2014

 

DSN Chemical Transportation specializes in chemical logistics and has been moving dangerous goods within North America since 1988.  If you need help moving your dangerous goods or have questions, please contact us at: www.chemicaltransportation.com

Posted in Best Practises, Chemical Transportation, Industry Information, Shipping to Canada | Comments Off

Hazmat Transport Quick Reference Guide

hazmat quick reverence guide tdg

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7 Lessons Learned about Melon Season

Every year at this time logistics managers have an annual meltdown if they move shipment out of areas affected by “Melon Season”.  Here are seven lessons to help you cope learned in over 25 seasons from DSN Chemical Transportation.

What is Melon Season?

Melon Season is the time of year when produce is ripe and ready for shipment out of key growing areas like the Southeast United States (Georgia, Florida, Mississippi), Texas and Southern California.  From Late May to Late June every year produce is ready for shipment to market.  The growers are willing to pay just about anything to ship their produce to market as the alternative is for it to rot in the fields.  Truckers know this and typically can make up for the rest of the year’s poor revenue in just a few short weeks if they play  their cards right.  For shippers this means lack of availability and skyrocketing rates.

How do you deal with melon season?

1.  Check the Fruit and Vegetable Truck Rate Report

melon season

This is a report published by the US Department of Agriculture and can give you a “heads up” about what areas are experiencing capacity shortages.  Us the report to help you plan.

http://www.ams.usda.gov/mnreports/fvwtrk.pdf

2.  Book Early

This just makes sense.  It happens every year.  Try your best to plan out a few weeks in advance and book your orders with carrier in advance of melon season.  You’re more likely to get a commitment and you won’t have to be looking for capacity at the last minute.

3.  Have a core group of carriers that service the area

If you really want to minimize melon season headaches, then cultivate a core group of carriers all year round.  Pay them fair rates all year (slightly above average) and you will have some leverage to pressure your carriers to get your loads covered before the carrier commits to produce, or other high paying loads this time of year.

4.  If possible, stock up before melon season

It shouldn’t come as a surprise every year!  If it’s possible, stock up in April.  There is a cost/benefit analysis here of the increased cost of freight and service interruptions during melon season vs. the cost of carrying the extra inventory.  If the numbers work, you should try it out.

5.  Be on the phones during melon season

You never know when a load may get cancelled, not be ready, or a customer gets on credit hold.  These situations happen for a carrier everyday and mean that they have a last minute truck available.  If you’re not on the phones talking to carriers every day, all day, then you’ll miss these opportunities.

6.  Consider alternate sources of supply during melon season

If possible, you may have a choice of vendors.  If you can source an alternate either in an area that’s not affected, a local distributor, or off shore, you may have a better chance of maintaining supply at a reasonable cost during this difficult time of year.

7.  BUDGET!

Truck rates during melon season can skyrocket to double and triple what they are during the low season.  Be sure to plan this into your costing model  If you budget a truck a month at $1500 freight per load, you may want to consider budgeting 2-3 loads at $3000, bringing up your annual average cost.  You’re likely going to have to pay it anyway and having a negative freight variance on your reports is something no logistics manager wants!

Bonus tip

Give DSN Chemical Transportation a call.  We’ve been moving freight out of affected areas for over 25 years.  Let’s have a conversation about how we can help you minimize the impact of melon season next year.

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How far on $500 worth of diesel fuel?

How far on $500 worth of fuel

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The Logistics of the Foreign Driver in Transborder Transportation

An overwhelming majority of transborder truck traffic between Canada and the US is done by Canadian drivers.  Knowing this, can help you plan  your logistics around a foreign driver.

I’ve covered in previous articles why Canadian Drivers dominate transborder trucking traffic, as well as, that geography significantly the amount of driving time is done in the US vs. in Canada.  Now, it’s helpful to understand the impact of a Canadian Driver and how this impacts transborder transportation.  Until I started working in the industry, I never really appreciated the human being behind the wheel.  I’d just call and a truck would show up.  I never really thought that the driver may be days away from home and his/her family, or the impact of that on when I chose to ship.

Human Resource Issues

Canadian truck drivers are people who have personal and family issues just like any other worker in any other industry.  As you can imagine, like everyone else, they prefer to be home for the weekend with their families.  This is an important factor to take into account in your logistics planning.  For example, if you are two day’s drive from the Canadian border and are shipping to Canada on a Friday, you’re going to have a hard time getting shipments out.  The drivers prefer to leave your area on a Wednesday or Thursday to enable them to be home for the weekend.  Similarly, if you need to have a delivery on a Monday on a shipment from Canada, you’re going to have a hard time because that would mean the driver would be driving all weekend.

Monday Morning Deliveries in Canada

Many shippers want their deliveries to be delivered “first thing Monday morning”.  This is a big challenge for Canadian trucking companies.  Because drivers prefer to be “off” on the weekends, and freight that arrives at the Canadian terminal on Friday, Saturday and Sunday can’t be delivered ’till Monday, it makes for a big crunch of deliveries on Monday mornings.  P&D drivers have three days worth of freight to deliver on Monday morning.  If you’ve ever noticed that Monday morning deliveries typically are late or run behind, this is why.  If you have a choice, you should plan for deliveries on another day of the week.  You’ll find they’ll be much more predictable.

Border Clearance

Truck drivers get paid by the mile and not by the hour.  They prefer to be moving!  A long delay at the border significantly impacts their paycheck!  Drivers prefer to  clear the border at non-peak times.  Keep this in mind if you are close to the border.  Drivers are going to want to clear at night or early morning.  If you expect a delivery late in the day and are a few hours from the border, the driver is going to spend a significant amount of time waiting to clear.  You can expect this to impact your freight charges.  If you have a choice and can time your deliveries and shipments so that your freight arrives at the border during non-peak times.

Last in the Transborder Series

This is the last article in the transborder transportation series.  We hope you enjoyed a different perspective on how transborder transportation works.  Here at DSN Chemical Transportation, we’ve been moving transborder shipments between Canada and the US for almost 30 years.  If you need help, or a different perspective on how your handling your transborder shipments we’d be happy to give your logistics a second look.  You can contact us at:  www.chemicaltransportation.com

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