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Training … the necessary evil of TDG – Part 3

Hello everyone. I’m back with the subject of TDG training. In my last blog, we made it clear who has responsibility for a list of the most important elements. We used the sections of the Canadian TDG Regulations for each part stating the implications of the various stakeholders.

Now, in order to fully understand what TDG requires as training, we will discuss what is the normal duration for a TDG training that would provide you with adequate skills and especially training applicable to your responsibilities.

It should be noted that the primary purpose of Part 6 of the TDG (article 6.2) is to ensure that the person has a solid knowledge of all of the topics listed in paragraphs (a) to (m) that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport.

It is important to clarify here that Transport Canada does not define clearly or exactly what training should contain. TDG leaves much room for the interpretation of what constitutes appropriate training, and it remains the responsibility of the company to establish this.

For this reason, we will be discussing a training standard in the industry and it is equally important to believe that if a training facility declares that it is certified by the government or any other departmental entity that this is completely false. Continue Reading…

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Training … the necessary evil of TDG – Part 2

Hello everyone and welcome back! In my last blog, we made it clear who needs to be trained by using the definitions available to us in the Canadian TDG Regulations. Now, let’s try to properly interpret what TDG requires as training. It should be noted that the primary purpose of TDG regulations is the safety of dangerous goods in transport and to achieve an acceptable level of safety, it is, of course, essential that the persons managing dangerous goods in transport have adequate competency. To do this, in Part 6 of the TDG, the Regulations clearly state that any person who handles, offers for transport, or transports dangerous goods must have appropriate training and hold a training certificate. To fully understand what constitutes appropriate training, we must refer to article 6.2 and this article states that a person must have a solid knowledge of all the listed topics as well as the dangerous goods that he is called to handle, transport or offer for transport.

Let’s try to understand these topics that are specified and for each of the points, I will name who is responsible under the TDG.

  • Classification from Part 2 of the TDG. What does classification mean? This consists of defining whether your product meets the characteristics of a dangerous good included in one or more of the 9 hazard classes.
    Person responsible for this Continue Reading…
Taking Part in the BC Provincial CVSA Challenge

In June of this year, I was invited to participate in the Commercial Vehicle Safety and Enforcement (CVSE) Inspectors Commercial Vehicle Safety Alliance (CVSA) Challenge in Surrey, BC, Canada as a judge. I know it doesn’t sound fun but honestly, it was awesome.

The challenge was over a 3-day period and the competitors were seven (7) very qualified CVSE inspectors from all over BC to test their skills and knowledge. The winner from this competition would go on to compete in the North American Inspectors Championship (NAIC) in Pittsburgh, PA, USA. The NAIC includes the best of the best inspectors from Canada, the United States and Mexico competing for the title of Grand Champion. This is some serious stuff and of course, comes with bragging rights!

For the provincial competition, the competitors first have to write a series of qualifying exams, which advances them to the provincial competition. This year’s competition consisted of driver interview, dangerous goods cargo tank inspection, coach bus inspection, and dangerous goods packaging inspection. 

I came in as a judge for the dangerous goods inspections. We provided some of the dangerous goods packaging with “compliance issues”. That was fun for me. I got to make dangerous goods stuff incorrect on purpose for once. 

A few incompliance issues that I added: 

  • put primary and subsidiary hazard labels on opposite sides of the package, 
  • left out the telephone number on Continue Reading…
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Transport Canada Unveils Training Standard Draft

Since Canada first created regulations on the transportation of dangerous goods, those who “handle, offer for transport or transport” dangerous goods must be adequately trained. The question, of course, is what does “adequately” mean? Section 6.2 of the Transportation of Dangerous Goods Regulations (TDGR) says that it means “the person has a sound knowledge of all the topics … that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport,” but that still doesn’t clarify how the employer should verify that the knowledge is “sound.” Now Transport Canada, in consultation with the Canadian General Standards Board (CGSB), has attempted to answer that question.

On August 30, the CGSB put out a draft of a proposed training standard that reflects current international work on “competency-based training.” This standard is not available on a website, but may be obtained by contacting Beata Hart of the CGSB at Beata.Hart@tpsgc-pwgsc.gc.ca for a PDF copy. Comments are due on October 24th, 2019.

The proposed standard would establish two levels of training. First, a “general awareness” segment, that should be approximately 2 hours long, which would cover the basics of how the TDGR works. Then, when employees are familiar with those concepts, they would receive “job specific” training, which would specifically address the job functions they do in that organization.

This would, of Continue Reading…

Transport Canada Launches Video: Responding to Rail-Car Incidents Involving Flammable Liquids

When a train carrying flammable liquids is involved in an incident, first responders are often the first on scene. These types of incidents are not typical for first responders. They require a unique approach. And for that reason, Transport Canada has put out a video on how to respond to rail-car incidents that involve flammable liquids. Below are the factors and steps from the video when dealing with these types of incidents.

Situation:

A Rail Car is involved in an accident and a fire starts on impact.  The rail car is properly placarded with the appropriate class 3 flammable Placard. Below are the factors that can influence the fire as well as steps and tools to utilize during the incident. 

Factors:

Whether it’s Gasoline, Diesel, Ethanol, Crude oil, or bitumen, knowing the properties of each is important to first responders because all can behave differently under spill and fire conditions.  This is where the importance of proper placarding will come into play as first responders can detect exactly what type of flammable substances are on the train based on the UN number.   Below are important factors of flammable substances that would help first responders determine the proper course of action:

Viscosity- Gives an indication on how fast the fire can spread.

Density- Will determine if substance will sink or float if it is near a body of water.

Flashpoint- Tells how easily the Continue Reading…

Transport Canada Updates ERAP Requirements

On May 1, 2019, Transport Canada issued an amendment to Part 7 of the Transportation of Dangerous Goods Regulations (TDG). This part covers the requirements for Emergency Response Assistance Plans, or ERAPs. Details can be found at http://www.gazette.gc.ca/rp-pr/p2/2019/2019-05-01/pdf/g2-15309.pdf.

ERAPs are unique to Canada, and are intended to ensure support for local responders in catastrophic spills, such as the 2013 Lac-Mégantic derailment. Essentially, they require consignor of significant amounts of high-risk dangerous goods to establish a specific protocol, often involving an on-call response team, that can assist local responders in case of a release. Transport Canada must review and approve the plan before the consignor can offer or import affected shipments (although the approval only has to be issued once.)

The amendment has three main goals:

  • clarify ERAP implementation and reporting;
  • enhance emergency preparedness and response; and
  • make housekeeping changes that address smaller issues.

The amendment replaces all the text of Part 7, although unamended requirements will remain the same. Changes also occur in Parts 1, 3 and 8.

Clarifying Implementation of ERAPs

The original requirements of Part 7 didn’t go into any detail as to how an ERAP would be implemented – presumably it would be by emergency responders or by the person with control of the released material, but it’s never been established precisely. The amendment addresses initial notification of an accident requiring ERAP response, and clarifies that the person with the ERAP Continue Reading…

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Training … the necessary evil of TDG

 

Part 1 – The Importance of Training for Regulatory Compliance

Training is an eternal problem that has been going on for so many years. I started my career in 1999, and at that time the regulations did not help us to define our needs for training requirements regarding the Transportation of Dangerous Goods Regulations (TDGR). It is fair to state that in many ways, we are not that much further ahead today.

It is essential to understand which sections of the Transportation of Dangerous Goods Regulations apply to your business to define whether or not your company should have a training program, and determine who in the company should receive training, what needs to be covered, the frequency of training, and how long the training needs to be for maximum effectiveness.

This blog is one of a series that will try to make it as clear as possible and help your process to establish the training needs for your employees.

We start by asking ourselves relevant questions that we will answer with regulatory sections and afterward, I will attempt to explain accurately and guide you to the best solution for your business.

Before I begin, I would like to clarify the term ”Transportation”. When Transport Canada uses the term transportation it is to include any activity that relates to the request for transportation by all modes of transport (contacting a carrier Continue Reading…

Small DG shipment via ground from Canada to USA

One of the most frustrating issues with shipping dangerous goods is finding a carrier that will transport the goods. When a client contacts us for repackaging services, besides the DG information, I always ask if they have arranged a carrier to transport their goods. Most of the time it’s a “no”. Then I get started with what their options are; ground or air.

For shipments going from Canada to the US, believe it or not, it is easier to ship by air than ground. Of course, it does depend on the quantity being shipped and whether the DG is allowed for air transport. It is definitely more cost-effective to send anything via ground than air; however, that is not always true especially for small DG shipments. I have been told that sending a small, e.g., 20 lbs, DG package by air will cost about the same as sending it via ground.

Carriers such as FedEx and Purolator do not haul DG packages from Canada to the US via ground service. They do offer air but not ground. UPS which offers both air and ground does transport certain dangerous goods (just check for limitations on the UN# being shipped on UPS’s website under “UPS Dangerous Goods Acceptance Tool” prior to shipping) from Canada to the US but you must have a DG account set up with them.

What I have Continue Reading…

Don’t Turn Your Vacation into an Embarrassing Headline

Sometimes no matter how many precautions you take, there is no way to stop the inevitable. Football players with helmets designed to protect their brains still get concussions. You cross every “t” and dot every “i” on your federal income tax return and you still get audited. And sometimes even if you follow all of the safety tips for lithium ion batteries in my previous blog, they still can explode. http://blog.thecompliancecenter.com/safety-tips-for-lithium-ion-batteries/

However, by not taking the proper preventative measures in all of the cases listed above, the chances of a negative outcome can be greatly increased. With the travel season looking to pick-up in the coming months and many of us looking to hop on a plane and head out to our idea of paradise, I think it is safe to say that none of us want to end up in a situation like the story below.

What Happened?

Just like any other domestic flight, passengers on a Delta flight in New York City were stowing their carry on items in the overhead storage bins and preparing for take-off for a scheduled departure to Houston, Texas. Suddenly, passengers started to smell something burning, similar to the smell of a camp-fire. It was at that point that passengers started to see smoke in the cabin and begin panicking. The panic was caused by a vape pen that started smoldering Continue Reading…

Know Your Exemptions – the Explosives Exemption (TDG Section 1.31), and Special Provision 125

If your business is like most, you don’t usually deal with shipping explosives in Class 1. However, this class sometimes shows up in places you’d least expect it. While it’s expected to deal with explosives in construction, mining, and the military, you can also find explosives in unexpected products such as toys (caps for cap guns), pyrotechnics for stage and movie productions, and animal tracking collars (some use explosive bolts to free the animal so it doesn’t have to make a permanent fashion statement).

Shipping explosives can be more complex than many other classes of dangerous goods. They are subject to other regulations, such as the Explosives Act, and may require special licensing depending on what type they are. In addition, they are often excluded from some of the common exemptions found in Canada’s Transportation of Dangerous Goods Regulations (TDGR). For example, explosives can’t use the Limited Quantity exemption of section 1.17, or the Excepted Quantity exception found in section 1.17.1. Some low-level explosives may qualify for the 150 Kilogram Gross Mass Exemption in section 1.15 and the 500 Kilogram Gross Mass Exemption in section 1.16, but only if they fall into certain divisions, compatibility groups or UN numbers. You’ll need to read each exemption closely to ensure that your particular explosive will qualify.

To balance things out, TDGR does contain some provisions for shipping small amounts of low-level Continue Reading…