Have You Made Your TDG Updates Yet?
The holiday rush for 2014 is over. Our parties have been held, and our gifts are unwrapped and appreciated. But if you’re a dangerous goods shipper or carrier, you can’t relax just yet. New requirements from Transport Canada become mandatory, January 15, 2015. So, it’s time to make sure that everything in in compliance with the new system.
Back on July 2, 2014. Transport Canada issued two amendments to the Transportation of Dangerous Goods Regulations (TDG). One was called the Safety Mark Amendment, and the second was the Update of Standards Amendment. Both will have important effects on dangerous goods shipping procedures, and will need to be addressed immediately if you want your shipments to remain in compliance.
If your organization hasn’t already done so, it will need to review these amendments and make all necessary changes as soon as possible. Here are some of the most critical changes:
- Non-bulk packaging must now be selected for ground shipment using a standard published by Transport Canada, called Transport Canada Standard TP14850E, “Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and, 9, a Transport Canada Standard.” Note that this is available as a free download from the Transport Canada site at http://www.tc.gc.ca/publications/en/tp14850/pdf/hr/tp14850e.pdf
- Consignors of dangerous goods must keep on file a “proof of classification” for all dangerous goods they offer for transport. Details on what is required for this proof can be found in TDG section 2.2.1.
- Safety marks must be updated to current United Nations standards. For example, the all-yellow Division 5.2 label has been retired; if you are shipping organic peroxides, you must use the new red-and-yellow version for Division 5.2. Also, Marine Pollutant marks must be updated to the new diamond shape, as the older triangle marking is now obsolete.
- The placarding rules have been revamped significantly. For example, certain classes such as Division 4.3, Dangerous When Wet, must be placarded for any amount, rather than using the 500 kg placarding exemption. Also, new restrictions have been put on the use of “Danger” placards.
- Large containers carrying bulk packagings such as tote tanks must now display all class placards and UN numbers that are required on the packagings inside.
- The Limited Quantity provisions of section 1.17 have been updated so that it is no longer necessary to include the words “Limited Quantity,” “LTD. QTY.” or “Consumer Commodity” on shipping papers when offering limited quantities for transport.
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On November 16, Transport Canada published proposed changes to certain safety standards in the Transportation of Dangerous Goods (TDG) Regulations. These changes can be found in Canada Gazette I, and may be accessed online at http://gazette.gc.ca/rp-pr/p1/2013/2013-11-16/html/reg5-eng.html.
It may appear at first that these are merely technical changes and updates. Transport Canada says that the main reason for the amendment is that some of the standards need their references updated to the most current version, and some of them need to be introduced for the first time. However, if the amendment is finalized in Gazette II, some of the implications are significant for Canadian shippers and carriers.
The principle points behind this amendment are:
- Several new standards must be introduced in order to enhance compliance with the UN Recommendations in their current form. This means including standards for packagings such as cylinders (which currently have a TC (Transport Canada) specification), and UN-specification portable tanks. This will ensure that Canadians are using the most harmonized, as well as the most modern, packaging standards.
- A number of the existing standards referenced in TDG are not referenced in the most current version. For example, the current regulation has a reference for CSA Standard B339-08, “Cylinders, spheres, and tubes for the transportation of dangerous goods”, last amended in February 2005. The amendment will update this reference to the version published in March 2008.
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So, you want to bend the rules? What happens when you have a scenario where following the regulations to ship your dangerous goods becomes impractical to the point of impossibility?
This blog entry will speak to what the process is for applying for an Equivalency Certificate in Canada as per the Transportation of Dangerous Goods Clear Language Regulations.
Generally when people ship dangerous goods, the process becomes a matter of reading and complying with everything the regulations state. However, below are some scenarios where following exactly what the regulations state is… shall we say… less than ideal.
Al wants to ship some large batteries for equipment within Canada with classification:
UN 2794, Batteries, Wet, Filled With Acid, Class 8, P.G. III
His dilemma is that when a new battery is commissioned, the outer package is generally discarded due to space limitations. In many cases these batteries were installed prior to the packaging requirements of Part 5 of the TDG Regulations.
Al wants to ship this without UN approved packaging.
Bill wants to ship a MRI machine that contains liquid helium, classification:
UN 1963, Helium, refrigerated liquid, Class 2.2
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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.
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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.
The new safety marks to be introduced are:
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.
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