{"id":10569,"date":"2019-01-24T11:00:47","date_gmt":"2019-01-24T16:00:47","guid":{"rendered":"http:\/\/blog.thecompliancecenter.com\/?p=10569"},"modified":"2025-09-08T00:44:12","modified_gmt":"2025-09-08T04:44:12","slug":"know-your-exemptions-the-explosives-exemption-tdg-section-1-31-and-special-provision-125","status":"publish","type":"post","link":"https:\/\/www.thecompliancecenter.com\/ca\/help-center\/articles\/know-your-exemptions-the-explosives-exemption-tdg-section-1-31-and-special-provision-125\/","title":{"rendered":"Know Your Exemptions \u2013 the Explosives Exemption (TDG Section 1.31), and Special Provision 125"},"content":{"rendered":"

\"\"<\/p>\n

If your business is like most, you don\u2019t usually deal with shipping explosives in Class 1. However, this class sometimes shows up in places you\u2019d least expect it. While it\u2019s expected to deal with explosives in construction, mining, and the military, you can also find explosives in unexpected products such as toys (caps for cap guns), pyrotechnics for stage and movie productions, and animal tracking collars (some use explosive bolts to free the animal so it doesn\u2019t have to make a permanent fashion statement).<\/p>\n

Shipping explosives can be more complex than many other classes of dangerous goods. They are subject to other regulations, such as the Explosives Act<\/em><\/a>, and may require special licensing depending on what type they are. In addition, they are often excluded from some of the common exemptions found in Canada\u2019s Transportation of Dangerous Goods Regulations<\/em><\/a> (TDGR). For example, explosives can\u2019t use the Limited Quantity exemption of section 1.17<\/a>, or the Excepted Quantity exception found in section 1.17.1<\/a>. Some low-level explosives may qualify for the 150 Kilogram Gross Mass Exemption in section 1.15<\/a> and the 500 Kilogram Gross Mass\u00a0Exemption in section 1.16<\/a>, but only if they fall into certain divisions, compatibility groups or UN numbers. You\u2019ll need to read each exemption closely to ensure that your particular explosive will qualify.<\/p>\n

To balance things out, TDGR does contain some provisions for shipping small amounts of low-level explosives more easily. However, these provisions may seem confusing for those who are used to the relatively straight-forward limited quantity rules.<\/p>\n

The main exemption found in Part 1 of TDG is section 1.31<\/a>. This is called, helpfully, the Class 1, Explosives Exemption<\/em>. Some refer to it as \u201climited quantity for explosives,\u201d since it shares some of the features found in limited quantities. But be careful using it, because many other parts of its provisions are quite different from limited quantities for other classes.<\/p>\n

First, using section 1.31 will exempt you from Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks), Part 6 (Training), Part 9 (Road) and Part 10 (Rail). You won\u2019t need to comply with these parts for the handling, offering for transport or transporting of your explosive by road or rail. Note that this exemption doesn\u2019t apply to shipment by air or water (even domestically).<\/p>\n

To determine if an explosive qualifies, first go to Schedule 1, and look up the explosive by UN number. Let\u2019s say you\u2019re shipping shotgun shells. These will be classified as UN0012, CARTRIDGES, SMALL ARMS. Check Column 6a, \u201cExplosive Limit and Limited Quantity Index.\u201d For Class 1 material this will not be a limited quantity index \u2013 instead, it will be the Net Explosives Quantity (NEQ) that can be shipped as exempted under section 1.31. In this example, for UN0012, the number is 25, indicating a maximum NEQ of 25 kilograms.<\/p>\n

Note that \u201cnet explosives quantity<\/a>\u201d is not the net weight as it would be calculated for non-explosive substances. NEQ is defined in section 1.4 as \u201cthe net mass of explosives, excluding the mass of any means of containment.\u201d Explanatory text clarifies that \u201c[s]ome explosives are articles and depend on the means of containment to achieve an explosive effect. This definition clarifies that, even in such a case, only the mass of explosives is counted.\u201d So, when calculating the NEQ of your shotgun shells, base it on the net amount of explosive substance (gunpowder in this case), but not including the packaging, casings or pellets. The NEQ will be significantly lower than the net weight of the shells as a whole. But remember, it\u2019s the gunpowder that poses the danger, not the rest of the article.<\/p>\n

Next, add up the amount of gunpowder in the shipment you\u2019re sending. Let\u2019s say, for ease of calculation, each shell contains one gram of gunpowder and each package contains 200 shells. The NEQ for one box would be 200 g. If you\u2019re shipping ten boxes, the NEQ of the shipment would be 2 kilograms.<\/p>\n

This is good news, because according to Schedule 1 for UN0012, shipments with a NEQ not exceeding 25 kilograms do not require normal TDG shipping documents or safety marks. Also, shippers, carriers and receivers don\u2019t have to be TDG-trained. However, there are still some things you\u2019ll have to do to comply with this exemption:<\/p>\n