March 2018 TDG TP 14877 Update

Railway Tanker Transporting Dangerous Goods

Rail TDG Standard TP 14877 Update

On March 15 Transport Canada released a notice on the intent to issue a new January 2018 edition of standard TP 14877 “Containers for Transport of Dangerous Goods by Rail” to replace the current 2013 (with Corrigendum) edition.

This is the penultimate culmination of the public process, in part arising out of the Lac Mégantic 2013 disaster, undertaken by a stakeholder Consultative Committee that began in February of 2016.

The main features of the proposed 2018 edition include:

  • Improved usability by incorporating external technical requirements, such as those in Protective Direction 34, 37 and 38.
  • Updated dangerous goods list to align with the 19th edition of the UN Model Regulations. Adjusted special provisions to reflect updated transportation requirements for Sulphuric Acid (UN1831) and Hydrogen Peroxide (UN2014 / UN2015).
  • Updated technical requirements for Class 3, Flammable Liquids and the new tank car specification known as TC 117.
  • Improved harmonization between tank car requirements in Canada and the US, including tank car approvals, tank car design requirements and a new mechanism to secure One Time Movement Approvals (OTMA) – Category 2.
  • Updated material of construction requirements for tank cars, including the addition of stainless steel, normalized steel for dangerous goods classified as a toxic inhalation hazard (TIH) and improved thickness requirements for new tank car construction.

Comparing the 2013 and 2018 Standard TP 14877

A brief comparison of the TABLE OF CONTENTS of 2018 versus 2013 indicates:

  • removal of Appendices A and B (emission standards for liquified petroleum gas and anhydrous ammonia respectively); these appendices now refer to TC 117P impact testing (side and head respectively)
  • subsections and .4, 8.6.20, 9.5.14, c., 10.5.5 are now “reserved”; as are special provisions 12 and 43 in Appendix E, Schedule 1.
  • a new section 2.2 “Reference Conflicts” emphasizes the precedence of the TDG regulations
  • new section 4.12 “Tank Car Cleaning Prior to Conducting Work” has been added
  • a new section 7.5 “Delayed Installation” allows, conditionally, the option of marking a tank car with the date a pressure-relief device was installed (if it was qualified no more than 6 months before installation) rather than the device qualification date.
  • TC 117 tank cars have been added to section 8.3 “General Requirements…”
  • Subsections in Section 11 have been revised and re-titled to reflect OMTA requirements.

Also of interest may be the reorganization of subsection 10.8 responsibilities (in the 2013 ed. “Before Offering for Transport”) to require the inspection by a “person” expanding the responsibility beyond just the person “who offers for transport”. The subsection is now titled simply “After Loading”.

The amendment to adopt the proposed revised standard is expected to be published in the Part I Canada Gazette (CGI) in the fall for a 60-day comment period. Transport Canada hopes to have the CGII final amendment version adopted in the fall of 2019.

Presumably the incorporation of information will result in at least as stringent requirements, as currently are in place with the 2013 edition, and subsequent Protective Directions and amendments in Part 5 of the TDG regulation, since Transport Canada has indicated in this notice that (despite the 2013 edition remaining in force until the CGII publication):

“However, stakeholders can begin transitioning to the new requirements at any time.”

The notice of publication and a link to the proposed January 2018 edition of TP 14877 is found at:

If you have any questions regarding the recent changes to the TDG TP 14877 Update contact ICC Compliance Center at 888-442-9628 in the USA and 888-977-4834 in Canada.

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.