“Fast Away the Old Year Passes…” – TDGR Moving into 2019

, “Fast Away the Old Year Passes…” – TDGR Moving into 2019, ICC Compliance Center Inc - USA

The Canadian Transportation of Dangerous Goods Regulations (TDGR) were uncharacteristically quiet in 2018. This represents the first year in a 5-year stretch where stakeholders didn’t see at least one amendment to the TDGR.

That doesn’t mean, however, that there was no activity within this very active government department. For example, in keeping with the move to adopting ambulatory references to cited standards, the responsibility for several standards (e.g., TP14850 small container performance packaging, and TP14877 rail containers) began their return to the Canadian General Standards Board. In addition, there were various consultations on topics such as ERAPs (TDGR Part 7), and discussion of training requirements (TDGR Part 6) – the latter in conjunction with establishing a CGSB committee.


Various research projects were explored in 2018 including collaboration on examining crude oil flammability, properties of produced water in oil and gas activities, as well as validation testing of a proposed SAE standard for lithium battery packaging. These activities a

An invitation was issued to stakeholders on a scheduled symposium to present/discuss other areas for research. The symposium is scheduled for February 28 – 29 in Ottawa (http://www.tc.gc.ca/eng/tdg/tdg-research-symposium.html).


Various topics referenced above and others undertaken in the 2016-2018 period were given status updates, including proposed Canada Gazette (CG) I (final consultation) or II (final amendment) at a late November GPAC (General Policy Advisory Council) session:

Training (Part 6):

This includes the above-noted work of the CGSB committee on developing a “competency-based training” standard for employer use in development of required training, and possible Transport Canada determination of a general “TDG-101” awareness course requirement. Expected CG I in spring of 2020.

Client Identification Database (CID):

This will require registration of all companies involved in TDG activities. The database is intended to facilitate targeting consultation requests, and allow prioritizing of enforcement activities. Expected CG I in fall of 2019.

Cost Recovery on Container Registration:

The initial consultation on fees to apply for means of containment (MOC) approval will progress. The current status involves a graduated system of 4 categories based on the expected evaluation resources required for the type of application. Pre-CG I consultation continues Q1 2019.

TDGR Part 7 ERAP Update:

Following a GPAC sub-committee review of the Emergency ResponseAssistance Plan system, extensive consultation was undertaken, culminating witha CG I proposal in mid-2018. Expected CG II in March 2019.

TDGR Part 12 Air/International Harmonization:

A review of the domestic air transport requirements, and other sections requiring harmonization with current IMDG, UN, and US regulations is underway. Web-based consultation is being initiated. Expected CG I in fall 2019.

“Canadian” Updates:

This amendment process is expected in 3 parts:

Formatting- to conform to the general format required to post to the Canadian “Justice Laws” website where all other legislation is found. This will require removing the very useful italicized guidance statements interspersed throughout the text. These will have to appear in the separate FAQ section on the Transport Canada website. Another useful practice that is not available in the “Justice” format is inclusion of the SOR/revision indicators for those who would like to track through the history of changes. Expected CG II in fall 2019.

Canadian update part 1 (packaging) – specific Class updates to simplify/modernize with modal, and US provisions. Expected CG I in fall 2020.

Canadian Update part 2 (classification) – updates to TDGR Part 1, 2 and Schedules; incorporate equivalency certificate conditions and align classifications to 20th Ed. UN Model. Expected CG I in winter 2021.

Miscellaneous Amendment Regulation (MARs):

This amendment is part of an ongoing effort to improve grammatical aspects, and correct typographical errors. MARs also fixes outdated references and make minor, non-substantive improvements to regulations. This version has been prepared based primarily on input already received by stakeholders. Expected CG II in fall 2020.

Transport Canada welcomes submissions on errors noted by stakeholders addressed to: TC.TDGRegulatoryProposal-TMDPropositionReglementaire.TC@tc.gc.ca

Additional background may be obtained from stakeholder representatives on GPAC, http://www.tc.gc.ca/eng/tdg/consult-advisorycouncil-488.htm

Clifton J. Brown

Clifton J. Brown

Clifton Brown has over 35 years of practical experience in the Canadian chemical and manufacturing industries. He has worked in research, quality, environment, health and safety in a range of industries including explosives, pesticides, manufacturing/contract packaging, pharmaceuticals, and specialty chemicals. This experience has provided a basis for dealing with a variety of regulatory approaches that have been useful in implementing and evaluating/auditing compliance. This experience has also been useful in effectively helping others to understand and apply the regulations in a North American context. Clifton represents ICC on the RDC regulatory and safe operations committees, participates in Transport Canada consultations and attends WSPS, CSSE and related activities.