TDG Standards on the Move – Explosives Plus TP14850 & TP14877

TDG Update - Red and white semi truck on the highway

CGSB.43-151 Class 1 Explosives Draft Update

There have been some recent developments in 2 of the packaging standards of potential interest to the DG community involved with Canadian transportation.

  • TP14850- Class 3-6.1, 8 and 9 Small Packaging pre-publication 3rd Edition-Transition to CGSB
  • TP14877- Rail Transition to CGSB

CGSB-43.151 Explosives Packaging Standard

Transport Canada has provided notice of a consultation on a proposed update of the Canadian General Standards Board (CGSB) standard “Packaging, Handling, Offering for Transport and Transport of Explosives (Class 1),” CAN/CGSB.43-151.

The new edition, to replace the current 2012 edition, will update the list of UN numbers and packing instructions to align with the UN Recommendations 20th edition; and update references to other dangerous goods container standards.

Also proposed in the draft are packing instructions for UN large packaging (ELP) to supplement the existing standards for IBC and portable tanks.

New Canadian domestic packing instructions (CEP 01) for jet perforating guns, used in oil well completion, are also included in the draft. Previously packaging of these (UN0124 and UN0494) had to be authorized on a case-by-case basis as referenced in EP 01.

CEP 02 replaces the previous EP 17 for highway and portable tank transport.

In common with the recent approach in other Canadian standards, changes to the organization of information, as well as regulatory requirement updates and additional definitions are part of the draft.

New or clarified definitions are provided for “IM” and “IMO-type” portable tanks, the “IMDG Code,” “mobile process units (MPU),” and “set piece”.

Interested parties have until July 31, 2018 to submit comments by following the CGSB protocol. Transport Canada provides links to the protocol, and instructions for obtaining a copy of the draft, on their website:
http://www.tc.gc.ca/eng/tdg/clear-modifications-menu-261.htm

TP14850 – 3rd Edition June 2018

Transport Canada (TC) has finalised the 3rd Edition of the performance packaging standard for small means of containment (not exceeding 450 L volume capacity) for classes 3, 4, 5, 6.1, 8 and 9 dangerous goods (DG). In keeping with current TC practice, the title references the types of packaging – i.e. “Design, manufacture and use of UN Standardized drums, jerricans, boxes, bags, combination packaging, composite packaging and other packagings for the transport of dangerous goods classes …”

A significant enhancement in this final pre-publication version is the conditional waiver of the need to submit periodic re-test data for metal or plastic drums; or for plastic-in-metal or plastic-in-plastic composite containers. This exclusion is dependant on the registrant having a registered quality management system verified by a recognised Registration Organization.

The updated June 2018 3rd Edition (expected to be published by year-end) may, however, be short-lived.

Transport Canada plans to return the standard to the Canadian General Standards Board (CGSB), who developed and issued the pre-TP14850 version as CAN/CGSB-43.150. This will allow the adoption of the CGSB standard “as amended”. A quirk of the Statutory Instruments Act (§18.1) requires that this option cannot be used for documents issued by a federal government regulation-making authority accountable to Parliament, unless it’s done by an agency accredited by the Standards Council of Canada.

One final note on the proposed 3rd Edition is that references to “overpacks” have been removed. When TP14850 was initially adopted overpacks were not defined or addressed in the TDG Regulation (TDGR).

As overpacks are not strictly speaking part of the “standardized” packaging it was decided that reference to them was now inappropriate since they are defined in the TDGR. This may leave a slight gap (unless the TDGR addresses this in a future amendment), since the general prohibition on combining incompatible goods, in §12.8.9 of TP14850 2nd Ed., does not include overpacks in the corresponding §12.8.4 of the 3rd Ed. The references in the current TDGR (e.g. §5.4 “Loading and Securing”) do not really address the issue in the same way.

TP14877 – Rail Containers

The current review of this standard was the subject of an earlier blog,

Transport Canada has also indicated that the final version of the update to the standard for rail containers for dangerous goods will also be transferred to the CGSB- the notice is available at:

http://www.tc.gc.ca/eng/tdg/clear-modifications-menu-261.htm#TP14850

Look for the publication of the updated editions in a future issue of Canada Gazette Part II – or stay tuned to this Blog or sign up for or weekly newsletter using the form at the bottom of this page!

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