“Sea Change” Amendment to TDG Proposed- Criteria Requiring IMDG Code Clarified

Hot on the heels of the Feb. 2 Transport Canada proposed amendment (“Harmonization Updates”) posting, there was another (Feb. 9) proposal for consultation to clarify the intent of Part 11 regarding marine/ferry shipments.

A major result, if the proposal is adopted, will remove the confusion around when the IMDG Code is mandatory for vessel (updated terminology to replace the noun “ship”) shipments of dangerous goods. This issue has been subject to conflicting interpretations from time-to-time; not just among consignors, but also within the transport and enforcement communities.

This difficulty in making a clear interpretation stemmed from the difference in the intent of the term “Home Trade Voyage” in an obsolete version of the Canada Shipping Act which was quoted (perhaps out of context) in Part 11 of the TDGR.
A literal reading implied that essentially all “salt water” voyages could be considered Class I home trade voyages; requiring use of the IMDG Code.

As proposed, shipments by ferry to, for example Newfoundland or Vancouver Island, will likely clearly be under the provisions of the TDGR, not the IMDG Code. This will be of benefit, particularly to shippers of limited quantity/consumer commodity items which should no longer require a formal dangerous goods document or other considerations unique to the IMDG Code.

Short-Run Ferry qualification criteria may also be expanded to 5 km voyages; and restrictions on fuel transport on passenger ferries may Continue Reading…

Harmonization Continues (No, not that one!) – TDGR Consultation Proposal

…or “Preliminary consultation on International Harmonization Updates to the Transportation of Dangerous Goods Regulations”:

Transport Canada, after a busy 2014/2015, has begun a public consultation on proposed amendments aimed at improving the harmonization between the Transportation of Dangerous Goods Regulations (TDGR) and International/US regulations. The proposed amendments will also update referenced standards on classification, packaging, etc.

TDGR Part 8 Reporting requirements will include the ICAO-based requirement for the Air Operator to notify CANUTEC if DG have been discovered to have been carried in non-compliance without proper notification to the pilot-in-command.

Ambulatory References:

A key feature of the proposal is the move towards citing versions of safety standard/requirement documents in Part 1 “as amended from time to time” rather than referring to a specific issue date or revision. This will simplify things for international trade and reduce potential confusion over which edition must be followed.

Canada-US Reciprocity:

In keeping with objectives established in the 2012 Canada-US Regulatory Cooperation Council action plan: ;

the proposal seeks to consider allowing the provisions of Canadian Equivalency Certificates (TDGR Part 14)/US Special Permits to be mutually acceptable between the two countries.

While recognizing the potential beneficial aspects of the change for industry stakeholders; there is concern on other potential impacts, such as for the enforcement community.

The proposal also includes provision for authorizing the interchangeable use of gas cylinders and aerosols (TDGR Part 5).

Catch Up:

As part of the proposal to Continue Reading…

OSHA Flammable
“Light My Fire” – Calculating Flash Points for Flammable Liquids

One of the most common tests for determining hazard classification is the flash point. This humble piece of physical information is defined in various ways in various regulations, but generally is the lowest temperature at which the vapours from a flammable liquid will ignite near the surface of the liquid, or in a test vessel. This can be critical for safety, because this temperature will be the lowest possible for the liquid to cause a flash fire if released or spilled. If the material can be handled and transported at temperatures lower than the flash point, the fire risk will be much smaller.

The flash point has become the standard test for classifying flammable liquids. It’s used by the U.S. OSHA (Occupational Health and Safety Act) and HMR (Hazardous Materials Regulations) classification systems, as well as Canada’s WHMIS (Workplace Hazardous Materials Information System) and TDG (Transportation of Dangerous Goods Regulations).

Obtaining a flash point on a new product is usually easy enough. Many laboratories, particularly those that deal with petrochemicals, can perform the test for a reasonable charge. If your company has too many products to make outsourcing practicable, a flash point tester itself is comparatively low cost (as scientific apparatus goes), and a trained person can obtain data quickly and efficiently. However, both of these options do cost money. Wouldn’t it be nice if there were a Continue Reading…

When an Ordinary Box Isn’t so Ordinary After All (HazMat Box)

We have all used a fiberboard (or cardboard as most people call it) box to ship something. It may have been a box of gifts for a friend or family member, or a package of merchandise for a client at work. Most of the time, you probably didn’t give much thought to the box other than to make sure it was sturdy enough and big enough to contain what you were shipping. For these typical kinds of shipments, that ordinary box will do just fine. HazMat (or dangerous goods) shipments, however, aren’t ordinary and neither is the box that they need to be shipped in.

The packaging industry is a science in itself, with ever evolving processes, techniques, materials, treatments, and regulations. HazMat packaging is a specialized area of packaging technology, and it has some very specific requirements that must be followed. Even though a HazMat box may look identical to a standard shipping carton, there are some significant “behind the scenes” differences between them!

  1. Material matters! When dealing with HazMat boxes, there are specific tolerances for manufacturing. The combination of materials used to make up the fiberboard has very little wiggle room once the design has been approved and certified. Changes in the material may invalidate the certification and make the boxes non-compliant.
  2. Proven performance! HazMat boxes have to be put to the test before they can be Continue Reading…
Single Packaging
The Carrier Has The Final Say

Have you ever prepared a shipment that you were 100% certain was done according to regulation, only to have it refused by the carrier? The reason may be because carriers can put in place requirements that go above and beyond the regulations and will refuse your shipment if you do not comply. Finding these extra requirements can be simple for air shipments thanks to the Operator Variations listed in IATA Section 2.8.3. However, other modes of transport do not have the variations listed, and even the IATA variations don’t cover every possible extra requirement.

Below are a few ways you can determine if there are additional requirements for your shipment.

  1. Ask your carrier! If you are using a new carrier or shipping a new material with your current carrier, ask them if there are any additional requirements that you should be aware of before you prepare the shipment. Most carriers have dedicated Dangerous Goods agents who will be able to let you know about any extras.
  2. Check the IATA variations even for ground or vessel shipments. Many of the operator variations that are listed in IATA apply to all shipments for that carrier, regardless of the mode of transportation. One common example is FedEx’s FX-02, which requires Division 6.1 material in PG I or II to be in special permit packaging for domestic shipments.
  3. Trial and error. Continue Reading…
Know Your Exemptions – the 500 Kilogram Exemption (TDG Section 1.16)

Like most regulations based on the UN Recommendations for the Transport of Dangerous Goods, Canada’s “Transportation of Dangerous Goods Regulations” (TDG) includes a number of exemptions. These provide easier and more cost-effective ways for shipping low-risk materials. However, each exemption needs to be carefully studied. If you don’t comply with all the requirements, you are not entitled to any part of the exemption.

One of the most misunderstood exemptions in TDG is found in section 1.16, the “500 Kilogram Exemption.” The provisions in this section originated in a long-ago series of permits intended to make shipment of small quantities of dangerous goods easier. Over the years, changes to this section have reduced its effectiveness; it still may be a helpful exemption in certain specific cases, but it must be used appropriately.

The first myth about the 500 kilogram exemption is that it is a total exemption from all requirements of TDG. This is far from the truth. At best, the exemption relieves the shipper from Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks) and Part 5 (Means of Containment). All other requirements of TDG will still apply. This includes, for example, the requirement that the carrier and all handlers must be TDG-certified. At one point, receivers were exempted from Part 6, Training, but this relief was removed in an amendment several years ago.

Obviously, the exemption only applies Continue Reading…

Single Packaging
The Importance of Packing Instructions

Simon Says . . . It’s All About Following Directions

An experienced shipper knows that in order to be compliant for HazMat or Dangerous Goods shipping, packaging designs have to be subjected to performance testing. In fact, this should be something that even new shippers learn during their training. This testing is meant to simulate conditions that the package could encounter during typical transport operations.

Did you know that there are requirements to be followed even after the testing is complete and the packaging is marked as meeting the appropriate specifications? In a game of Simon Says, all players must do whatever Simon says. Packaging manufacturers are like Simon, they must provide proper instructions to customers so that they are able to assemble and use the packaging correctly. The packaging must be assembled in the same manner as it was during the testing process. If not, the shipment could be considered non-compliant.

The certification provided for the packaging is only good for the exact configuration that was tested. This is especially critical for combination packagings which can have numerous parts necessary to make a complete package. Making even minor changes to that configuration means there is no way to know for sure if it would still pass the testing criteria. Using specification packaging is much like a game of Simon Says . . . one wrong move and you Continue Reading…

TDG Proposed Changes: BioPackaging – Reporting

Transport Canada recently shared proposed changes affecting the official standard for Class 6.2 packaging and the Part 8 reporting requirements. The former is by reference to a proposed update to the CGSB standard; the latter by a Canada Gazette (CG) I notice.

Intention to Update CGSB-43.125 Reference:

Transport Canada has declared the intention of updating the referenced CGSB-43.125 packaging standard required for shipping Class 6.2 Infectious Substances under TDGR:

(Note that Transport Canada does not recognize the 2003 Edition (Table of Safety Standards, TDGR Part 1.3.1- the 1999 edition is still the official version for transportation).

The Canadian General Standards Board (CGSB) has issued a draft update for CGSB-43.125 to replace the current 2003 edition. The draft is available for public comment until July 13, 2015.

Proposed changes include updating various regulatory references and changing the terminology to align with UN Recommendations: P620 (for 6.2, Category A- formerly CGSB “Type 1A, high integrity”); P620 (Category B & lower hazard Category A- formerly CGSB “Type 1B, routine”); and “Part III” general UN standardized packaging and non-standardized packaging for non-P620 wastes (formerly CGSB “Type 1C, waste”).

P650 packages will no longer require design registration. The standard will have separate sections for:

  • Design/test/manufacturing (Part I);
  • Selection/use (Part II- Cat. A & B);
  • Selection/use (Part III- Cat. A & B for disposal/Medical-Clinical bio waste)

A copy of the draft may be obtained from Public Works & Government Continue Reading…

DG (Including Wastes) Shipping Documents/Manifests- “ISHP”


July 1 (or June 30, depending on how you count “6 months”), 2015 represents a change in the required order of presenting the shipping description elements on a Canadian dangerous goods (DG) shipping document.

This change was part of the general harmonization (a good, but much-abused word!) with UN and modal regulations that were not specifically highlighted in the title or RIAS for the amendment in Canada Gazette II.*

Since 2005 Canadian consignors have had the option, for domestic ground shipments, to describe the DG on a shipping document in either the “ISHP” (UN#, shipping name, hazard class, PG) or “SHIP” (shipping name, hazard class, UN#, PG) order. No more.

ISHP Mandatory

As of the end of the upcoming 6 month transition period following the Dec. 31 CGII (SOR/2014-306) amendment ONLY the “ISHP” format is compliant as specified in the amended TDGR subsection 3.5(1)(c). This brings ground shipments into line with the international and other modal (i.e. IATA & IMDG) documentation requirements. This is logical, after all, in a world where many languages are used but numerical representations are more universally recognised.

Waste Manifests

A potential glitch in agreement between regulations should be noted by those who ship wastes which may also be classed as dangerous goods, using the Canadian standard “Movement Document/Manifest” required in most regulations.

(Note that, under environmental regulations, wastes can be classed as “hazardous”, “registerable” or “regulated”, requiring a Continue Reading…

TDG TC 117 Rail Tankers/ERAP Clarification- CGII, May 20 (no question)!

Transport Canada’s May 1st announcement of a TDGR amendment was formalized in the May 20th edition of CGII. This amendment, SOR/2015-100 (“TC 117 Tank Cars”), phases in the requirement for the upgraded TC 111 and basic-enhanced TC 117 rail tank cars for flammable liquid service (see my Blog of May 4th).

The amendment details the enhancements required to the basic tank car design and construction in TP14877 for use in service for flammable liquids. TP14877, published in 2013, was formally adopted in July 2014 and became mandatory in January. Subsequent incidents and recommendations have led to these extra measures to provide a stronger tanker in conjunction with other operating procedures to improve rail safety for flammable DG transportation.

On the related topic of rail tanker ERAP (emergency response assistance plans-TDGR Part 7), the amendment clarifies the requirements as they apply to rail tankers and true flammables.

Canada Gazette II: