Transport Canada has posted a bulletin for shipping infectious substances (RDIMS#8210418).
In the overview, Transport Canada reviews what an infectious substance is: anything that is known or reasonably believed to cause disease in humans or animals. This substance can be in blood, body fluids, body parts, organs, tissue or cultures. The responsibility of the consignor is to: train, classify, package, mark/label, document, placard and have an ERAP in place, if necessary. In addition to the definition found in section 1.4 of TDG (Transportation of Dangerous Goods Regulations), the Public Health Agency of Canada (PHAC) has regulations that apply to lab safety and the import of human pathogens into Canada. Please keep in mind that provincial governments may have additional regulations in place.
Classification of infectious substances is generally done by a medical professional. If you know that what you want to ship is an infectious substance, then it is class 6.2. In TDG, under Appendix 3 in Part 2 is a listing of regulated infectious substances. This list is not exhaustive. If what you want to ship is not on the list, but exhibits the characteristics of an infectious substance, then it is class 6.2.
The authorized shipping names in TDG are:
UN2814 Infectious substance, affecting humans,
UN2900 Infectious substance, affecting animals
UN3373 Biological substance, Category B
UN3291 Clinical waste, unspecified, n.o.s., (Bio)Medical waste, n.o.s., or Regulated medical waste, n.o.s. are not listed in TDG. These shipping names can be used utilizing section 1.10 of TDG. It is recommended to use Type 1C packaging.
When shipping infectious substances, you must do so in compliance with TDG. When shipping by air, you must use the ICAO Technical Instructions and by sea, the International Maritime Dangerous Goods Code (IMDG). Please note that competent authority approval may be needed.
There are exemptions available for shipping within Canada:
section 1.39 – Class 6.2, Infectious Substances, Category B Exemption
section 1.41 – Biological Products Exemption
section 1.42 – Human or animal Substance Believed not to Contain Infectious Substances Exemption
section 1.42.1 – Tissues or Organs for Transplant Exemption
section 1.42.2 – Blood or Blood Components Exemption
Quick reference guide for road transport
Infectious Substance, Affecting Humans
Infectious Substance, Affecting Animals
Biological Substance, Category B
UN2814 or UN2900 if waste contains Category A.
UN3291 if waste contains Category B.
Type 1B (only in certain instances. Refer to TDG 5.16)
Type 1A, or
Type 1B, or
No, if shipped in accordance with the exemption in TDG 1.39
The Alberta government has issued Industrial Railway Circular No. 1 (Guideline for the Transfer of Dangerous Goods to or from a Railway Vehicle).
Although only a 7 page document, there are 11 sections:
Primary selection criteria
Additional selection criteria
The guideline falls under the Railway (Alberta) Act and applies to companies that intend to transfer dangerous goods to or from a railway vehicle. This circular does not apply to Class 1 Explosives. These must be handled under the Federal Handling of Carloads of Explosives on Railway Trackage Regulations.
Railways that intend to construct or connect railway track to a service provider or construct railway works must have approval from the provincial government. Site selection is done in accordance with sections 4 and 5, and if the criteria cannot be met, the application may still be considered if an equivalent level of safety can be demonstrated.
The guideline suggests a dangerous goods transfer track/rack should meet minimum distances from residences, commercial establishments, schools, hospitals, recreation centres, etc..
Dangerous Goods Class
3 excluding inhalation hazard materials
4.1 molten sulphur
5.1 excluding inhalation hazard materials
6.1 excluding inhalation hazard materials
In addition, the site shall not be located next to busy highways, under a bridge or overpass, next to transformers, power lines, sources of ignition, etc.. The site shall be located so that emergency responders can access it as well as be near an emergency water source.
A company that intends to transfer dangerous goods from or to a railway vehicle must have operating approval from the Alberta Transportation Railway Administrator.
A competent person who is trained in the Transportation of Dangerous Goods Regulations and is familiar with this Circular and the Industrial Railway Regulations must make periodic inspections looking for leaks, and if found, knows who to notify. Written records of all inspections must be kept for two (2) years after the rail cars have been released from holding.
A person who will be loading, unloading or transferring dangerous goods must be trained in the Industrial Railway Employee Qualification Standards. This person must also have a working knowledge of tank cars, fittings, products being transferred, and placarding requirements. This person must ensure that the correct documentation is provided to the carrier. In the event of an emergency involving dangerous goods, the person must provide emergency response information.
In the event of an incident or leakage of dangerous goods, CANUTEC, the local RCMP and the Alberta Transportation Coordination and Information Centre (1.800.272.9600) must be notified.
Regulatory requirements for loading of dangerous goods include:
ensuring all fittings and safeties are in proper condition
bottom discharge outlets must have caps and plugs removed
tank cars with heater coils must have inlet and outlet caps removed
sufficient ullage must be in the tank car
Regulatory requirements for loading or unloading of dangerous goods include:
dangerous goods that have a primary or subsidiary class of 2.1, 3, 4 or 5 must be grounded/bonded to prevent exposure to ignition sources or static electricity
hand brakes applied, 1 set of wheels blocked/chocked in both directions
track protection using locked switches or derails
use of caution signs set at either end of the track
keeping the immediate area free of combustible and other non-compatible materials
January 15, 2013 – 1 person dead, 45 injured on the E4 motorway in Sweden involving 100 vehicles. Preliminary investigation shows three transport trucks collided that created the chain reaction.
January 25, 2013 – 3 people injured seriously in approximately 60-80 vehicle collision on Highway 401 near Newtownville. Looking at the pictures in the link below, how is it someone wasn’t killed? Some reports have a transport truck jackknifing as the initial cause.
In both these accidents, visibility was poor, yet operators were not driving according to the road conditions.
Some jurisdictions (like Quebec) have made snow tires mandatory. And some in Sweden are calling for mandatory high-spec winter tires for trucks. But if the operator is not driving according to the road conditions, what’s the point?
Why is it that people feel the need to be on the road when the road conditions and visibility are poor? And when they are out there, the windows are not cleared of snow, the windscreen is fogged up and they drive like the roads are dry.
To all operators (passenger and transport), can we do the following:
prepare for the road and weather conditions
have properly inflated tires
full washer fluid container (including good wipers)
full fuel tank
all windows clear of snow, ice and fogging
ALL lights on
have emergency supplies – blanket, candles, first aid kit, snack bars, water, etc.
SLOW down, it’s not a race
And above all, look down the road, not your hood. Watch for changing weather conditions. Get off the road and wait it out if necessary. Keep an eye on the other guy and increase your distance. Look for the “out” so you can avoid the accident. All accidents are avoidable. Don’t become a statistic.
Transport Canada published in Canada Gazette, Part I, the amendment titled “Part 4 Dangerous Goods Safety Marks”. Notable changes include:
introduction of overpacks
modifications to the use of the DANGER placard
introduction of new safety marks (3)
new proposal for placarding large means of containment
Let’s start with the overpacks. Currently under TDG, overpacks are not recognized although they are being used. And this is causing enforcement issues. TC considers an overpack to be a large means of containment. The definition for overpacks will be added to section 1.4 of TDG. Safety marks for overpacks is covered in section 4.10.1. As part of this section, when the overpack has a capacity ≥ 1.8 m3, then safety marks must appear on two opposite sides of the overpack.
All the safety marks are in the UN Model Regulations, ICAO Technical Instructions, IMDG Code and 49 CFR.
The requirements for placards will undergo a major change. The table in TDG section 4.15 is replaced. Placards will be required on both ends and sides of a large means of containment. The subsidiary placard requirements do not change. UN numbers on a placard or orange panel will be required when an ERAP is required, or the dangerous goods are liquids or gases in bulk. IBCs (intermediate bulk containers) will be permitted to only have 2 placards with UN number on opposite sides, or a label and UN number on each side. This will remove the need for equivalency certificates. However, placards with UN numbers will be needed on the outside of the truck.
The use of the DANGER placard changes as well. The DANGER placard can be displayed in place of hazard class placards when there are 2 or more classes and there are 2 or more small means of containment. The current restrictions for the use of the DANGER placard do not change, but those restrictions now include:
gross mass not to exceed 1,000 kg,
not to include only one hazard class, and
are offered by one consignor at one location.
The 500 kg requirement for placards is found in section 4.16.1 with the restrictions being very similar to the restrictions currently found in the exemption 1.16 500 kg gross mass exemption. If any part of a shipment involves a restriction that is listed, then that amount is not used in the calculation for determining placards. For example, if a shipment consists of 2,300 kg of dangerous goods, with 2,000 kg being sodium, then that shipment will require the hazard class placard with UN number as it requires an ERAP. The remaining 300 kg, being under the 500 kg, will not require placards.
The wording of section 4.22.1 for the Category B mark has been changed to read that the Category B mark replaces the Class 6.2 hazard label.
For dangerous goods that are subject to special provision 23, it will now be required to add the words “toxic – inhalation hazard” next to the shipping name for small packages, and on the large means of containment, in addition to any required placards.
The purpose of this amendment is harmonize with the international regulations as well as with 49 CFR. There may be additional costs to carriers for implementing these changes, but TC is of the opinion that for carriers who do business in the US, they will already have the additional placard holders on their trucks.
Transport Canada has given 75 days for comment from December 1, 2012. Comments are to be sent to:
Genevieve Sansoucy, Legislation and Regulations, Transport Dangerous Goods Directorate, Department of Transport, Place de Ville, Tower C, 9th Floor, 330 Sparks Street, Ottawa, Ontario K1A 0N5 (tel.: 613-990-5766; fax: 613-993-5925; email: TDGRegulatoryProposal-TMDPropositionReglementaire@tc.gc. ca).
Transport Canada published Amendment 11 in the Canada Gazette, Part II on December 5, 2012. In Amendment 6 (February 2008), a number of errors were introduced. This amendment corrects those errors, and brings others into line with some changes to the Act (June 2009).
The changes in this amendment are:
definition of “person” now aligns with the definition in the Act, including the addition of “organization”,
section 1.15 150 kg Gross Mass Exemption has been changed to allow up to 6 aerosols to be transported without complying with Part 5 Means of Containment. However, the aerosols must have a valve protection cap; in addition, special provision 80 has been changed to provide consistency,
section 5.5 Filling Limits goes back to the wording prior to Amendment 6 so as to remove any confusion and misinterpretation regarding standards or safety requirements,
the placarding provisions of the IMDG Code have been placed in Part 9 Road and Part 10 Rail; this allows for the placarding under the IMDG Code which means that placarding requirements are simpler and will reduce if not eliminate confusion,
other changes are of an editorial nature or typo:
in section 2.29(2)(c), 0.2 g/L now reads 0.2 mg/L
in the restricted paragraphs of section 1.15 and section 1.16, the title for Class 4 has been corrected
in section 1.32.1, the shipping name Liquefied Petroleum Gas now reads Liquefied Petroleum Gases
table of contents for Part 2 Classification now shows Category A and Category B instead of risk groups
in part 2, appendix 3, item 3, the word “formerlly” is changed to read “formerly”
section 1.32.2 Gases, Absolute Pressure between 101.3 kPa and 280 kPa now reads 1.32.2 Class 2, Gases, Absolute Pressure between 101.3 kPa and 280 kPa
in section 1.47 UN1044, Fire Extinguishers, Exemption, “and (d)” is added after “Paragraphs 5.10(1)(a)(b)”
Although these changes come into force on December 5, there is a transition period of six months (June 5, 2013) before all the changes become mandatory.