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Batteries or Piles? A Bilingual Quirk in the TDG Regulations

Batteries or Piles? A Bilingual Quirk in the TDG Regulations

If you work with lithium batteries in Canada, you’ve probably noticed a quirky little difference between the English and French versions of the Transportation of Dangerous Goods (TDG) Regulations.

In English, the shipping descriptions for lithium items use the term “lithium batteries” even when the package contains only cells. The English version doesn’t distinguish between cells and batteries when it comes to shipping descriptions; everything ships under the entry “batteries”, regardless of what is actually inside the package. That’s how the regulations are written.

But in French, the same shipping descriptions use the word “piles”, which, when directly translated, means cells, not batteries. The French version doesn’t reflect the same distinction between single cells and assembled batteries it uses “piles” across the board, even when referring to complete battery packs.

It’s a small but important nuance. If you’re used to thinking in one language, the other might throw you off — especially when completing bilingual shipping documents or interpreting regulatory texts.

This little observation came up during a presentation I was giving on the transportation of lithium batteries. The question was raised by a bilingual participant who understood the technical difference between a cell and a battery, and it sparked a great discussion about how language can subtly change how we interpret regulatory requirements.

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Elton Woodfine

Elton Woodfine CD (Canadian Decoration) served 22 years as a member of the Canadian Forces. Initially as an Infantry section Commander in the Princess Patricia Canadian Lite Infantry (PPCLI), he served on two peace keeping missions in the former Yugoslavia, and one combat tour in Afghanistan where his unit was awarded the Governor General Unit Citation for actions in combat. He then continued to serve as a member of the Royal Canadian Air Force as a firefighter, where he completed a diploma in Fire Science/ Fire-fighting from Memorial University and Occupational Health and Safety diploma from the University of New Brunswick. Lastly, in his career with the Canadian Forces, he served as a member of the Joint Incident Response Unit (CJIRU) as a Chemical, Biological, Radiological and Nuclear Operator (CBRN Op), part of the Canadian Special Operation Command (CANSOFCOM). Upon his retirement from the Canadian Forces, he took a position as a Life Cycle Management of hazardous materials instructor for the logistical branch of the Department of National Defense and is knowledgeable in NFCC, CEPA 1999, IMHWR, TDGR, ICAO, IATA, IMDG, GHS and OH&S federal regulations.