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
Time flies. Can you believe that it has been 20 years since RSPA (now PHMSA) published docket HM-126F regarding training?
Final rule HM-126F is now incorporated into the 49 CFR regulations Part 172 Subpart H. Subpart H stipulates that:
A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart
Employees may not perform functions without appropriate training
Training may be provided by the hazmat employer or other public or private sources
A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the topics covered
Hazmat employee training must include the following:
General awareness/familiarization training
Security awareness training
In-depth security training
Often times both function-specific and in-depth security training is better done onsite by the employer. It is the employer’s responsibility to certify that the hazmat employee can perform their job, and do so safely.
For more than 25 years, ICC has provided companies with training that complies with these regulations. We offer training that complies with the general awareness/familiarization, security awareness, safety and some function specific topics.
Ask us about our scheduled public training for ground, air or ocean at our facilities across North American. We also offer GHS training, and new OSHA compliant safety training.
Call 888.442.9628 for more information. Have a problem? We have a solution.
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:
Any substance that would require an ERAP if its classification were determined in accordance with Part 2, Classification, requires an approved ERAP if its classification from the ICAO Technical Instructions, the IMDG Code or the UN Recommendations is used as permitted under section 1.10 of Part 1, Coming Into Force, Repeal, Interpretation, General Provisions and Special Cases.
For example, as the consignor, you have an IBC (1,500 L) of sodium cyanide solution, UN3414 to ship. As UN3414 is not listed in TDG, you go to the model regulations for the classification. But the model regulations don’t have an ERAP index, so how do you determine if an ERAP is required? Or, you have 2 x 20 L drums of iodine, UN3495, to be shipped and you use the TIs for your classification. The TIs don’t have an ERAP index, so how do you determine if an ERAP is required?
To determine if an ERAP is required for your shipment where the classification is not in TDG, go to: http://www.tc.gc.ca/eng/tdg/clear-newerapnumbers-87.htm and scroll to the table at the bottom of the page to see if your product is listed and what the ERAP index is. Please bear in mind that all the requirements of Part 7 apply to the numbers listed in this table.
At the United Nations, the Sub-Committee of Experts on the Transport of Dangerous Goods (TDG) have unanimously granted observer status to the Dangerous Goods Trainers Association (DGTA).
This means, that as a non-governmental agency (NGO), DGTA will be able to contribute and comment on proposals and changes to the model regulations. Members of DGTA will be able to share their vast wealth of knowledge and experience with this regulatory body.
Dr. Bob Richard (Labelmaster) was insturmental in writing up the application and presenting at the UN. The chair of DGTA, Leif Soderman (Optimal Assistans Sweden), will be representing DGTA at the TDG meetings.
So, what’s going to be coming in TDG in the next year?
Well, let’s start with an Equivalency Certificate for limited quantities. Members of the Canadian Paint and Coatings Association have an Equivalency Certificate (http://www.tc.gc.ca/tdg/permits/htm/10832-eng.htm) for the use of the new limited quantity mark. If Transport Canada is not going to have this in a very near future amendment, then why don’t they issue the Equivalency Certificate to all shippers?
Amendments 8, 9 & 10 have come into force this year. Amendment 11 was sent to the Minister on October 20 and it deals with correcting errors in Amendment 6. The next step for Amendment 11 is a consultation phase.
Amendment 12, which was reviewed last June, is a large amendment with emphasis on placarding and introduces the overpack. The comment review was completed in June and it may go direct to Gazette II.
Amendment 13 will deal with the standards and Part 5 Means of Containment. This proposal has been at Justice since June and its next stop should be Gazette I.
Amendment Q will be an update of Schedule 1 and 2. Amendment 12 was to take us to the 17th Edition of the UN Recommendations on the Safe Transport of Dangerous Goods, so why would a separate amendment be needed for the Schedules? Interesting that Schedule 3 is not listed in this proposal – typo? The next step for this amendment is consultations.
The Surface Inter-modal Security (SIMS) directorate is still in the policy development phase. They have indicated a combined use of voluntary practices and regulations that will be phased in over a reasonable time period. In addition, harmonization with the US will be key, but there will be some unique Canadian situations.
The one thing we do not have are target dates for each of the above.
The Auditor General will be releasing his findings on December 13th on the ERAP programme.