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Understanding Special Provisions

Understanding special provisions is crucial when navigating regulatory requirements for shipping products. Special provisions can fall into one of four categories:

  1. Additional Requirements: Special provisions may impose extra requirements on shipping your product. For instance, under the Transportation of Dangerous Goods Regulations (TDGR) in Canada, Special Provision 16 mandates including a technical name alongside the proper shipping name on shipping documents and exterior packaging for certain dangerous goods. Similarly, in the United States under 49 CFR, Special Provision 45 dictates temperature control measures for product transportation.
  2. Exemptions/Relief: Some special provisions provide exemptions or relief from regulatory requirements. For instance, in Canada’s TDGR, Special Provision 18 exempts regulations concerning carbon dioxide solids. Similarly, under 49 CFR, Special Provision 66 exempts certain formulations of substances from regulatory oversight.
  3. Non-Applicability: Certain special provisions may not apply to specific circumstances. For example, TDGR’s Special Provision 138 pertains only to batteries intended for disposal or recycling. Similarly, in air transportation regulated by IATA, Special Provision A154 addresses restrictions on damaged or defective lithium batteries. In the US, 49 CFR’s Special Provision A54 permits shipping batteries exceeding allowable quantities with competent authority approval.
  4. Assistance in Classification: Special provisions can aid in correctly classifying products or selecting appropriate entries within regulations. For instance, 49 CFR’s Special Provision 172 specifies that alcohol mixtures containing up to 5% petroleum products fall under a particular classification.

In conclusion, overlooking special provisions can lead to non-compliance and potential issues during shipping. Therefore, it’s essential to thoroughly understand and adhere to these provisions to ensure regulatory compliance and smooth transportation processes.

Do you have questions about shipping dangerous goods? Our team of experts is just a call away for our customers at 855.734.5469 or send us an email, we’re happy to help.

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Elton Woodfine

Elton Woodfine CD (Canadian Decoration) served 22 years as a member of the Canadian Forces. Initially as an Infantry section Commander in the Princess Patricia Canadian Lite Infantry (PPCLI), he served on two peace keeping missions in the former Yugoslavia, and one combat tour in Afghanistan where his unit was awarded the Governor General Unit Citation for actions in combat. He then continued to serve as a member of the Royal Canadian Air Force as a firefighter, where he completed a diploma in Fire Science/ Fire-fighting from Memorial University and Occupational Health and Safety diploma from the University of New Brunswick. Lastly, in his career with the Canadian Forces, he served as a member of the Joint Incident Response Unit (CJIRU) as a Chemical, Biological, Radiological and Nuclear Operator (CBRN Op), part of the Canadian Special Operation Command (CANSOFCOM). Upon his retirement from the Canadian Forces, he took a position as a Life Cycle Management of hazardous materials instructor for the logistical branch of the Department of National Defense and is knowledgeable in NFCC, CEPA 1999, IMHWR, TDGR, ICAO, IATA, IMDG, GHS and OH&S federal regulations.