Although Amendment 8 was published in Gazette I in May 2009, Transport Canada (Dangerous Goods Directorate) has made changes due to comments received since May 2009.
Some of the changes are:
Part 16 Inspectors is revoked
Part 7 Emergency Response Assistance Plans (ERAP):
7.1(1) – now specifies a single means of containment, regardless of the size of the means of containment
7.1(2) – has had "small" deleted from means of containment and is the total quantity in all the means of containment
7.1(3) – the 10% rule is revoked and it is now back to the accumulation of large means of containment
7.1(5) – deals with Class 2 Gases where the means of containment is greater than 225 L and where there is more than 1 and interconnected and permanently mounted on a structural frame for transport
7.1(6) – changed to 17 rail cars that are interconnected and each rail car is filled to 70% or more
7.1(9) – now allows the use of another’s ERAP provided the shipper gets permission in writing to use that plan and the holder of the plan agrees to do the emergency response
7.1(10) – where permission is given to use another’s ERAP, the holder of the ERAP must notify the Director General that permission has been given and again when the permission is rescinded
7.1(11) – although a shipper has permission to use another’s ERAP, the shipper is still responsible for the emergency response assistance
Comments are to be sent no later than April 2, 2010 to:
Linda Hume-Sastre
Director, Legislation and Regulations
Transport Dangerous Goods Directorate (ASDC), Transport Canada
By one of the following options: Email: linda.hume-sastre@tc.gc.ca Fax: 613-993-5925 Surface mail: Place de Ville, Tower C, 330 Sparks Street 9th Floor, Ottawa, Ontario, Canada, K1A 0N5
Posted by
Jim Henry on
November 25, 2009
|
Filed under: Jim's Blog
Transport Canada has posted on its website two (2) proposed interim orders that will cover the Vancouver Olympics. The first one is titled "Interim Order Respecting the Transportation of Dangerous Goods Into, Through or Within Controlled Access Zones". This proposed interim order, once approved by the Governor in Council would expire on March 4, 2010. The order sets boundaries which creates the access zones.
does your company have an emergency response assistance plan (ERAP)?
has it been reviewed by Transport Canada?
do you use a third party provider to provide the technical information?
do you use a third party provider to respond to the incident site for remediation?
If you are using a third party for incident response, have you:
recently audited the provider?
ensured that they have the proper tools to handle your products?
provided training on your products?
ensured that they have the proper equipment, i.e. UN specification packaging, correct specification tankage, hoses, couplings, etc.?
checked that they are following the closure instructions for the UN specification packaging?
checked to make sure that they are providing the right technical information?
checked to make sure that they can respond to wherever the incident is?
Keep in mind that when there is a dangerous goods incident involving an ERAP, it is the ERAP holder who is held responsible for the emergency response.
The placarding saga continues. Transport Canada has issued an ALERT to explain (?) the options available when a large means of containment that requires placards is loaded into a large means of transport. So if we have 2 IBC’s (class 8 and class 3) to be shipped, our options are:
Option 1: for each primary class placard and UN number, duplicate on the outside of the truck.
TDG 4.15(2) is up for discussion again. Transport Canada is stating that a change to the regs is being considered and it should harmonize with 49 CFR.
Transport Canada is also suggesting that the "inspector community" should take the least restrictive of options available in TDG, i.e. return to using the DANGER placard.
Transport Canada has issued a discussion/consultation paper that contains 36 amendments. Some of these suggested amendments make sense, but the others are begging the question: just what is Transport Canada thinking?
The following proposed amendments to the Transportation of Dangerous Goods Regulations were presented by J.S. Bergeron, Regional Manager, TC at the Canadian Association of Chemical Distributors (CACD) semi-annual meeting recently:
Part 7 Emergency Response Assistance Plan: now with Justice, expect to see in Gazette I before year end,
Titled "Back to the Future": returning to pre-Amendment 6 for Section 4.15 Dangerous Goods Safety Marks on a Large Means of Containment: Placards and UN Numbers: correcting safety mark errors, etc. Consultation will be the end of November, early December,
Clean up of the standards; discussion centred on CGSB-43.147 Construction, Modification, Qualification, Maintenance, and Selection and Use of Means of Containment for the Handling, Offering for Transport, or Transporting of Dangerous Goods by Rail, & CGSB-43.126 Remanufacturing and Reconditioning of Drums Used for the Transportation of Dangerous Goods; adoption of rail standards; end of year?
Adopt the 15th Edition of the UN Model Regulations; harmonization of TIH’s (toxic inhalation hazards); early next year
Changes to Part 12 Air re: domestic provisions and isolated areas; there is an internal discussion at Transport Canada going on now.
Transport Canada has posted an Amendment 8 proposal on its website.
Here are some of the proposed changes:
Take the Transportation of Dangerous Goods Regulations to the 15th Edition of the UN Recommendations (model regulations), not including Chapter 1.4 (Security Provisions) and provision 7.2.4 (Security provisions for transport by road, rail and inland waterway). (about time)
Several changes to Part 3 Documentation and Part 4 Dangerous Goods Safety Marks in relation to Special Provision 23 where "Toxic Inhalation Hazard" must be added.
New Class 5.2 Organic Peroxides safety mark of the red top half and yellow bottom half will now be permitted with the safety mark becoming mandatory January 1, 2011. Continue reading »
