Transport Canada Unveils Proposed Amendment to Safety Standards

On November 16, Transport Canada published proposed changes to certain safety standards in the Transportation of Dangerous Goods (TDG) Regulations. These changes can be found in Canada Gazette I, and may be accessed online at http://gazette.gc.ca/rp-pr/p1/2013/2013-11-16/html/reg5-eng.html.

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:

  1. 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.
  2. 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.
  3. Currently, there is a standard for the approval of non-bulk UN-specification packaging (CAN/CGSB-43.150-97. “Performance Packagings  for Transportation of Dangerous Goods”). However, this standard does not give significant guidance for shippers to select an appropriate package for a specific substance. Several years ago, Transport Canada proposed a standard for this purpose, known as TP14850, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8, and  9, a Transport Canada Standard”; however, it has not been implemented into  Canadian regulations yet. This amendment will establish the standard to  enhance compliance with other regulations, reduce the requirements for  equivalency certificates, and to general improve safety in packaging.
  4. The TDG Regulations allow the use of certain other regulations, such as the Hazardous Materials Regulations of Title 49 of the Code of Federal Regulations (49 CFR), the International Maritime Dangerous Goods Code (IMDG), the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, and the UN Recommendations for the Transport of Dangerous Goods. However, these are referenced to specific editions or years (for example, the UN Recommendations are referenced to the 14th Revised Edition, which was published in 2005). This has led to problems in harmonizing with international regulations. The references will be updated to more recent versions; for example, the reference to 49 CFR will be the version from 2010.
  5. Packaging standards for aerosol containers will be updated, and will now also cover UN2037, GAS CARTRIDGES.

This amendment may, based on its size in the Canada Gazette, appear to be rather small. However, because the amendment references such a large number of supporting documents, changes may be effected that are not immediately apparent. For example, TP14850 includes detailed instructions on how to verify compatibility between the packaging and the substance transported.

Canadian stakeholders should consider the implications of these amendments to their operations. Transport Canada has given interested persons 75 days after the date of publication to make Comments, which should be addressed to:

Geneviève Sansoucy
Analyst
Regulatory Affairs Branch
Transport Dangerous Goods Directorate
Department of Transport
Place de Ville, Tower C
330 Sparks Street, 9th Floor
Ottawa, Ontario
K1A 0N5
Telephone: 613-990-5766
Fax: 613-993-5925
Email: TDGRegulatoryProposal-TMDPropositionReglementaire@tc.gc.ca

OR:

Stéphane Garneau
Superintendent
Intermediate Bulk Containers and Small Means of Containment
Regulatory Affairs Branch
Transport Dangerous Goods Directorate
Department of Transport
Place de Ville, Tower C
330 Sparks Street, 9th Floor
Ottawa, Ontario
K1A 0N5
Telephone: 613-991-3151
Fax: 613-993-5925
Email: TDGRegulatoryProposal-TMDPropositionReglementaire@tc.gc.ca

If you have any questions that ICC The Compliance Center Inc. can assist you with regarding this amendment, or other TDG-related questions, please contact us at 1-888-977-4834.

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