Know Your Exemptions – the Explosives Exemption (TDG Section 1.31), and Special Provision 125

If your business is like most, you don’t usually deal with shipping explosives in Class 1. However, this class sometimes shows up in places you’d least expect it. While it’s expected to deal with explosives in construction, mining, and the military, you can also find explosives in unexpected products such as toys (caps for cap guns), pyrotechnics for stage and movie productions, and animal tracking collars (some use explosive bolts to free the animal so it doesn’t have to make a permanent fashion statement).

Shipping explosives can be more complex than many other classes of dangerous goods. They are subject to other regulations, such as the Explosives Act, and may require special licensing depending on what type they are. In addition, they are often excluded from some of the common exemptions found in Canada’s Transportation of Dangerous Goods Regulations (TDGR). For example, explosives can’t use the Limited Quantity exemption of section 1.17, or the Excepted Quantity exception found in section 1.17.1. Some low-level explosives may qualify for the 150 Kilogram Gross Mass Exemption in section 1.15 and the 500 Kilogram Gross Mass Exemption in section 1.16, but only if they fall into certain divisions, compatibility groups or UN numbers. You’ll need to read each exemption closely to ensure that your particular explosive will qualify.

To balance things out, TDGR does contain some provisions for shipping small amounts of low-level Continue Reading…

Amendment to Amendment 6

Section 1.15 of the Transportation of Dangerous Goods has become the 150 kg Gross Mass Exemption as a result of Amendment 6. This exemption provides relief from the following sections:

  • documentation
  • dangerous goods safety marks
  • means of containment
  • training, and
  • immediate reporting

The conditions to be met are: the individual package cannot exceed 30 kg gross mass and the shipment cannot exceed 150 kg gross mass. There are some restrictions that are similar to section 1.16 500 kg Gross Mass Exemption.

Although this exemption is for ground or a ship on a domestic voyage, it appears some shippers are trying to use this exemption to ship by air. In addition, some carriers are finding that shippers are utilizing this exemption and this is causing some serious concerns for carriers as there are no dangerous goods safety marks on the packages. The 500 kg exemption still requires the application of the shipping name, hazard label(s) and UN number. This provides for identification of the hazard(s) in the package. Under 1.15 nothing is required to be marked on the package. If a package is found to be leaking on the carrier’s vehicle – what is the hazard?

Transport Canada recognizes that there is a problem with this section and will issue an amendment that will limit the transport of the dangerous goods to the purchaser or user of the dangerous goods.