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Transportation of Dangerous Goods (TDG) 6.2 Infectious Substances
Trainer note: Transport Canada’s TDG Bulletins reference in this presentation are dated March 2018: Shipping Documents Shipping Infectious Substances TDG Training FedEx bulletin “Pointers on Shipping” is available via SASWH’s if needed
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Safety First! Housekeeping: Evacuation route/Muster point Washrooms
Cell phones Administration: Sign in sheet Evaluation SAY: The emergency exits are... You can find the washrooms... Turn off your cell phones during class or set them to vibrate. Please sign the attendance sheet. Trainer note: If using SASWH’s evaluation with pre and post session questions, ask participants to complete the “pre” questions only. Then put the evaluation to the side as the post questions would be answered after the session.
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Course Participation This session will be a hands-on learning experience with lots of interactive participation/discussion. Please ask questions, voice comments and concerns as we go. DO: Create a Park Aide for participant questions. Review questions at end of day. If you can’t answer the question, source it and then follow-up with your participants. SAY: TDG training is one part of your employer’s comprehensive safety program and required by federal legislation. Successful completion of this program includes your active involvement in discussion and learning activities.
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Course Agenda Introductions and Expectations Legislation
Training Considerations Transport Canada’s TDG Ground Regulations Air Regulations: IATA Written Exam and Course Evaluation SAY: There will be a required exam at the end of the session. Mention they can use their resources when completing the exam. This session should take about 3 hours. Trainer note: plus an additional hour if teaching transportation by air.
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Introductions and Expectations
Your name What types of materials are shipped To where and by what means Anything else you’d like to share with respect to your expectations of this course SAY: Please refer to the course material that you have. DO: Review the materials they have, such as: Full copies of applicable legislation Transport Canada’s Bulletin (current versions) FedEx Pointers (current version) employer policy/procedure sample shipping container/s (you’ll use later in training) SAY: If you lose track of where we are, please let me know. If you are facilitating by Telehealth or Webex, say: If you have the exam in front of you please set aside. It will get confusing if you are trying to answer questions while paying attention.
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Rights, Responsibilities & Accountability
Saskatchewan’s Occupational Health & Safety Regulations, 1996, set out the general requirements of the employer and workers. DO: Refer to the Trainer’s Lesson Plan (p 21-23), and speak about accountability and legislation.
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TDG Act & Regulations Published by Transport Canada
Federal laws that stipulate the roles of the worker and the employer with respect to shipping hazardous substances. Layout instructions for safe and legal transport by road, rail, and ship. Both laws (OH&S and Transport Canada’s) hold the employer accountable for provision of training and a safe work environment; and the worker is accountable for following safe work practices and reporting unsafe conditions. Trainer note: Environment Canada and Health Canada play a role in development of the legislation. These are the agencies that provide the instructions on how dangerous goods are transported in Canada.
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Shipping by Ground Legislation Enforcement General Overview
The 9 TDG Classes The Regulations Parts The Regulations Schedules Key Terms & Definitions Roles & Responsibilities in the Transport Chain The Importance of Training Documentation ERAP Reporting Enforcement Summary SAY: These topics are what we will be going through.
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TDG Act and Regulations
Public Safety: The TDG Act & Regulations are meant to ensure that hazards associated with the movement of dangerous goods are minimized by: Use of standardized, tested containers Clear communication of hazards Documented tracking of hazardous shipments Provision of effective emergency response plans SAY: The legislation was set to address accidental release procedures, documentation requirements, safety marks, certification marks and labeling etc. that would govern transportation by ground, air, rail and sea.
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Enforcement Federal inspectors enforce the law. They can:
inspect shipments and training documents issue warnings write tickets There are monetary penalties, creative sentencing options, and jail time for noncompliance. Where violations occur, everyone in the shipping chain can be charged. SAY: An inspector may: search your shipment seize your shipment take samples from your shipment make copies of shipping documents make copies of your training certificates Any person who contravenes or fails to comply with a provision of this Act can be fined $50,000 for the first offense, maximum fine is $100,000 or two (2) years in jail. (Act 33).
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General Overview Personnel must be ‘trained’ and ‘certified’
Substances must be ‘classified’ Containers must be ‘in standard’ Containers must have ‘safety marks’ Documentation must be completed and accompany the shipment Packaging must follow instructions Spills must be reported SAY: The TDG Regulations state everyone involved in the movement of dangerous goods must be trained and has to know what the duties of others in the transport chain are. A carrier could be held responsible for something a consignor did. You must have a hard (paper) copy of documentation to accompany the dangerous goods when in transit. Any leaks, package damage or incorrect information, the shipment has to be stopped until corrected. Trainer note: Refer to 8.4 in the Regulations.
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The 9 TDG Classes Explosives Gases Flammable Liquids
Flammable Substances Oxidizers & Organic Peroxides Toxic & Infectious Substances Radioactive Corrosives Miscellaneous (includes Dry Ice) SAY: There are 9 TDG classes. Our focus today is on Class 6 – Toxic & Infectious Substances Class 9 – Miscellaneous (includes Dry Ice)
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The Regulations by Parts
Ground Regulations Part Topic 1 General (including definitions) & Exceptions 2 Classification 3 Documentation 4 Safety Marks (labels & placards) 5 Means of Containment (packaging) 6 Training 7 Emergency Response 8 Reporting (spills or imminent spills) 9-12 Transport 13-16 Enforcement The Regulations by Parts SAY: The complete TDG Regulations has16 parts listed in the table of contents. Part 2 Classification - refer to TDG Regulations for the UN numbers and the Categories. This information will help in classifying the product that you are shipping which will then help you decide the documents labels, kind of packaging, and if you have the proper training for the item you are shipping. Part 3 Documentation – Transport Canada’s Bulletin on Documentation has this information summarized
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The Regulations by Parts
Ground Regulations Schedule Contents 1 Listing of substances by UN Number 2 Special Provisions 3 Listing of substances by Shipping Name The Regulations by Parts SAY: The TDG Regulations includes 3 Schedules. Schedule 1 is listed by UN number. If you know the UN number for your substance, you can look that up in Schedule 1. UN stands for “United Nations” and are four-digit numbers that identify hazardous materials, and articles (such as explosives, flammable liquids, oxidizers, toxic liquids, etc.) in the framework of international transport. Schedule 2 lists out any special provisions (instructions) associated with a particular substance, such as compatibility and any special handling or storage instructions. Schedule 3 is a listing of all substances in alphabetical order. If you do not know the UN number, you can look up the substance in Schedule 3. Once you find the UN number, you can then go back to Schedule 1 for more detailed information about the substance.
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Schedule 1 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6a Col 6b Col 7 Col 8 Col 9 UN # Shipping Name and Description Class Packing Group/Category Special Provisions Explosive Limit & Limited Quantity Index Excepted Quantities ERAP Index Passenger Carrying Ship Index Passenger carrying Road or rail index UN 2814 INFECTIOUS SUBSTANCE, AFFECTING HUMANS 6.2 Category A 16, 38, 84, 164 EO See SP 84 .05kg or .05l UN 2900 INFECTIOUS SUBSTANCE, AFFECTING ANIMALS only See SP84 UN 3373 BIOLOGICAL SUBSTANCE, CATEGORY B Category B 38, 164, 165 EO 4kg or 4l UN 1845 CARBON DIOXIDE, SOLID; or DRY ICE 9 18 EO 200kg SAY: UN numbers always have to have “UN” in front of the number. UN 2814 and UN 2900 are both Category A. UN 2814 affect humans UN 2900 affects animals (you would see this a lot in vet colleges).
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Schedule 3 Col 1a Col 1b Col 2 Col 3 Col 4 Shipping Name and Description Appellation reglementaire ou technique Primary Class UN Number Marine Pollutant INFECTIOUS SUBSTANCE, AFFECTING HUMANS 6.2 UN 2814 INFECTIOUS SUBSTANCE, AFFECTING ANIMALS only UN 2900 BIOLOGICAL SUBSTANCE, CATEGORY B UN 3373 CARBON DIOXIDE, SOLID 9 UN 1845 SAY: This shows the layout of Schedule 3 – the alphabetical listing.
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Part 1 - Key Terms & Definitions
Classification Culture Shipping Name Biological Product UN Number Neutralized/Inactivated Primary Class Exposure Infectious Substance Means of Containment Category A Safety Marks Category B Exempt Specimens SAY: In the TDG Regulations there are key terms and definitions that you will need to be aware of. We will go through all of these. Trainer note: These definitions can be found in Section 1.4 of the Regulations.
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Classification Classification for infectious substance includes all of: UN number shipping name primary class the infectious substance category DO: Have participants go to Schedule 1. SAY: In order for a substance to be properly classified it must have the following information: UN Number: identified in column 1. Shipping Name: The shipping name is the name of that substance that is found in column 2. This is the name of the substance that must appear on all documentation. Primary Class: The primary class of a substance is found in column 3. Infectious Substance Category: means a substance known to or reasonably believed to contain viable micro-organism that are believed to cause disease in humans and animals. These are listed in Appendix 3 of Part 2. These could be bacteria, viruses, rickettsia, parasites or fungi.
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Classification - General
SAY: This flow sheet helps in determining the classification of the biological/infectious substance. If it’s a dried blood spot/fecal occult blood it can’t be spilled so it’s not a risk. UN 2814 infectious substances affecting humans; can also affect animals. UN 2900 infectious substances affecting animals only – can not be transmitted to humans. An example of exempt specimens include metabolic testing, water samples. Transplant organs have very specific shipping instructions.
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Classification – Patient Specimens
SAY: Refer to Table 1 (page 6) in Transport Canada’s TDG Bulletin - Shipping Infectious Substances for list of the 19 viruses which must always be transported as a Category A, suspected or not. There are more infectious substances than what is in Table 1; however, the 19 viruses listed must be sent as a category A, suspected or not.
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Shipping Name The official name of a substance is found in Schedule 1, Column 2. This is the name that must appear on shipping documents. Not necessarily the technical name, especially for biological materials. Example: Shipping name: Infectious Substance, affecting humans Technical name: Mycobacterium tuberculosis DO: Review the slide
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Shipping Name and UN Numbers
For shipping biological materials, the main shipping names are: Infectious substance affecting humans UN 2814, Category A Infectious substance affecting animals UN 2900, Category A Biological substance, Category B UN 3373 Exempt Specimen Clinical Waste, N.O.S.UN 3291 (BIO) Medical Waste, N.O.S. UN 3291 Regulated Medical Waste, N.O.S. UN 3291 SAY: These are the main shipping names for biological materials that you will be dealing with, along with their corresponding UN numbers.
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Primary Class Infectious Substance
The primary hazard class the substance is assigned to. For infectious substances, the Class is 6.2. For dry ice (a ‘Miscellaneous’ substance), the Class is 9. Infectious Substance A substance known or reasonably believed to contain viable micro-organisms such as bacteria, viruses, rickettsia, parasites, fungi, and other agents such as prions that are known or reasonably believed to cause disease in humans or animals. SAY: The primary class can always be found in Schedule 1, column 3. The primary class takes precedence over any other class. Trainer note: You could refer to Regulation 2.36, as well as Appendix 3, which is located at the back of Section 2.
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Criteria Category A An infectious substance that is being transported in a form such that, when released outside its means of containment and there is physical contact with humans or animals, it is capable of causing permanent disability or life-threatening or fatal disease in humans or animals. Category B Infectious substances that do not meet the criteria for inclusion in Category A. SAY: Some examples of Category A are TB, hantavirus and West Nile. Some examples of Category B are Streptococcus, Staphylococcus, and Salmonella.
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Exempt Specimens Biological materials, collected directly from humans, animals or the environment that are being transported for research, diagnosis, investigational activities or prevention where you have NO REASON TO BELIEVE that the specimen contains an infectious substance. TDG Regulation 1.42. SAY: Examples of exempt specimens are: blood or urine specimens to monitor cholesterol levels, blood glucose levels, hormone levels, Prostate Specific Level (PSA) or other organ function. specimens to determine the presence of drugs or alcohol for insurance or employment purposes pregnancy tests biopsies to detect cancer specimen for antibody detection in humans or animals Trainer note: More information about exempt specimens can be found in 1.42 of the Regulations.
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Exempt Specimens Includes excreta, secrete, blood, blood components, tissues, tissue swabs, and body parts. 3 Types of Exempt Specimens: Exempt Human Specimen Exempt Animal Specimen Biological Product SAY: One of the 3 types of Exempt Specimens listed would be written on the packaging.
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NO!!!! Are All Specimens Exempt?
If you HAVE REASON TO BELIEVE that the specimen contains Class 6.2 micro-organisms, the specimens are classified as Class 6.2 and assigned to either Category A or B. If the specimens are part of routine screening tests, they would be shipped as per section 1.42 of the TDG Regulations. SAY: The lab requisition is where you find clarification regarding the test being conducted. Page 8 of Transport Canada’s Shipping Infectious Substances bulletin has information on “reason to believe”.
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Culture Biological Product
The result of a process by which pathogens in a specimen are intentionally propagated. This definition does not include specimens taken from a human or animal and that are intended to be processed in a laboratory. Biological Product A product derived from living organisms that is used to prevent, treat or diagnose disease in humans or animals or in the development, experimentation or investigation of disease. This includes finished or unfinished products, live vaccines and attenuated vaccines. SAY: Basically, a culture is growth of any microorganism on culture media, this could be liquid or solid. Page 7 of Transport Canada’s Shipping Infectious Substances bulletin for more information on biological products. Biological products reasonably believed to contain pathogens that meets the definition of Category A or B, must be assigned UN2814, UN2900 or UN3373.
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Neutralized/Inactivated
Substances in a form that any pathogens present have been treated such that they no longer pose a health risk. These neutralized/inactivated/fixed materials are not subject to the Regulations unless they meet the criteria for inclusion in another class. For example, fixed samples are not infectious, but the fixative is often flammable. SAY: Can be neutralized/inactivated by chemical or heat. For example, if alcohol was used to neutralize the substance, it would then become a Class 3 flammable liquid. Then two labels are needed – one for Class 6.2 and one for Class 3 flammable liquid.
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Exposure An exposure occurs when an infectious substance is released outside of the protective packaging, resulting in physical contact with humans or animals. SAY: Exposure refers to an uncontrolled manner.
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Means of Containment The shipping container.
Approved containers meet specific standards and have undergone detailed testing (dropping, crushing, piercing) to ensure that they will meet the rigors of shipping without releasing the dangerous goods packed within them. Small = less than 450 L or 500 kg Large = more than 450 L or 500 kg DO: IF POSSIBLE, SHOW DIFFERENT TYPES OF APPROVED PACKAGING USED FOR SHIPPING AS EXAMPLES. SAY: Container will have specification marks to show proper testing of it. Pages of Transport Canada’s Shipping Infectious Substances bulletin has more information. 4G or 4GU markings - the “U” represents the package was tested with fragile primary receptacles; this shows a more stringent testing. This would be a Category A container. Category B containers will have a square on point marking with UN3373.
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Means of Containment NOTE:
Type 1A packaging has been replaced by “Type P620 Packaging” which refers to packing instructions P620 of the UN model recommendations. Type 1B packaging has been replaced by “Type P650 packaging” which refers to packing instructions P650 of the UN model recommendations. Type 1C packaging has been removed from the Canadian General Standards Board standards. See: SAY: There must be enough absorbent material in the packaging to prevent seepage from the package. When you are shipping several containers, or units, you may place them in an over-pack. An over-pack is an appropriate container for multiple items. An over-pack is more commonly used for chemicals or sharps containers. Ensure that the over-pack is labelled correctly.
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Means of Containment SAY:
This is a Category B container and more common than Category A. The main difference to note is that it is not a rigid outer packaging. The secondary receptacle can not be a zip lock bag it has to be a tested plastic fibre envelope. Secondary containers for biological substances Category B UN3373 must be certified by the manufacturer prior to use.
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Safety Marks - Labelling of the Container
The labels and other information that consignors are required to put on the outside of the rigid outer packaging to indicate the presence and type of hazard. Also provides information about the construction and durability of the shipping container. See the Regulations Part 4 or the TDG Bulletin Shipping Infectious Substances for more information. Trainer note: Page Transport Canada’s Shipping Infectious Substances bulletin.
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Safety Marks - Labelling of the Container
Shipments must be labeled prior to transport (Regulation 4.4) Labels must remain legible during transport (Regulation 4.5) Labels must be removed after hazard is removed from the container (Regulation 4.9) Labels must be applied ‘on point’ and be 100 mm x 100 mm (Regulation 4.7) SAY: It is the responsibility of the consignor to label the shipment prior to transport. It is the carriers responsibility to ensure that the labels remain legible during transport. Labels must be removed after the hazard is removed from the container by the person who neutralizes the contents or who unloads or unpacks the container. There is a standard size and placement for labels and placards. UN3373 is exempt from the removal from empty packages, as it is both the hazard label and the manufactures certification mark. Special Provision 165 allows us to keep UN3373 on the package even if empty. However, it is a good idea to indicate the package is empty.
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Safety Marks - Labelling of the Container
The container labelling requirements vary with the classification of the shipment but always includes the shipping name, UN Number, container specification marks and address of the consignor. DO: Review the slide.
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24- Hour Telephone Number
Safety Marks - Labels Category A Category B Exempt Specimen If you are shipping a Cat. A, you must label the pack with an infectious substance label. This label is illustrated in the Appendix to Part 4 of the TDG Regulations. When shipping a Category B infectious substance, section 1.39 and say you must label the package with the “Category B mark” illustrated in the appendix to Part 4. No label required. The text on the (bilingual) label is: INFECTIOUS IN CASE OF DAMAGE OR LEAKAGE IMMEDIATELY NOTIFY LOCAL AUTHORITIES AND CANUTEC The text on the label is: UN3373 24- Hour Telephone Number Extra marking requirements: The shipping name and UN number UN2814 – Infectious Substance, Affecting Humans, or UN2900 – Infectious Substance, Affecting Animals The shipping name Shipping name is required if you are using the exemption under section 1.39 Exempt Human Specimen Exempt Animal Specimen SAY: For a Category A, have CANUTEC’s phone number or an approved ERAP phone number. For Category B you need to have a 24 hour telephone number. When using the CANUTEC number you must first register the shipment with them prior to shipment of the dangerous good.
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Safety Marks - Placards
The placard that carriers or anyone loading the dangerous goods into a means of transport are required to display on the vehicle. Placards are required when the: gross mass of infectious substances >500 kg shipment requires an ERAP (see Transport Canada’s Regulations, Subsection 7.1(7)) See the Regulations Part 4 or the TDG Bulletin Shipping Infectious Substances for more information. SAY: An example would be hospital waste contractors. These vehicles would need placards. Another example would be placards seen on the side of a semi for anhydrous ammonia containers. OPTIONAL: Ask: What else would you see placards on shipments? Possible responses: oxygen, propene, fuel trucks
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Roles & Responsibilities in the Transport Chain
The TDG Regulations define the roles and responsibilities of everyone in the transport chain: Employer/Supervisor Consignor Carrier Consignee SAY: The supervisor would be acting on behalf of the employer. There may also be various handlers such as anyone working in a loading bay. Handlers are required to be trained on packing and handling, and must inform the supervisor if the container or label is compromised in any way. If you import any hazardous goods from another country you become the consignor and are legally responsible.
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Roles & Responsibilities - Employer
The TDG Regulations Part 6.1 Training Certificate Requirements The TDG Regulations Part 6.3 Issuance & Contents of a Training Certificate The TDG Regulations Part 6.5 Keeping Proof of Training The TDG Regulations Part 6.7 Showing Proof of Training DO: Refer to the full copy of legislation for information to share on each of the Regulations noted. This is not included in the excerpt package SASWH utilizes in training. Transport Canada’s TDG Training bulletin is a good resource on training requirements.
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Consignor (Shipper) A person who: is named in a shipping document
will import dangerous goods has possession of dangerous goods immediately before they are in transport The consigner must: be adequately trained prepare and give to the carrier a shipping document package and label the dangerous goods as per the Regulations provide his or her training certificate to an inspector immediately on request SAY: The consignor is the person who prepares the shipment. Section 4.4 of the Regulations state the shipper is responsible to: classify the dangerous goods ensure it is documented correctly ensure it is packaged in certified packages ensure package has the correct markings ensure the package is labelled with the appropriate labels report any loss
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Roles - Carrier A person who has possession of dangerous goods immediately before they are in transport. Example: courier, waste disposal company Shipping dangerous goods by Canada Post is illegal. SAY: Canada Post’s website offers a list of what can and cannot be shipped. Part 6 of the Canada Post Non-Mailable Matter states: Dangerous Goods, as defined by the Transportation of Dangerous Goods (TDGR), are non-mailable matter. Canada Post will not accept packages that contain dangerous goods or that display dangerous goods symbols, except for lithium batteries described in Section 2.2.9 Batteries of ABCs of Mailing. Canada Post must assume that all markings and labels on a package identify the actual contents. If any evidence of former hazardous material contents is visible, the package will not be accepted.
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Responsibilities - Carrier
The carrier must: not take possession of a dangerous good unless it is packaged and labelled in accordance with Regulations. refuse possession of a dangerous goods where the accompanying shipping document is incorrect or incomplete or the packaging and labeling is incorrect. report any loss of product while they are in possession of the shipment. provide a copy of the shipping document upon delivery. keep copies of shipping documentation for inspection by federal inspectors for 2 years. DO: Review the slide. SAY: When changes are required to the safety marks for any reason, the carrier is responsible to make the changes while the dangerous goods are in transport. Once the goods are removed from the vehicle, the carrier would be responsible to remove any placards.
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Roles – Consignee (Receiver)
A person who receives dangerous goods. The consignee has a duty to report damaged or lost shipments. The consignee has a right to refuse those shipments. DO: Review the slide.
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Part 6 - The Importance of Training
The TDG Regulations Part 6: A person who handles, offers for transport or transports dangerous goods must Be adequately trained and hold a training certificate in accordance with this Part; or Perform those activities in the presence and under the direct supervision of a person who is adequately trained and who holds a certificate in accordance with this Part. (2) An employer must not direct or allow an employee to handle, offer for transport or transport dangerous goods unless the above (1) conditions are met. DO: Refer to Transport Canada’s TDG Training bulletin.
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Training Topics as per the Certificate
Classification Shipping Names Use of Schedules 1, 2, & 3 Shipping Documents Safety Marks Means of Containment Emergency Response Assistance Plans Accidental Release Reporting Requirements Safe Handling & Transportations Practices Reasonable Emergency Measures Requirements set out in ICAO Technical Instructions SAY: These are the training topics on the certificate. The employer determines the level of training an employee will receive and it is based on what pertains to that employee’s job.
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Part 3 - Documentation A shipping document is the document that contains the required information about the dangerous goods being handled, offered for transport or transported. While en route, a paper copy must accompany the shipment. The document is prepared by the consignor, and copies must be kept by the consignor and carrier for at least 2 years. Minimum information: Consignor’s name and address Date of shipment Classification of goods SAY: You may need more information on the document, depending on what is being shipped. All the information the consignee or consignor would need must be on the document. The carrier/driver must keep the documentation within arms reach, for example in the pouch on the drivers side door.
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Part 3 - Documentation Minimum information required on a shipping document: Consignor’s name and address Date of shipment UN Number Shipping name Primary class and subsidiary class Packing group or category any extra information required by Special Provisions the quantity in metric measurement 24 hour contact information the consignor’s certification DO: Review the slide.
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Documentation Note: the yellow spaces are required information. Other space reflect common practice. SAY: Transport Canada’s TDG Bulletin – Shipping Documents (page 11 and 12) has samples of shipping documents.
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Item Category A Category B Waste Classification Packaging Selection
Infectious Substance, affecting animals Biological Substance, Category B UN3291 if waste contains Category B Packaging Selection Type Cat B, if permitted in Section 5.16 Type Cat A or B Documentation Yes No, if meeting the conditions of Exemption 1.39. Yes, unless meeting the conditions of Exemption 1.39. Labels & Markings UN Number & Shipping name. Category B mark & 24 hr number Yes. Class 6.2 Label. Placards Yes, if: ERAP is required 7.1(7) Over 500 kg Training SAY: This chart sets out what you need for each category. For Category A you must have documentation, and workers must be trained for all categories. For an example “Waste” would be sharps containers. Trainer note: This chart is in Transport Canada’s TDG Bulletin – Shipping Infectious Substances (page 21).
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Emergency Response Assistance Plan (ERAP)
Required for substances and/or quantities that are considered beyond the risk capabilities of local first responders (usually the fire department). Regulation 7.1(7): A person who offers for transport or imports any quantity of the following dangerous goods, included in Class 6.2, Infectious Substances, or any substance that exhibits characteristics similar to these dangerous goods, must have an approved ERAP. SAY: ERAP, or Emergency Response Assistance Plan, is a plan that must be registered and approved by Transport Canada in advance and the plan must be activated prior to the movement of the shipment. It is a plan that describes what is to be done in the event of an accident involving certain higher risk dangerous goods, in our case, the Risk Group 4 viruses specified in the next slide. These Risk Group 4 viruses are classified as Category A but they require special expertise and response equipment to respond to an incident or spill. The plan is intended to assist local emergency responders by providing them with technical expertise and specially trained and equipped emergency response personnel at the scene of an incident. Activation of an ERAP includes the plan number documented on the TDG Shipping Document and includes a 24 hour contact phone number provided in the plan. Trainer note: This is Transport Canada’s page for ERAP application. Transport Canada reviews and approves all plans.
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Class 6.2 Substances Requiring an ERAP
Crimean-Congo Hemorrhagic Fever Virus Marburg Virus Nipah Virus Ebola Virus Omsk Hemorrhagic Fever Virus Foot and Mouth Virus Cultures Russian Spring-Summer Encephalitis Virus Guanarito Virus Hendra Virus Sabia Virus Herpes B Virus Variola (Smallpox Virus) Junin VirusKyasanur Forest Virus and recently added Tick bourne encephalitis Lassa Virus Machupo Virus SAY: All of these viruses listed here, even if suspected, require an ERAP. It is only this list of Risk Group 4 viruses (RG4 is the most dangerous because they are highly infectious, cause serious disease and there is no cure as per the Human Pathogens and Toxins Act) classified under 6.2 that require an ERAP. There are many other viruses, bacteria and fungi classified as Category A that do not need an ERAP. It is a Category A in culture form but doesn’t need an ERAP! The legislation changed summer of 2019, any substance found in Schedule 4: Risk Group 4 Human Pathogens. Tick bourne encephalitis has made the list. This is normally found in Europe. But due to travel, we are seeing some requests coming through for this. If so, alert your manager and supervisor for further instructions. Trainer note: This is the link to show Tick Bourne encephalitis has made this list
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Reporting A release (or imminent release) of any amount of Class 6.2 material is immediately reportable by whomever has possession of the dangerous goods at the time of the release. The incident must be reported to all of the following: Provincial authorities (Saskatchewan ) or local police The employer The consignor The owner of the road vehicle, if applicable CANUTEC if transporting by ground, rail, ship or air. SAY: For Category A, the emergency response contact would be CANUTEC, and according to special provision 84, must have an ERAP. The phone number for CANUTEC ( toll free or ) must be displayed on the shipment container. The ERAP must be applied for and approved before the shipment of the dangerous goods begins. For a Category B, a 24 hour phone number must be used and displayed on the container. This 24 hour phone number is a contact number of a person who must answer the call in an emergency and has knowledge of the dangerous goods being shipped. For Category B packages, you can still use CANUTEC. CANUTEC provides emergency response assistance and all spills must be reported to CANUTEC for any amount of class 6.2. To use them as an emergency contact, you must register first at
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Reporting Emergency report by phone.
The immediate report - includes the company name and address, shipping name of the spilled substance, quantity, description of the incident, any injuries and any evacuations that resulted. The 30 day report only if release resulted in death or evacuations - a summary of the incident must be submitted to Transport Canada. The information provided in the report is used to evaluate the effectiveness of the regulations and may lead to regulatory change. SAY: Technically there are 3 reports - only 2 are physical/documented. Trainer notes: The information required for the immediate report can be found in section 8.5 of the Regulations. The information required for the 30 day follow up can be found in section 8.6 of the Regulations. Section 8.2 of the Regulations has a table which lists the quantities at which the reporting process must be initiated. Class 6.2 Category A or B, the quantity is “Any Amount”.
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SAY: This flow chart is from Transport Canada. When an incident happens, you can follow this algorithm to assist you with the reporting process.
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SAY: This flow chart is also from Transport Canada.
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Summary To protect public health, there is an international agreement on shipping practices for dangerous goods. In Canada, these practices are outlined in the TDG Act & Regulations. All shipments must be classified, packaged, labelled and documented as per Regulations. Each person in the shipping chain has responsibilities and required documented training. Failure to meet responsibilities can result in penalties. SAY: To Protect Yourself, You Can: Ask for training Use the training that you’ve been provided Keep yourself current Practice - perfect practice makes perfect Know your employer’s current policy and procedures
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Exam Evaluation Certificate Thank you for attending! Be safe.
DO: Exam: Have participants complete the required exam if you’re only teaching Ground. There is one question on the exam that pertains to air – you can have participants disregard that question. Evaluation: Ask participants to complete the “after the session” and other questions on the evaluation and hand in before leaving. The employer will need a copy of the sign in sheet in order to document and record training. Certificate: Complete the back of each certificate, then hand out to each person who successfully completed the course. Certificates will need to be signed by the participant and their employer. If you’re teaching TDG 6.2 by Air, continue – the exam and balance of evaluation can be completed at the end of the training session.
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Air Regulations for Shipping Infectious Substances
The Following Slides Pertain to Teaching Air Regulations for Shipping Infectious Substances
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IATA & ICAO The organizations who publish the rules for transporting dangerous goods by air. IATA International Air Transport Association Trade association of airlines Controls 84% of air traffic ICAO International Civil Aviation Organization Specialized United Nations Agency that works with countries, industry and aviation agencies to develop international standards and practices for safe air transport. SAY: The IATA is the Regulations for the day to day functional level. This training today references IATA. The IATA Regulations are very clear and easy to follow. The ICAO set the technical requirements. The other 16% that is not controlled by the IATA you wouldn’t be shipping.
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Shipping by Air IATA Regulations Limitations & Variations
Identification Section IATA Classifications Means of Containment Packing Instructions Safety Marks Documentation for Air Special Provisions Handling Reporting Summary DO: Review the slide.
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The IATA Regulations Govern air transport.
Based on the ICAO Technical Instructions for the Safe Transport of Goods by Air. Provided by IATA, who layers their own requirements on top of the ICAO requirements. Divided into: 10 Sections Appendices A to H Index SAY: The IATA regulations are set the same as they are in ground. Same concept as ground, the regulations are divided up into 10 sections.
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The IATA Regulations Section Topic Highlights 1 Applicability
Responsibilities 2 Limitations State & Operator Variations 3 Classification Cat. A List; Exemptions 4 Identification Schedule 1 & 3 Equivalents 5 Packing Packaging Instructions 6 Packaging Specifications 7 Marking & Labelling 8 Documentation Shipper Declaration 9 Handling Package Acceptance 10 Radioactive Materials Appendices A to H Glossary & Country Info. Index SAY: The IATA is the same concepts as ground but they use different names. Section 2- Limitations: depending on your location and operator Section 5- Packing: gives you step by step specific instructions Section 6- Packaging: gives information on they tested the packaging Section 7- Marking and Labelling: regulations are specific to air, they can’t put placards on passenger planes.
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Limitations & Variations
Forbidden & Restricted Items see P Table 2.3A State Variations Extra restrictions set by national governments that apply to dangerous goods going to, from or through their country. Each country has a 3 letter code ending with ‘G’ for government; Canada (CAG), the USA (USG). Operator Variations Extra restrictions set by individual airlines for dangerous goods. Each airline has a 2 letter code; Air Canada (AC), Fedex (FX), UPS (5X) SAY: The IATA Regulations sets the standards of what goes through the countries. There can still be variations from state to state that would include extra restrictions.
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Passenger and Cargo Aircraft
Identification Section Size limit Table 2.6.A Passenger and Cargo Aircraft Cargo Aircraft Only Ltd Qty UN # Shipping Name and Description Class Hazard Label (s) Packing Group EQ see 2.6 Pkg Inst Max Net Qty/Pkg S.P. see 4.4 ERG Code A B C D E F G H I J K L M N UN 2814 INFECTIOUS SUBSTANCE, AFFECTING HUMANS (liquid) 6.2 Infectious substance E0 Forbidden 620 50 mL 4L A A140 11Y INFECTIOUS SUBSTANCE, AFFECTING HUMANS (solid) 50 g 4 kg UN 2900 INFECTIOUS SUBSTANCE, AFFECTING ANIMALS only (liquid) INFECTIOUS SUBSTANCE, AFFECTING ANIMALS only (solid) UN 3373 BIOLOGICAL SUBSTANCE, CATEGORY B see 650 11L UN 1845 CARBON DIOXIDE, SOLID; or DRY ICE 9 Miscellaneous 954 200 kg A48 A151 A805 9L SAY: Identification is similar to the Schedules in Transport Canada’s Regulations. Section 4-Identification: List of dangerous goods page in IATA. Shows the UN number, shipping name and description, class, hazard label, if it is allowed on passenger aircraft or not, quantity allowed, packaging instructions and any special provisions needed. Qty/pkg differentiates between solids and liquids as you can see under the size limit. EQ see 2.6-Dangerous Goods in excepted quantities - infectious substance is not permitted as excepted quantity (E0). ERG code-Emergency Response Guidance/Drill Code for Aircraft incidents involving dangerous goods. CANUTEC as an example. Section 5.1 Yellow pages Section 4.4
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IATA Classification of Biological Materials
Section Division 6.2 Infectious Substances Definitions for Infectious Substance, Biological Product, Cultures, Patient Specimen, and Medical or Clinical Wastes similar to definitions as in TDG Ground Regulations SAY: When classifying biological materials, follow the same guidelines as for ground.
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IATA Classification of Biological Materials
Section Category A UN 2814 (Infectious substance, affecting humans) UN 2900 (Infectious substance, affecting animals only) Infectious substance in a form such that exposure risks permanent disability or fatal disease in otherwise healthy humans or animals. Assignment to UN 2814 or UN 2900 must be based on the known medical history and symptoms of the source human or animal, endemic local conditions or professional judgement concerning the source patient. Indicative examples provided in Table 3.6.D. Not exhaustive. DO: Refer to applicable Regulation for the table.
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IATA Classification of Biological Materials
Section Category B UN 3373 (Biological substance, Category B) Infectious substance in a form such that exposure does not risk permanent disability or fatal disease in otherwise healthy humans or animals. In other words… infectious substances that do not meet the criteria to be considered Category A! Includes Patient Specimens that do not meet the requirements of : DO: Refer to applicable Regulation for details.
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IATA Classification of Biological Materials
Section Medical or Clinical Wastes UN 3291 Biomedical waste, n.o.s. Clinical waste, n.o.s. Medical waste, n.o.s. Regulated medical waste, n.o.s. Medical or clinical wastes containing Category B infectious substances must be assigned to UN 3291. Medical or clinical wastes containing Category A infectious substances must be assigned to UN 2814 or UN 2900. SAY: This is very similar to what you learned in TDG by ground.
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IATA Classification of Biological Materials
Fixed tissues? Inactivated pathogens? Decontaminated clinical wastes or medical equipment? These are not included in Division 6.2, but may meet the criteria for inclusion in another Class or Division if the consignment contains another hazardous substance: corrosive disinfectants, flammable fixatives, etc. SAY: If you are using a fixative, classify according to the hazard of that fixative.
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Means of Containment Section 6 - Packaging Specifications
6.5 Packaging for Infectious Substances of Category A Required markings (see Table 6.5.A): the United Nations packaging symbol the code designating the type of packaging (6.0.3) the text “Class 6.2” the last 2 digits of the year of manufacture the State authorizing the allocation of the mark the name or identification mark of the manufacturer for packaging meeting the requirements of , a U must follow the other markings DO: Review the slide.
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Means of Containment I want my shipping container back, what does the receiver have to do? Before an empty packaging is returned to the consignor, or sent elsewhere, it must be disinfected or sterilized to nullify any hazard and any label or marking indicating that it contained an infectious substance must be removed. DO: Review the slide.
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Packing Instructions for Air
Section 5 - Packing Instructions Specific to each dangerous good, listed in column I of the Identification Table in Section 4. For: UN 2814 & UN 2900 follow Packing Instruction 620 UN 3373 follow Packing Instruction 650 UN 3291 follow Packing Instruction 622 UN 1845 follow Packing instructions 954 DO: Review the slide.
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Packing Instructions for Air
UN2814 & UN2900: Packing Instruction 620 Requirements: Inner packaging comprised of a leak-proof primary receptacle, leak-proof secondary packaging, and absorbent material sufficient to absorb the entire contents of the primary receptacle Itemized list of contents between the secondary packaging and the outer packaging Rigid outer packaging not less that 100 mm in any dimension SAY: Follow the packing instructions.
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Packing Instructions for Air
UN2814 & UN2900: Packing Instruction 620 Requirements: (d) The primary receptacle or the secondary packaging must be able to withstand, without leakage, an internal pressure of 95 kPa and temperature range of -40C to 55C (e) Inner packagings must not be consolidated with other, unrelated types of goods (f) Less than 30 mL of Class 3, 8 or 9 may be packed in each primary receptacle provided it is below the Excepted Quantity for that substance SAY: You may pack your specimens in preservatives that may fall under class 3, 8 or 9. Example of class 3 - Alcohol Example of class 8 - Phenyl or Phenol Example of class 9 - Dry ice
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Packing Instructions for Air
UN2814 & UN2900: Packing Instruction 620 Additional Requirements: When the infectious substances are unknown but suspected of meeting the requirements for inclusion in Category A (a patient specimen, for example) the words “Suspected Category A Infectious Substance” must be shown in parentheses following the proper shipping name on the itemized list of contents inside the outer packaging. All packages must be marked durably and legibly on the outside with the name and phone number of the person responsible. SAY: Diagnostic testing for specific diseases would be an example of a specimen that may be ”Suspected Category A Infectious Substance”.
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Packing Instructions for Air
UN2814 & UN2900: Packing Instruction 620 Temperature-dependent requirements: Ambient or higher temperature: primary receptacles must be glass, metal or plastic. Must be made leak-proof by crimping, heat seal, skirted stopper, paraffin sealing tape or locking closure. Refrigerated or frozen: refrigerant must be placed around secondary packaging or in an overpack. For wet ice, the over pack must be leak-proof. For dry ice, the packaging must permit the release of Carbon dioxide. Liquid Nitrogen: primary receptacles must be plastic capable of withstanding low temperatures. Follow provisions for N2 DO: Review the slide.
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Packing Instructions for Air
UN3373: Packing Instruction 650 Requirements: Inner packagings comprised of a leak-proof primary receptacle of no more than 1L, leak-proof secondary packaging, and absorbent material sufficient to absorb the entire contents of the primary receptacle Itemized list of contents between the secondary packaging and the outer packaging Rigid outer packaging not less that 100 mm in any dimension or holding more than 4L DO: Review the slide.
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Packing Instructions for Air
UN3373: Packing Instruction 650 Requirements: (d) The primary receptacle or the secondary packaging must be able to withstand, without leakage, an internal pressure of 95 kPa and temperature range of -40C to 55C (e) Less than 30 mL of Class 3, 8 or 9 may be packed in each primary receptacle provided it is below the Excepted Quantity for that substance DO: Review the slide.
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Packing Instructions for Air
UN3373: Packing Instruction 650 Temperature-dependent requirements: Refrigerated or frozen: refrigerant must be placed around secondary packaging or in an overpack. For wet ice, the over pack must be leak-proof. For dry ice, the packaging must permit the release of Carbon dioxide. Liquid Nitrogen: primary receptacles must be plastic capable of withstanding low temperatures. Follow provisions for nitrogen (N2). DO: Review the slide.
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Packing Instructions for Air
UN3291: Packing Instruction 622 Outlines container specifications (Packing Group II performance Standards) for shipping medical waste Packaging must be sufficient to contain liquids present, with absorbent able to absorb the contents Packaging intended to contain sharp objects must be puncture resistant and retain liquids under performance test conditions for the packaging SAY: Packing groups are relative to the degree of danger. Refer to IATA Regulation Packing Groups: Packing Group I – substances presenting high danger Packing Group II – substances presenting medium danger Parking Group III – substances presenting low danger UN 3291 – Clinical Waste - example: Sharps
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Safety Marks for Air UN3373: Packing Instruction 650
On the outside of the rigid outer container: the name and address of the shipper and of the consignee must be on each package the name and phone number of a person responsible must be provided on the air waybill or on the package “BIOLOGICAL SUBSTANCE, CATEGORY B” the classification must be in accordance with to 3.6.2 the incident report requirements in must be met the inspection for damage or leakage requirements in and 9.4.2 SAY: Safety Marks are the same for air and ground.
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Safety Marks for Air UN2814 & UN2900: Packing Instruction 620
On the outside of the rigid outer container: the proper shipping name and UN Number the technical name and NET QUANTITY of the substance the name and address of the shipper and of the consignee must be on each package the name and phone number of a person responsible must be provided on the air waybill or on the package labelling for any secondary hazards contained within the package (e.g., dry ice). SAY: The technical name goes on the shippers declaration, not on the package. This is for biosecurity reasons.
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Safety Marks for Air Other Safety Marks: Handling Labels (7.4)
Cargo Aircraft Only (7.4.2) Package Orientation (7.4.4) Labeling for any secondary hazards contained within the package (e.g., Class 9 Miscellaneous Dangerous Goods UN Dry Ice) SAY: If the package needs to stay in an upright position, there are orientation stickers (e.g., “this way up”) available.
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Documentation for Air Section 8.0.1
A “Shipper’s Declaration for Dangerous Goods” must be completed by the shipper/consignor for each consignment of dangerous goods, except as provided in SAY: An electronic e-file format document is available online (Transport Canada’s website).
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Documentation for Air Section 8.0.1.2
The following articles or substances do not require a “Shipper’s Declaration for Dangerous Goods”: Dangerous goods in excepted quantities; UN3373, Biological Substance, Category B (see Packing Instruction 650) UN1845, Carbon dioxide, solid (Dry Ice) when used as a refrigerant for other than dangerous goods (see Packing Instruction 954(c)) SAY: Exempt specimen on dry ice by air does not need a “Shipper’s Declaration for Dangerous Goods”, but remember it does need a Safey Mark.
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Documentation for Air “Shipper’s Declaration for Dangerous Goods”:
Required for UN2814 and UN2900 Must be printed in red ink (or red & black ink) on white paper Must be on 11x17 or 11x8.5 inch paper If the consignment contains both dangerous and non-dangerous goods, the dangerous goods must be listed first The number of copies required is set by the carrier Proper shipping names must be provided, and where shipping names are followed by a star, technical names must be provided (UN2814, UN2900) Must be signed by consignor/shipper DO: Review the slide.
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Shipper’s Declaration for Dangerous Goods
Required only for Category A shipments! SAY: This differs a bit from the ground declaration: “Air Waybill No.” is required while ground indicates “Shipping Document #”. Includes a “WARNING” regarding failure to comply. For the sections titled “TRANSPORT DETAILS” and “Shipment type”, you would cross out what is NOT applicable. For example: if the specimen is radioactive, you would cross out “non-radioactive”.
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Shipping on Dry Ice by Air
UN Carbon dioxide, solid Requirements: the NET WEIGHT of dry ice contained in each package must be shown in metric (kg) measurements on the outside of the package the package must allow for the venting of carbon dioxide SAY: Remember, when shipping Category A substances and using dry ice as the refrigerant, it needs to be recorded on the shippers declaration.
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IATA Special Provisions for Biological Materials
For UN2814, UN2900 A81: The quantity limits shown in Columns J and L do not apply to body parts, organs or whole bodies. A140: Notwithstanding the “ “ against the proper shipping name in Column B, the technical names need not be shown on the package. When the infectious materials are unknown but suspected to meet the criteria for inclusion in Category A, the words “Suspected Category A infectious substance” must be shown in parentheses, following the proper shipping name on the Shipper’s Declaration, but not on the outer packaging. DO: Review the slide.
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IATA Special Provisions for Dry Ice
For UN1845 A48: Packaging tests are not considered necessary. A151: When dry ice is used as a refrigerant for other than dangerous goods loaded in a unit load device or other type of pallet, the quantity limits per package shown in Columns J and L in Section 4.2 do not apply. In such case, the unit load device or other types of pallet must be identified to the operator and must allow the venting of Carbon dioxide gas to prevent a dangerous build up of pressure. A805: Carbon dioxide, solid may be placed directly within an overpack that meets PI954 to cool other dangerous goods. DO: Review the slide.
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Handling of Class 6.2 9.4.1 Inspection for Damage or Leakage
9.4.2 Infectious Substances If damage or leakage of a Class 6.2 package is found, the handler must: avoid or minimize handling the package inspect adjacent packages for contamination and put aside any that may have been contaminated inform the appropriate health authority and provide information on any other countries of transit where people may have been exposed notify the shipper and/or the consignee SAY: Before handling a package, verify that it is not damaged.
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Reporting Section Dangerous Goods Accidents & Incidents (excerpt) An operator must report dangerous goods accidents or incidents to the appropriate authorities…in accordance with the reporting requirements of those authorities. CAG-19 (IATA’s code for Canada): in Canada reporting must be done in accordance with the requirements found in Part 8 - Accidental Release and Imminent Accidental Release of the Canadian TDG Regulations. DO: Review the slide.
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Reporting IATA 9.6 (excerpt) Any type of occurrence must be reported:
Accident: serious injury sustained by a person Incident: injury to a person, property or environmental damage, fire breakage, spillage, leakage of fluid or radiation that seriously jeopardises the aircraft or its occupants When undeclared or mis-declared dangerous goods are discovered Initial report should be dispatched within 72 hours, written report sent as soon as possible to the competent authority. SAY: Additional requirements and explanation are listed in the legislation. IATA has a sample report in the legislation that could be used.
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Summary The IATA Dangerous Goods Regulations set out the rules for transporting dangerous goods by air. IATA Classification of biological materials is similar as for Ground - both follow international conventions. Packaging and Documentation requirements are specific to each classification. Handlers must inspect packages for damage/leakage. Damaged/leaking packages must be reported. SAY: To Protect Yourself, You Can: Ask for training Use the training that you’ve been provided Keep yourself current Practice - perfect practice makes perfect Know your employer’s current policy and procedures …
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Exam Evaluation Certificate Thank you for attending! Be safe.
DO: Exam: Have participants complete the required exam if you’re only teaching Ground. There is one question on the exam that pertains to air – you can have participants disregard that question. Evaluation: Ask participants to complete the “after the session” and other questions on the evaluation and hand in before leaving. The employer will need a copy of the sign in sheet in order to document and record training. Certificate: Complete the back of each certificate, then hand out to each person who successfully completed the course. Certificates will need to be signed by the participant and their employer.
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