TDG Emergency Response Assistance Plans (ERAP) Update
On June 30, 2018, Transport Canada issued a proposed 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 on Government of Canada’s website.
Canada’s ERAP requirements are unique, not being adopted from the UN Recommendations on the Transport of Dangerous Goods. 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.) Since the Lac-Mégantic disaster in 2013, improving ERAP requirements has been a particular concern of Transport Canada’s.
The June amendment has four main goals:
- To clarify how an ERAP should be implemented;
- To enhance emergency preparedness and response;
- To reduce the regulatory burden for those affected by the requirement; and
- To make some general “housekeeping” changes to keep all parts of the regulations harmonized.
Clarifying Implementation of ERAPs
Currently, the regulations are unclear as to how exactly 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 Continue Reading…