Transport Canada published in Canada Gazette, Part I, the amendment titled “Part 4 Dangerous Goods Safety Marks”. Notable changes include:
- introduction of overpacks
- modifications to the use of the DANGER placard
- introduction of new safety marks (3)
- new proposal for placarding large means of containment
Let’s start with the overpacks. Currently under TDG, overpacks are not recognized although they are being used. And this is causing enforcement issues. TC considers an overpack to be a large means of containment. The definition for overpacks will be added to section 1.4 of TDG. Safety marks for overpacks is covered in section 4.10.1. As part of this section, when the overpack has a capacity ≥ 1.8 m3, then safety marks must appear on two opposite sides of the overpack.
The new safety marks to be introduced are:
All the safety marks are in the UN Model Regulations, ICAO Technical Instructions, IMDG Code and 49 CFR.
The requirements for placards will undergo a major change. The table in TDG section 4.15 is replaced. Placards will be required on both ends and sides of a large means of containment. The subsidiary placard requirements do not change. UN numbers on a placard or orange panel will be required when an ERAP is required, or the dangerous goods are liquids or gases in bulk. IBCs (intermediate bulk containers) will be permitted to only have 2 placards with UN number on opposite sides, or a label and UN number on each side. This will remove the need for equivalency certificates. However, placards with UN numbers will be needed on the outside of the truck.
The use of the DANGER placard changes as well. The DANGER placard can be displayed in place of hazard class placards when there are 2 or more classes and there are 2 or more small means of containment. The current restrictions for the use of the DANGER placard do not change, but those restrictions now include:
- gross mass not to exceed 1,000 kg,
- not to include only one hazard class, and
- are offered by one consignor at one location.
The 500 kg requirement for placards is found in section 4.16.1 with the restrictions being very similar to the restrictions currently found in the exemption 1.16 500 kg gross mass exemption. If any part of a shipment involves a restriction that is listed, then that amount is not used in the calculation for determining placards. For example, if a shipment consists of 2,300 kg of dangerous goods, with 2,000 kg being sodium, then that shipment will require the hazard class placard with UN number as it requires an ERAP. The remaining 300 kg, being under the 500 kg, will not require placards.
The wording of section 4.22.1 for the Category B mark has been changed to read that the Category B mark replaces the Class 6.2 hazard label.
For dangerous goods that are subject to special provision 23, it will now be required to add the words “toxic – inhalation hazard” next to the shipping name for small packages, and on the large means of containment, in addition to any required placards.
The purpose of this amendment is harmonize with the international regulations as well as with 49 CFR. There may be additional costs to carriers for implementing these changes, but TC is of the opinion that for carriers who do business in the US, they will already have the additional placard holders on their trucks.
Transport Canada has given 75 days for comment from December 1, 2012. Comments are to be sent to:
Genevieve Sansoucy, Legislation and Regulations, Transport Dangerous Goods Directorate, Department of Transport, Place de Ville, Tower C, 9th Floor, 330 Sparks Street, Ottawa, Ontario K1A 0N5 (tel.: 613-990-5766; fax: 613-993-5925; email: TDGRegulatoryProposal-TMDPropositionReglementaire@tc.gc. ca).
For more information, please go to: http://www.canadagazette.gc.ca/rp-pr/p1/2012/2012-12-01/html/reg2-eng.html