Have You Made Your TDG Updates Yet?
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 for transport. Details on what is required for this proof can be found in TDG section 2.2.1.
- Safety marks must be updated to current United Nations standards. For example, the all-yellow Division 5.2 label has been retired; if you are shipping organic peroxides, you must use the new red-and-yellow version for Division 5.2. Also, Marine Pollutant marks must be updated to the new diamond shape, as the older triangle marking is now obsolete.
- The placarding rules have been revamped significantly. For example, certain classes such as Division 4.3, Dangerous When Wet, must be placarded for any amount, rather than using the 500 kg placarding exemption. Also, new restrictions have been put on the use of “Danger” placards.
- Large containers carrying bulk packagings such as tote tanks must now display all class placards and UN numbers that are required on the packagings inside.
- The Limited Quantity provisions of section 1.17 have been updated so that it is no longer necessary to include the words “Limited Quantity,” “LTD. QTY.” or “Consumer Commodity” on shipping papers when offering limited quantities for transport.
Not all the requirements of these amendments share the January 15 compliance date. The requirement found in section 3.6.1 for a signed certification on shipping papers will not become mandatory until July 15, 2015. This will allow organizations to use up stock of preprinted documents that do not include the certification statement.
As of January 15, Transport Canada and provincial inspectors will be able to charge organizations which have not adopted the changes in these amendments. If you haven’t already switched to the new requirements, do so as soon as possible to avoid potential fines. If you’ve been proactive and already implemented them, congratulations! But you should still do a final check to ensure that all your employees understand the new requirements, and have the tools they need to comply with them, such as copies of the new packaging standard and instructions for the revised placarding rules.
If you have questions about the impact of these changes, or how to implement them, please contact our regulatory specials here at
ICC Compliance Center by calling 1-888-977-4834 (Canada) or 1-888-442-9628 (USA).