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Regulatory Blog | ICC » ERAP

ERAP Changes Potentially Extend Beyond Rail Tankers

by Clifton Brown on January 12, 2015 at 1:36 pm · in Clifton's Blog, Transportation of Dangerous Goods

erap-changes-potentially-extend-beyond-rail-tankers

Are You Implicated?

Wording of amendment includes highway tankers, IBC, for UN1993, etc.

Recently, I wrote about the December 31 (SOR/2014-306) amendment to the TDG regulations, which contained a change to the substances requiring an ERAP (TDG-approved Emergency Response Assistance Plan) under Part 7.

As worded, the ERAP obligation extends to consignors of the specified flammable liquids in any shipment  of an accumulation of large means of containment (LMOC) i.e. capacity exceeding 450L) exceeding 10,000 L or any individual LMOC containing more than 10,000 L.

The intent was to incorporate the ERAP requirement for petroleum/petroleum-like products being shipped by rail tanker as contemplated in the post-Lac-Mégantic Protective Direction 33.

This was clearly stated in the Regulatory Impact Statement accompanying the Gazette II notice.

[What follows, by way of disclaimer, may seem like a bit of a regulatory wonk’s snore- but it does illustrate the importance of keeping aware (and sometimes involved) in regulatory aspects of your business. Onward.]

A similar provision was already in place for things like gasoline (UN 1202) by means of a Special Provision (rather than a direct trigger quantity) in Column 7 of Schedule 1. This Special Provision 82 bypassed the normal criteria of section 7.1(1) & (3), invoking 7.1(6) limiting the rail tanker criteria as applicable to the 3 designated UN numbers.
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Ebola Outbreak Puts Stress on Shippers of Infectious Substances

Ebola Outbreak Puts Stress on Shippers of Infectious Substances

The headlines are frightening – Ebola virus, one of the most deadly viruses known, has broken out in several African countries. Medical authorities are concerned that it could spread beyond that region, carried by travellers all over the world. Laboratories in North America and Europe are on alert for patients showing suspicious symptoms. This, in turn, means that samples and specimens must be transported for testing and verification. How can the medical community deal with transportation of such high-risk materials?

Shipping biological substances training »

Ebola virus is considered a “hemorrhagic fever,” which affects the blood system. Its virulence is astonishing, with a fatality rate of between 50 and 90 percent. Combine this with the ability to be transmitted through casual contact, and the lack of specific vaccines or treatment, and it’s understandable why Ebola is such a feared disease. Therefore, it is all the more essential that transporters make sure that they comply with all legal and safety requirements.

Ebola virus is one of the few pathogens that is always classed as a Category A infectious substance, even in its uncultured form. The shipping description will be:
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ERAP – When?

by ICC Compliance Center on January 26, 2012 at 8:00 am · in Jim's Blog, Regulations

One of the conundrums of the Transportation of Dangerous Goods Regulations (TDG) is the requirement to have an ERAP for a UN number that is not listed in Schedule 1 of TDG.

The problem we run into is that Schedule 1 is only up to the 11th Edition of the UN Recommendations on the Safe Transport of Dangerous Goods (model regulations). In section 1.3.1, item 39 in the table of standards indicates that TDG is at the 14th Edition of the model regulations. But since the 13th Edition of the model regulations, the UN has issued over 130 new classifications.

But section 1.10 of TDG states:

A person may use the appropriate classification set out in the ICAO Technical Instructions, the IMDG Code or the UN Recommendations to transport dangerous goods within Canada by a road vehicle, a railway vehicle or a ship on a domestic voyage if these Regulations or the document from which the classification is taken does not forbid their transport.

This means that if the consignor cannot find a classification in TDG, then the consignor can use a classification from the model regulations, ICAO Technical Instructions (TIs) or the IMDG Code. And this is where the conundrum lies. TDG section 7.1(12) states:
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Transport Canada Issues Amendment 10 to TDG

by Barbara Foster on October 24, 2011 at 8:00 am · in Barbara's Blog, Industry News, Regulations

Transport Canada has recently issued Amendment 10, an update to Canada’s Transportation of Dangerous Goods Regulations. The text of this amendment can be found at http://www.gazette.gc.ca/rp-pr/p2/2011/2011-10-12/html/sor-dors210-eng.html.

This Amendment deals specifically with Emergency Response Assistance Plans (ERAPs), and compensation for situations where the government has invoked a plan in the event of a terrorist action. Costs that are eligible for compensation include:

  • the salaries and other compensation for employees and contractors;
  • the cost for tools and equipment used, including rental of equipment where necessary,
  • cost of replacing supplies, single-use equipment and other consumables,
  • travel expenses for personnel, including meals and accommodation,
  • expenses related to injury or death of employees or contractors, and
  • costs incident to cleanup after an incident, including handling and disposal costs for dangerous goods and contaminated materials.

In the event of a terrorist incident involving dangerous goods in transport, the Minister of Transport can invoke an ERAP, even if the ERAP is held by someone other than the consignor of the goods. The amendment is required to ensure that this does not place an undue economic burden on the owner of the invoked ERAP.

Other aspects of ERAPs, such as the quantities that trigger the requirement, have not been changed in this amendment. If you have questions about how Amendment 10 will affect ERAPs, please contact ICC The Compliance Center Inc at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).
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Regulatory news

by ICC Compliance Center on July 11, 2011 at 12:17 pm · in Jim's Blog, Regulations

Some topics that were discussed at the last Regulatory Affairs Committee meeting of the Canadian Association of Chemical Distributors (CACD www.cacd.ca).

  • The CACD board of directors has approved a new standing committee – Health and Safety; there will be more news about this committee as it comes together
  • CACD has re-branded and launched its new website at its 25th anniversary AGM which was held in St. John’s NF this past June
  • the Auditor General will be reviewing the TDG directorate and will include the emergency response assistance plan (ERAP) programme in the review; the objective is to determine if the programme has value to Canadians; in general, experience has shown that emergency responders do not make use of ERAPs.
  • the MACTDG met in May at which Amendment 12 was discussed and CACD’s response to this amendment were presented
  • the security group of Transport Canada may be announcing that they will harmonize with the US regarding security issues, which we will hear more about later this year
  • CACD’s voice has been heard (along with others) regarding the Generic Products Regulations that Health Canada and Environment Canada buried in the mercury containing products regulations; the government has withdrawn the proposed legislation
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