The New Placarding Exemption for Dangerous Goods Having a Gross Mass of 500 kg or Less (TDG 4.16.1)
When I read a comment from Lynn in the “TDG Amendment 12 FAQs” comments section, my first response was to scratch my head and think to myself, “good point.”
She essentially asked:
Why can’t one use the 4.16.1 Exemption with 480 kg of Class 9, and 405 kg Class 2.2, all of which are in small means of containment on the same road vehicle at the same time? Each of these items separately are under 500 kg.
I went back to the regulations (Amendment 12 – Dangerous Goods Safety Marks) and after reading through with the fine-toothed comb, I’ve figured out an answer, and before writing this I’ve run it by Transport Canada to confirm. Let me start off by quoting what I originally wrote in the Q&A for the first “TDG Amendment 12 FAQs” blog. I made a mistake and left out a caveat.
If we analyzed another situation with 2000 kg of item A and 300 kg of item C, we would only need the class placard for item A since item C would fall under the new 4.16.1 Placarding Exemption for Dangerous Goods Having a Gross Mass of 500 kg or Less. The exception would be if item C was on the list of items that always needs placards listed in 4.16(2)
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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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