Transport Canada has issued a discussion/consultation paper that contains 36 amendments. Some of these suggested amendments make sense, but the others are begging the question: just what is Transport Canada thinking?

What makes sense:

• the correction of spelling errors, reference errors, etc.
• section 1.39 to exempt dangerous goods safety marks, namely the Class 6.2 label
• typos such as in 2.29(2)(c)(i) changing g/L to mg/L

What doesn’t make sense is:

• the changes to section 4.15
  • deleting 4.15(2) which means no placards with UN numbers on trucks with totes
  • deleting the references to the DANGER placard in the table
  • adding wording to “clarify” loading IBC’s on a flatbed truck
  • and now a “new” section, 4.15.1, for the DANGER placard, but where does the 1,000 kg rule come from? Who thought this one up? Well, this comes from US regs (49 CFR), which gives us reciprocity, so if we are going to do this, then why not leave 4.15(2) alone?
  • a subsection to the above outlining what situations are not permitted to use the DANGER placard. JUST WHAT IS THE PURPOSE OF THE DANGER PLACARD?
• section 4.9 goes back to pre-amendment 6, so this means we have one rule for applying placards and another for when to take them off – didn’t this section give inspectors problems and that’s why it was changed?
• a new section 4.9.1 on the DANGER placard which appears to allow leaving the placards up until the dangerous goods are removed

It appears that Transport Canada is giving a knee-jerk reaction to industry’s “concerns” on the placards. If Transport Canada is so concerned about safety, then instead of placarding the entire side of a truck, why not make use of the ERAP index? Either assign an index or adjust the values that are already there to deal with placards and UN numbers.

And why isn’t Transport Canada dealing with some of the “errors” in the current regulations?

• Section 1.15 needs to have the “user/purchaser” provision put in.
• Section 7.1 needs to have the “10% rule” removed and the accumulation of large means of containment put back.

These are more pressing issues – hello Transport Canada, anybody up there listening?