Air – TDG Part 12 Pre-Amendment Consultation

Ground and air transport

Time Flies

Transport Canada, in what has become a series of proposed amendments, has issued a consultation White Paper on updates to the Transportation of Dangerous Goods (TDG) Regulations (TDGR) Part 12 Air.

This part references the International Civil Aviation Organization (ICAO) Technical Instructions (TI) along with TDG-specific supplemental requirements and exemptions. Some ICAO references date back to 2002 and changes to the TI have made some TDG provisions redundant or in need of updating. Also, there are some clarifications proposed to better align with the Canadian Aviation Regulations under the Aeronautics Act.

In the interest of clarification, Transport Canada hopes to increase the “one window” approach, wherein material is incorporated into the Part 12 TDGR rather than simply referencing an external document. This self-contained approach will still have to consider that changes to external documents might make references a more practical approach in some areas. The objective is also to harmonize this proposal with the “dynamic” (aka “ambulatory”) approach taken with the TDG International Harmonization Amendment.

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Geography Counts – Limited Access Exemptions

A potential improvement to Part 12 includes adding a definition of “Limited Access”. The proposed definition reads:

“a location to or from which the transport of dangerous goods by means other than by aircraft is not reasonably possible, for at least Continue Reading…

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
    • 7.1(5) – deals with Class 2 Gases where the means of containment is greater than 225 L and where there is more than 1 and interconnected and permanently mounted on a structural frame for transport
    • 7.1(6) – changed to 17 rail cars that are interconnected and each rail car is filled to 70% or more
    • 7.1(9) – now allows the use of another’s ERAP provided the shipper gets permission in writing to use that plan and the holder of the plan agrees to do the emergency response
    • Continue Reading…