Two New Transport Canada Alerts — ERAPs & E-cigarettes

Transport Canada clarifies interpretation of 10,000 L ERAP requirement & warns of “e-cigarette” hazards in checked baggage.


Further to my blogs of January 12, 13 & 28th – Transport Canada has issued an Alert (dated February 2015- posted March 6) stating:

“the ERAP index of 10,000 L will only apply to rail tank cars”

This appears to be an interim solution until the entries can be formally modified in an amendment.

The full ALERT may be found here (PDF).


Another Alert deals with the potential fire hazard of e-cigarette heating elements accidentally activating in checked baggage on aircraft. The units typically are powered by lithium batteries.
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ERAP Changes Potentially Extend Beyond Rail Tankers

Are You Implicated?

Wording of amendment includes highway tankers, IBC, for UN1993, etc.

Recently, I wrote about the December 31 (SOR/2014-306) amendment to the TDG regulations, which contained a change to the substances requiring an ERAP (TDG-approved Emergency Response Assistance Plan) under Part 7.

As worded, the ERAP obligation extends to consignors of the specified flammable liquids in any shipment  of an accumulation of large means of containment (LMOC) i.e. capacity exceeding 450L) exceeding 10,000 L or any individual LMOC containing more than 10,000 L.

The intent was to incorporate the ERAP requirement for petroleum/petroleum-like products being shipped by rail tanker as contemplated in the post-Lac-Mégantic Protective Direction 33.
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Ebola Outbreak Puts Stress on Shippers of Infectious Substances

The headlines are frightening – Ebola virus, one of the most deadly viruses known, has broken out in several African countries. Medical authorities are concerned that it could spread beyond that region, carried by travellers all over the world. Laboratories in North America and Europe are on alert for patients showing suspicious symptoms. This, in turn, means that samples and specimens must be transported for testing and verification. How can the medical community deal with transportation of such high-risk materials?

Shipping biological substances training »

Ebola virus is considered a “hemorrhagic fever,” which affects the blood system. Its virulence is astonishing, with a fatality rate of between 50 and 90 percent. Combine this with the ability to be transmitted through casual contact, and the lack of specific vaccines or treatment, and it’s understandable why Ebola is such a feared disease. Therefore, it is all the more essential that transporters make sure that they comply with all legal and safety requirements.
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ERAP – When?

One of the conundrums of the Transportation of Dangerous Goods Regulations (TDG) is the requirement to have an ERAP for a UN number that is not listed in Schedule 1 of TDG.

The problem we run into is that Schedule 1 is only up to the 11th Edition of the UN Recommendations on the Safe Transport of Dangerous Goods (model regulations). In section 1.3.1, item 39 in the table of standards indicates that TDG is at the 14th Edition of the model regulations. But since the 13th Edition of the model regulations, the UN has issued over 130 new classifications.

But section 1.10 of TDG states:

A person may use the appropriate classification set out in the ICAO Technical Instructions, the IMDG Code or the UN Recommendations to transport dangerous goods within Canada by a road vehicle, a railway vehicle or a ship on a domestic voyage if these Regulations or the document from which the classification is taken does not forbid their transport.
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Transport Canada Issues Amendment 10 to TDG

Transport Canada has recently issued Amendment 10, an update to Canada’s Transportation of Dangerous Goods Regulations. The text of this amendment can be found at

This Amendment deals specifically with Emergency Response Assistance Plans (ERAPs), and compensation for situations where the government has invoked a plan in the event of a terrorist action. Costs that are eligible for compensation include:

Regulatory news

Some topics that were discussed at the last Regulatory Affairs Committee meeting of the Canadian Association of Chemical Distributors (CACD

  • The CACD board of directors has approved a new standing committee – Health and Safety; there will be more news about this committee as it comes together
  • CACD has re-branded and launched its new website at its 25th anniversary AGM which was held in St. John’s NF this past June
  • the Auditor General will be reviewing the TDG directorate and will include the emergency response assistance plan (ERAP) programme in the review; the objective is to determine if the programme has value to Canadians; in general, experience has shown that emergency responders do not make use of ERAPs.
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Transport Canada Issues Interim Order – G20

Transport Canada has posted on its website a proposed interim order for the period of the G20 meetings in Toronto. Dangerous goods that require an ERAP, are in Classes 1.1, 1.2, 1.5 or are in Class 7, other than medical isotopes (UN2915), are prohibited from the controlled access zone. Also included in this are dangerous goods that require the display of placards. However, these dangerous goods are permitted between midnight and 06:00.

The controlled access zone is the area in the City of Toronto that is bounded by Strachan Ave from Queen St West to Lake Ontario, Queen St West from Strachan Ave to Bathurst Street, Bathurst Street from Queen St West to Dundas St West, Dundas Street West/Dundas Street East from Bathurst Street to Jarvis Street, Jarvis Street from Dundas St East to Lake Ontario. You can also view this area on a map.

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Amendment T – Provisions for Orphan Releases

Transport Canada has posted on its website Amendment T – Provisions for Orphan Releases. This is a proposed regulation and has NOT been published in the Canada Gazette.

Amendment T outlines the compensation for implementing an ERAP at the request of the Minister. There are 4 sections that will be added:

  • 7.10 Compensation for Authorization to Implement an Approved Emergency Response Assistance Plan (ERAP)
  • 7.10.1 Compensation Limits
  • 7.10.2 Claims for Compensation
  • 7.11 Emergency Response Assistance Plan for Emergency Response Contractors

Section 7.10 outlines what expenses will be covered, such as:
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Amendment 8 (again)

Although Amendment 8 was published in Gazette I in May 2009, Transport Canada (Dangerous Goods Directorate) has made changes due to comments received since May 2009.

Some of the changes are:

  • Part 16 Inspectors is revoked
  • Part 7 Emergency Response Assistance Plans (ERAP):
    • 7.1(1) – now specifies a single means of containment, regardless of the size of the means of containment
    • 7.1(2) – has had "small" deleted from means of containment and is the total quantity in all the means of containment
    • 7.1(3) – the 10% rule is revoked and it is now back to the accumulation of large means of containment
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2010 Vancouver Olympics

Transport Canada has posted on its website two (2) proposed interim orders that will cover the Vancouver Olympics. The first one is titled "Interim Order Respecting the Transportation of Dangerous Goods Into, Through or Within Controlled Access Zones". This proposed interim order, once approved by the Governor in Council would expire on March 4, 2010. The order sets boundaries which creates the access zones.

Zone 1 is the downtown core and dangerous goods requiring an ERAP, in class 1.1, 1.2 and 1.5, and in class 7 may not move into, through or within. Any placarded vehicle is only allowed access between midnight and 0600.

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