TDG Update – Regulations Amending the Transportation of Dangerous Goods Regulations (Update of Standards)

On July 2, 2014, Transport Canada issued its amendment regarding updating the Transportation of Dangerous Goods Regulations (TDG) to reflect recent international standards, and to incorporate some new packaging standards. This amendment is intended to harmonize Canada’s regulations more fully with those used for international shipment, therefore simplifying international transport and improving safety. Please note that is a separate amendment from the one issued at the same time regarding safety marks.

The first thing you’ll notice in this amendment is the table in section 1.3.1, Table of Safety Standards and Safety Requirement Documents, has been extensively revised. Many standard references have been updated to more current versions; one of the most significant updates is the new reference to the Seventeenth Edition (2011) of the UN Recommendations on the Transport of Dangerous Goods. Also, some standards have been deleted, such as CAN/CGSB 43.150, “Performance Packagings for the Transportation of Dangerous Goods,” from the Canadian General Standards Board. Instead, new standards such as Transport Canada Standard TP14850, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and 9” have been added. This will bring in a whole new system for selecting packagings for these classes. Other new standards will introduce UN packaging provisions for portable tanks and rail containers.

Not all standards have been updated; note, for example, that CAN/CGSB 43.125, “Packaging of Infectious Substances, Diagnostic Specimens, Biological Products and Biomedical Waste for Transport”, still references the 1999 standard, not the subsequent updates to it.

Many international shippers will be alarmed at the repeal of section 1.10, which had allowed the use of shipping descriptions from the UN Recommendations, ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, and the IMDG Code. This has been invaluable in allowing people to ship using descriptions which were not yet in Schedule 1 of TDG. Fortunately, in the new amendments, provisions for using international descriptions can still be found in section 2.2(4).

One of the most significant changes to the current regulations will be the addition of a new section in Part 2, Classification. This section, 2.2.1, requires all consignors who turn dangerous goods over to carriers or who import dangerous goods into Canada, to keep a “proof of classification” available to Transport Canada. This proof can include:

  • a test report;
  • a lab report, or
  • a document that explains how the dangerous goods were classified.

The documentation must be maintained by the consignor for at least five years.

Another major change can be seen in Part 3, Documentation. A new section, 3.6.1, will require, as of July 15, 2015, that all shipping papers include a signed certification. For shipments not certified under other regulations, the wording must be:

I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, are properly classified and packaged, have dangerous goods safety marks properly affixed or displayed on them, and are in all respects in proper condition for transport according to the Transportation of Dangerous Goods Regulations.

This certification must be signed or authorized by the consignor, or an individual acting on behalf of the consignor. It  does not, however, have to be a written signature; the document must only “set out that individual’s name.” This requirement does not apply when returning large means of containment that contained dangerous goods, but which have not been cleaned or purged.

Part 5 of TDG, Means of Containment, has been extensively revised to refer to the various new packaging standards, and how to use them to select appropriate packaging. One point of interest is that the packaging requirements for UN1950, AEROSOLS, will now also apply to UN2037, GAS CARTRIDGES. Note that the new TC packaging standards, such as TP14850, will be available for free as an online resource, as compared to the CGSB or Canadian Standards Association (CSA) standards, which must be purchased.

A number of minor changes have been made in the modal parts, Parts 9 to 12. For example, the provisions for shipping goods by air under the ICAO provisions for consumer commodities have been updated to refer to the current packing instruction Y963 rather than the obsolete instruction 910.

Schedule 1 has been modified in a few places, mostly by adding or removing Special Provisions. The entry for UN3166, ENGINES, INTERNAL COMBUSTION (FLAMMABLE GAS POWERED) or ENGINES, INTERNAL COMBUSTION (FLAMMABLE LIQUID POWERED), has been expanded to include vehicles, and also to include machinery powered by fuel cells.

In Schedule 2, Special Provisions 26, 80, 81 and 89 have been removed. Special Provision 90 has been added, regarding fuels such as gasoline or fuel oil transported in welded tanks. Another addition is Special Provision 92, which requires those who ship UN1267, PETROLEUM CRUDE OIL, and UN1268, PETROLEUM DISTILLATES, N.O.S., to classify these goods on the basis of samples, and keep information on the sampling procedures available for Transport Canada.

Text of the amendment can be found here. The regulations come into force on July 15, 2014, and there will be a six month transitional period, ending January 15, 2015

If you have questions about the impact of these changes, or how to prepare for them, please contact our regulatory specialists or give us a call at 1-888-977-4834 (Canada) or 1-888-442-9628 (USA).

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