REGISTRATION and FINES and FAQs, OH MY!
February and March contain some interesting items potentially impacting the Canadian TDG landscape…
Transport Canada, through a consultation notice published in late February, has solicited input from stakeholders on a plan to require those who handle/offer for transport, transport or import dangerous goods to register with Transport Canada.
The premise is that, “… public safety depends” on Transport Canada knowing who is transporting DG, including where, when, and how much. The main thrust of this proposal seems to be for targeting enforcement and consultation activities.
The proposal as currently presented does not appear to distinguish among the size, frequency, or nature of DG involved; and will require period re-registration with submission of data to the “Client Information Database” (CID).
There’s nothing in the posted information to indicate whether there will be a cost to “clients” for registration, in addition to the record-keeping burden they will bear.
(For those familiar with the 49 CFR §107 (Subpart G) requirement, intended to subsidize government response activities, this TDG version does not serve the same purpose.)
The only exemptions currently contemplated, extend to those falling under a TDGR Part 1 “special case” exemption. This contrasts with 49 CFR’s registration which has exemptions based on load sizes and hazard types.
The TC proposal and comment provisions are found at:
While not directly cited in the Transport Canada TDG Act or regulations, Continue Reading…
Why did you use an exact concentration?
Why was an exact concentration used? Health Canada eliminated the allowable ranges (previously allowed with WHMIS 1988) and went to exact concentrations. The only exception is if there is a batch variation. The other option is the customer can apply for an exemption. The blog found here http://www.thecompliancecenter.com/blog/2015/08/10/strictly-confidential-not-sds-ingredient-disclosure-cbi/ provides addition information.
Why is my product a class 9 in Canada when it was not previously?
On December 31, 2014 Transport Canada issued an amendment to the Transportation of Dangerous Goods Regulations (SOR/2014-306). Details on this amendment can be found here http://www.thecompliancecenter.com/blog/2015/01/05/new-year-new-tdg-amendment/ . Essentially, Transport Canada brought in the criteria for classifying marine pollutants that follows the IMDG code. Based on the available aquatic data for fish, invertebrate and algae, the substance or product is given a classification. If that classification falls into Acute Category 1 or Chronic Category 1 or 2, it is regulated for transport and gets the shipping description Environmentally hazardous substance (solids or liquids), n.o.s. The USA still leaves this as an optional classification (you can still use the list or you can harmonize).
FAQs Arising from ICC’s Webinar on TDG Amendment 12
Congratulations to Balmor from Markham for winning the draw for a copy of the updated TDG Regulations!
FAQs from our first webinar »
Yesterday ICC hosted the second of two sessions for a webinar to inform our customers about the recent changes that arise from the release of TDG Amendment 12. As with the first session, there were a lot of great questions this time around and my colleague Clifton did a great job answering them throughout the session. Here are some of the questions with answers:
What does ERAP stand for?
Emergency Response Assistance Plan. More information can be found in Part 7 of the TDG Regulations.
For Class 7 (Radioactives), we must still label on two opposite sides, even if less than 64 cubic feet, right?
Correct. Class 7 always has a minimum requirement to have two opposite sides labeled.
If my shipment is an Overpack of Limited Quantity, do I still mark it with “Overpack”?
Yes, you still require the word “Overpack” or “Suremballage” and the limited quantity mark. The reference is 1.17(4) of the updated TDG Regulations.
Is there a minimum size requirement for the word “Overpack”?
Currently there is no minimum size requirement for the word “Overpack”. Like all marks, you’ll want to make sure that it is large enough to be easily read.
Does Continue Reading…
FAQs Arising from ICC’s Webinar on TDG Amendment 12
Congratulations to Josie from Toronto for winning the draw for a copy of the updated TDG Regulations!
Yesterday, ICC hosted a webinar to inform our customers about the recent changes that arise from the release of TDG Amendment 12. There were a lot of great questions asked using the direct chat with my colleague Barbara during the webinar and we wanted to post some best ones in a blog. Thank you to everyone who attended and for all of your participation. I read the feedback after the webinar and considered everyone’s feedback.
If we didn’t have a chance to answer your question in chat, please remember that ICC’s Regulatory Helpline is available to its customers.
Read the updated FAQs from our second webinar »
Without further ado, here are the questions:
Where can I find the Amendments?
Follow these links to read the Amendments:
Part 4 Safety Marks
Update of Standards
Will there be any training sessions planned for the new updates?
Yes! We’re working on those right now. Check back on our website in the near future.
If we have > 1000 kg of regulated goods in one class (let’s call it 2000 kg of item A) and other regulated items from other classes that amount to under 1000 kg per class (200 kg of item B, 300 kg of item C, and Continue Reading…