If you’ve ever applied for an interpretation from the U.S. Department of Transportation, or even looked one up online, chances are you’ve found a solution to your problem in a letter signed by Edward Mazzullo, longtime Director of the Office of Hazardous Materials Standards of the U.S. Department of Transportation (DOT). Mr. Mazzullo’s commitment to clarifying the complexities of the Hazardous Materials Regulations, as well as his career devoted to developing and improving regulatory standards, has resulted in him being awarded the George L. Wilson Award by the Dangerous Goods Advisory Council (DGAC) at its 40th Annual Summit and Exposition in Arlington, VA.
Each year, DGAC, a major organization for the education of the private and public sectors on transport of dangerous goods issues, presents the George L. Wilson Award to an individual, organization or company that has demonstrated outstanding achievement in the field of hazardous materials transportation safety. Previous winners include former members of the DOT, but also representatives of industry, and international representatives such as Linda Hume-Sastre, who labored for many years on the Transportation of Dangerous Goods Regulations for Transport Canada. Even CHEMTREC, the well-known emergency information service, has received the award.
DGAC presented the award to Mr. Mazzullo at a lunch attended by many hazardous materials professionals who have benefitted from his guidance through the years. We applaud his long service, and dedication to Continue Reading…
October 17, 2017 is the deadline for Transport Canada’s Air Cargo Security (ACS) Program.
What is the ASC program?
It is a cargo security program that:
meets the highest aviation security standards;
reduces risks to the safety and security of the travelling public; and
keeps goods moving in and out of Canada efficiently.
Business must apply to participate in the program in order to screen, store, transport, tender or accept secured air cargo.
Companies must choose a category that best suits their role in the supply chain. These categories include:
Known Consignor – originates air cargo that has been made secure through a screening process applied at the time of packing.
Certified Agent – stores, transports and/or accepts cargo that an authorized Air Cargo Security Program participant has screened and made secure.
Regulated Agent – screens cargo on behalf of others to make it secure and subsequently stores and/or transports the secure cargo.
Account Consignor – originates cargo and has it screened by an authorized participant in the Air Cargo Security Program to make it secure.
Authorized Cargo Administrator – directs the movement of secure cargo without coming into contact with it (i.e., provides logistics services without screening, storing and/or transporting the secure cargo).
Participants must submit an application to Transport Canada which will be vetted, followed by an inspection and ongoing oversight.
On June 1, 2016, Transport Canada issued an amendment to the “Transportation of Dangerous Goods Regulations” (TDG) under the Transportation of Dangerous Goods Act. This amendment substantially revises the requirements for reporting spills of dangerous goods during transportation. It also addresses changes to air shipment of lithium ion batteries and makes various minor corrections and changes. The “Reporting Requirements and International Restrictions on Lithium Batteries Amendment” reflects concerns that the previous requirements for reporting spills, called “accidental releases,” was inefficient and didn’t allow the reporting parties to evaluate the risk to the public when deciding if a release had to be reported.
Changes to Reporting – Surface Transport
The section on reporting accidental releases, Part 8, called “Accidental Release and Imminent Accidental Release Report Requirements,” has been removed from the regulations and replaced with a new Part 8 titled simply “Reporting Requirements”.
First, the amendment removes the definitions for “accidental releases” and “anticipated accidental releases” and replaced them with definitions for “releases” and “anticipated releases”. This means that the reporting requirements will now cover intended releases as well as those that occur by accident.
Next, Transport Canada has adjusted the quantities of a release that would trigger reporting. For road, rail and water transport, these changes include:
The limit is lowered to any amount for Class 1, Explosives; Class 2, Compressed Gases; Classes 3, 4, 5, 6.1, or 8, in Continue Reading…
On April 28, 2016, Transport Canada issued its latest Protective Direction. This Direction, number 36, will replace a previous one, Protective Direction 32, with more detailed instructions for rail carriers.
Protective Directions are rules that are not included in Canada’s Transportation of Dangerous Goods Regulations (TDG). Instead, they are announced by Transport Canada, and are published on their website. Usually, these directives are used when Transport Canada believes it’s important to bring in a new rule quickly in order to protect the public. Since amending the regulations can take months or longer, Part 13 of TDG allows them to use this method to respond to important issues with appropriate speed.
Protective Direction 36 requires Canadian Class I rail carriers to either publish information on the carrier’s website, or provide information to designated Emergency Planning Officials (EPOs) of each jurisdiction through which the carrier transports dangerous goods. This information includes:
Aggregate information on the nature and volume of dangerous goods that the rail carrier transported by railway car through the last calendar year (broken down by quarter);
The number of unit trains loaded with dangerous goods operated in the jurisdiction in the last year (again, broken down by quarter); and
The percentage of railway cars carrying dangerous goods that were operated by the rail carrier through the jurisdiction in the last calendar year.
A public notice has been posted by Transport Canada. The info is below:
The Transportation of Dangerous Goods Directorate will begin work on updating the Transport Canada Standard TP14877, “Containers for Transport of Dangerous Goods by Rail”, December 2013. The standard covers large means of containment used in the handling, offering for transport and transporting of dangerous goods by rail. The update will focus on incorporating recent regulatory changes and proposals that have been consulted with the TP14877 Consultative Committee. The TP14877 Consultative Committee is comprised of various key stakeholders with extensive knowledge and expertise in regards to various aspects associated to the transportation of dangerous goods by rail.
Zika virus – the name itself sounds exotic and dangerous. It is believed to be a serious risk for pregnant women. And it’s due to arrive in North America. Just how great a danger is this virus, and how should research and medical facilities prepare for the regulatory burden?
First of all, Zika is not a new virus. It has been known since the 1950s in equatorial Africa and Asia, but only recently has it appeared to migrate to new territories, including South and Central America, the Caribbean and Mexico. It is primarily a mosquito-borne illness, transmitted by the Aedes genus of mosquitos. Possibly climate change has increased the populations of these mosquitos in the areas where Zika is spreading. Aedes mosquitos are found in some parts of the U.S., and although they are not currently believed to be in Canada, they may spread as the climate warms. Person-to-person transmission by body fluids is possible, but this would be relatively rare compared to the mosquito vector.
Zika is classed in the Flaviviridae family of viruses, along with dengue fever, West Nile virus and the notoriously dangerous yellow fever. However, compared to these, Zika is usually a mild affliction. According to the Centers for Disease Control (CDC), only one in five persons infected with the virus shows any symptoms at all. For those who do fall ill, the symptoms Continue Reading…
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.
The holiday rush for 2014 is over. Our parties have been held, and our gifts are unwrapped and appreciated. But if you’re a dangerous goods shipper or carrier, you can’t relax just yet. New requirements from Transport Canada become mandatory, January 15, 2015. So, it’s time to make sure that everything in in compliance with the new system.
Back on July 2, 2014. Transport Canada issued two amendments to the Transportation of Dangerous Goods Regulations (TDG). One was called the Safety Mark Amendment, and the second was the Update of Standards Amendment. Both will have important effects on dangerous goods shipping procedures, and will need to be addressed immediately if you want your shipments to remain in compliance.
If your organization hasn’t already done so, it will need to review these amendments and make all necessary changes as soon as possible. Here are some of the most critical changes:
Non-bulk packaging must now be selected for ground shipment using a standard published by Transport Canada, called Transport Canada Standard TP14850E, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and, 9, a Transport Canada Standard.” Note that this is available as a free download from the Transport Canada site at http://www.tc.gc.ca/publications/en/tp14850/pdf/hr/tp14850e.pdf
Consignors of dangerous goods must keep on file a “proof of classification” for all dangerous goods they offer Continue Reading…
It may appear at first that these are merely technical changes and updates. Transport Canada says that the main reason for the amendment is that some of the standards need their references updated to the most current version, and some of them need to be introduced for the first time. However, if the amendment is finalized in Gazette II, some of the implications are significant for Canadian shippers and carriers.
The principle points behind this amendment are:
Several new standards must be introduced in order to enhance compliance with the UN Recommendations in their current form. This means including standards for packagings such as cylinders (which currently have a TC (Transport Canada) specification), and UN-specification portable tanks. This will ensure that Canadians are using the most harmonized, as well as the most modern, packaging standards.
A number of the existing standards referenced in TDG are not referenced in the most current version. For example, the current regulation has a reference for CSA Standard B339-08, “Cylinders, spheres, and tubes for the transportation of dangerous goods”, last amended in February 2005. The amendment will update this reference to the version published in March 2008.
So, you want to bend the rules? What happens when you have a scenario where following the regulations to ship your dangerous goods becomes impractical to the point of impossibility?
This blog entry will speak to what the process is for applying for an Equivalency Certificate in Canada as per the Transportation of Dangerous Goods Clear Language Regulations.
Generally when people ship dangerous goods, the process becomes a matter of reading and complying with everything the regulations state. However, below are some scenarios where following exactly what the regulations state is… shall we say… less than ideal.
Al wants to ship some large batteries for equipment within Canada with classification:
UN 2794, Batteries, Wet, Filled With Acid, Class 8, P.G. III
His dilemma is that when a new battery is commissioned, the outer package is generally discarded due to space limitations. In many cases these batteries were installed prior to the packaging requirements of Part 5 of the TDG Regulations.
Al wants to ship this without UN approved packaging.
Bill wants to ship a MRI machine that contains liquid helium, classification:
UN 1963, Helium, refrigerated liquid, Class 2.2
His dilemma is that his MRI machine is what contains the Helium and it is not in an approved means of containment. He requires the helium to remain in his equipment during transport in order to keep the magnet cool.