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DG (Including Wastes) Shipping Documents/Manifests- “ISHP”

“Harmonization”

July 1 (or June 30, depending on how you count “6 months”), 2015 represents a change in the required order of presenting the shipping description elements on a Canadian dangerous goods (DG) shipping document.

This change was part of the general harmonization (a good, but much-abused word!) with UN and modal regulations that were not specifically highlighted in the title or RIAS for the amendment in Canada Gazette II.*

Since 2005 Canadian consignors have had the option, for domestic ground shipments, to describe the DG on a shipping document in either the “ISHP” (UN#, shipping name, hazard class, PG) or “SHIP” (shipping name, hazard class, UN#, PG) order. No more.

ISHP Mandatory

As of the end of the upcoming 6 month transition period following the Dec. 31 CGII (SOR/2014-306) amendment ONLY the “ISHP” format is compliant as specified in the amended TDGR subsection 3.5(1)(c). This brings ground shipments into line with the international and other modal (i.e. IATA & IMDG) documentation requirements. This is logical, after all, in a world where many languages are used but numerical representations are more universally recognised.

Waste Manifests

A potential glitch in agreement between regulations should be noted by those who ship wastes which may also be classed as dangerous goods, using the Canadian standard “Movement Document/Manifest” required in most regulations.

(Note that, under environmental regulations, wastes can be classed as “hazardous”, “registerable” or “regulated”, requiring a movement document/manifest; even though they may not meet DG classification under TDGR- perhaps a topic for another Blog).

The Ontario Ministry of Environment (ON MoE-which coordinates modifications to, and arranges print runs for, the Canadian standard waste manifest on behalf of all the jurisdictions) has not yet incorporated the ISHP order into the standard form. **

Supplementary TDGR Bill of Lading- or Equivalency Certificate?

Those relying on the standard waste manifest, if required by applicable regulations, may want to ensure they have a supplementary TDGR-compliant shipping document to accompany the waste manifest when the waste is also classified as DG. This will require duplicating the consignor’s certification statement, which is printed on the current manifest form, on the document for TDG purposes.

This could, however, lead to some confusion since the statement on the manifest implies that the description there complies with TDGR- but it doesn’t since it’s in “SHIP” order!

Perhaps implicated parties may want to consult legal counsel, or question the appropriate authorities regarding a “due diligence” defense under Section 40 of the TDG Act.

Alternatively perhaps the ON MoE, or a representative body of Federal/Provincial/Territorial stakeholders could consider applying to Transport Canada for a TDGR Part 14 “equivalency certificate” allowing anyone shipping DG under a required waste manifest form to continue to use the “SHIP” format until the forms are reprinted…

*See my Blog of January 5, 2015

**The consignor’s certification- from the TDGR July 2014 amendment was apparently incorporated into a fairly large print run earlier this year; Ministry sources, at the time of writing, indicate that approval/agreement hasn’t been obtained to further change/reprint the document in time for the TDGR amendment’s effective date.

One Comment

  • Zonia Tierney says:

    Great Article. Thanks for the info. Does anyone know where I can find a blank Waste Manifest form?

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