On March 10, 2012, Transport Canada published a proposed amendment to the Transportation of Dangerous Goods Regulations (TDGR) in Canada Gazette 1. This amendment, called Amendment 11, will, when finalized, address a number of problematic points in the current TDG System.
The significant changes proposed in Amendment 11 include the following:
- The definition of “person” will be changed for clarity, and a definition of “organization” will be added. This is to align with the meanings already established in the Transportation of Dangerous Goods Act (TDGA), in 2009.
- Section 1.15, the “150 kg exemption”, is proposed to be changed allow for easier ransport of consumer-type aerosols. The proposed change will allow up to six aerosol containers to be transported in an outer packaging that is not UN specification. This fixes a problem introduced in Amendment 6; the current regulations allow most products transported under these provisions to be transported in non-standardized packaging, but does not exempt Class 2 materials. This was aimed at requiring cylinders to be tested and certified, but aerosols were not given an exception for their outer packagings. Companies that use section 1.15 to transport small, consumer-type aerosols are currently required to obtain a permit that exempts them from this requirement.
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On June 28, 2010, Transport Canada issued an Advisory Notice about hot air balloons. This notice addresses two (2) issues with the Regulations:
- an exemption
- cylinder compliance
1. Exemption: Section 1.27 Operation of a Means of Transport or a Means of Containment Exemption of the TDG Regulations does provide an exemption for propane cylinders. The catch is that the hot air balloon must be flight-ready and the cylinders are attached to the hot air balloon. Once the cylinders are removed from the hot air balloon for refill or the hot air balloon is not flight ready, such as when transporting the hot air balloon in a trailer, the exemption no longer applies.
2. Cylinder compliance: in TDG, Section 5.10 Means of Containment for Class 2, Gases requires the selection and use of cylinders in accordance with the Canadian Standards Association (CSA) standard B340. In addition, the manufacture of the means of containment (cylinder) must be done in accordance with CSA B339.
CSA B340 Selection and Use of Cylinders, Spheres, Tubes, and Other Containers for the Transportation of Dangerous Goods, Class 2: this standard covers the safety requirements for selecting and using cylinders for the transportation of dangerous goods in Class 2. It also covers the requirements for filling and handling of cylinders for Class 2 dangerous goods.
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