TDG
Standard TP14850 Pre-Canada Gazette (CG) I Consultation

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Updated TDG Packaging Standard – Small Containers for Classes 3, 4, 5, 6.1, 8, & 9

In addition to expanding the title to reflect the various types of containers contemplated in the Transportation of Dangerous Goods regulation (TDGR) §5.6, 5.12 (and cited within other referenced standards), this “final draft” reflects the penultimate result of a review that’s been active since the adoption of the current edition in 2015.

Anatomy of Development

The 2nd Edition of TP14850, published October 2010 was adopted into the Canadian TDGR in July 2014, replacing CGSB-43.150-1997 and becoming the mandatory standard for packaging the “common” classes of dangerous goods in Canada in January 2015.

The 16th Edition (2009) UN Model was the primary basis for the 2010 TP14850 standard, so it was time to move forward in the spirit of harmonization.

Transport Canada began the process of forming a consultative committee in mid-2015. A public notice regarding the consultation was published in early 2016 with provision for general public input. The committee, formed in April 2016, consists of about 3 dozen participants.

The committee includes a core group of 6–8 from Transport Canada with the remainder representing a variety of industry associations, individual manufacturers, users, provincial/US regulatory interests, and labour organizations.

The draft presently open for general comment was developed by consensus following discussions, including face-to-face meetings and a series of web/teleconference sessions, between April 2016 and June 2017. Comments received from the public on a draft released May 1, 2017 were considered during the process.

Feedback during these discussions was reviewed, leading to the “final” pre-CG I draft open for public comment until March 30, 2018.

Significant changes between the 2010 Edition and the first consultation draft were the subject of a May 2017 Blog.


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Changes following the May 2017 Draft

As indicated in the Transport Canada notice, a great deal of the update is to harmonize requirements as much as possible with changes to UN Model regulations since 2009, culminating in the 20th Ed. (2017) published recently.

[Despite the anticipation of the UN Model 20th Edition changes, there are several entries (e.g. UN3535 through UN3548) which have not yet entered the current edition of the TDGR or the “final” draft of TP14850. Presumably these will be considered in the pre-CGII period.]

Form as Well as Substance

As indicated in the 2017 review, an improvement in the 3rd Edition will be the incorporation of substance-specific provisions into the applicable packaging instructions (PI) themselves. This is similar to the format in the UN Model and the IMDG Code. It should be more convenient for users to consult these at the end of individual PI rather than referencing a general list in a separate appendix.

Also, in this edition there will be a list of tables in the Table of Contents for easier navigation.

One area that may cause some initial concern is the removal of the previous Appendix tables of “Currently Assigned Self-Reactive Substances and Organic Peroxides” formerly referenced in §12.8.8. The current draft (now §12.8.9) refers instead to the TDGR, which in turn cite the UN Model regulations. This will avoid the need to continually update this aspect of TP 14850 since the TDGR invoke the current (“as amended”) version of the UN Model.

Fleet Operators

The references to Fleet Operators has been expanded for clarity in the provision to allow use plastic drums or jerricans beyond the standard 5-year limit (note that in the TP14850 context “fleet” refers to the collection of containers, not the commonly encountered reference to a collection of vehicles that transport!).

Requirements for registration and quality management systems for the provision have been added.

Miscellaneous Changes

The term “manufacturer” has been added to §3 (Definitions) to clarify that the certificate holder is the manufacturer even if subcontractors actually do the fabrication.

Some “notes” have been incorporated into the regulatory text (e.g. provision to use antifreeze to maintain the test substance as liquid during the -18 degree Celsius conditioning).

The §12.7 “V”-pack requirement now indicates that user must ensure that the absorbent to be used is compatible with liquids to be shipped.

The language around ensuring users have the instructions required to use packaging effectively has been modified in §4. Manufacturers must “transmit” use instruction information (written or electronic) when a package is initially purchased, and subsequently make it “available” on request from users.

In addition to the above-cited earlier Blog, a summary of some of the changes is included in the Transport Canada notice, with contact information to get a copy of the pre-CGI draft is available at:

http://www.tc.gc.ca/eng/tdg/publications-standards-menu-1094.htm

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