Canada’s New UN Packaging Retesting Requirements

Canada’s New UN Packaging Retesting Requirements

A few months ago, I wrote an article about a new packaging standard in Canada that was published.

At the time that article was written, we were still waiting for the new standard to officially take effect. With the Government of Canada now publishing the amendments to the Transportation of Dangerous Goods Regulations in the Canada Gazette, Part II, the new standard is officially in force. One of the major changes of this standard involves UN testing requirements.

What is the New Standard and What Does It Replace? 

With the new Amendments to the TDG, comes a new packaging standard.  The new CGSB-43.150, Design, manufacture and use of UN standardized drums, jerricans, boxes, bags, combination packaging, composite packaging and other packaging for the transport of dangerous goods, classes 3, 4, 5, 6.1, 8, and 9 is now referenced in TDG at 5.6 (a) (iii).  This standard replaces the previous standard, the TP14850.  This new packaging standard should now be used to select compliant UN packaging when shipping dangerous goods within Canada.  There are some differences between the current and previous packaging standards, one in particular that involves UN testing.

What are the Changes Involving UN Testing?

If you are manufacturing UN rated drums, jerricans, boxes, bags, combination or composite packaging in Canada, you are required to register the design with Transport Canada, this has been the case for quite some time now.  In the past, if you were looking to renew an existing registration, or start an initial one, you would fill out an application and send design specifications of the containers including a UN test report to Transport Canada.

The New Five-Year Retesting Requirement

There was previously no restriction as to how long ago the UN Test report was produced.  The big change with the new CGSB-43.150 standard is there is now a requirement  found at 7.1.3 to retest the registered container design at an interval of no more than 5 years.  This means that if you are looking to register or renew a container design with Transport Canada, the UN test report cannot be more than 5 years old.

Is an Exemption Possible?

There is a potential exemption that says the Director may permit some or all of the tests prescribed by Section 7 to be waived for registered container designs that differ only in minor respects from registered container designs that have been retested in accordance with this clause. However, this would be at the discretion of Transport Canada.  My suggestion on that case would be to contact Transport Canada long before registration expires to see if you would qualify to use this exemption, as it seems pretty vague.

When Does the Retesting Requirement Take Effect?

I also did find a few transitional exceptions in relation to the new UN testing requirement.  One is found in the new CGSB-43.150 at 10.4.10, where it says a transition period for the periodic retest of container design starts 24 months after this standard comes into force. In addition, The Canada Gazette II that was recently published in June mentioned that the container retesting requirement will come into force on July 1, 2029.  In either case, we do have a transitional period to get our packaging designs retested in accordance with the new CGSB-43.150 standard.

Do You Need UN Testing or Certified Packaging?

If UN testing is needed, or if you are looking for UN rated packaging that is already certified, feel free to contact ICC Compliance Center at 855.734.5469 or send us an email, we’re happy to help.

View the New Packaging Standard

A link to the new packaging standard can be found HERE.

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