Regulatory Helpdesk: Sept 24

By October 4, 2018 May 13th, 2019 Regulations, Regulatory Helpdesk

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Limited Quantity from Canada to the USA

Q: I ship my material as a limited quantity under TDG in Canada. What do I need to do to ship it to customers in the US? We are also considering opening a hub in the US.
A: You will have to receive training in 49 CFR. Even though there are many similarities between the 2 regulations they are not exact matches. You may be able to use some reciprocity agreements in regards to transborder shipments. A hub based in the US will definitely have to have 49 CFR training.

New testing, now what?

Q: We just ran some testing on one of our products. It has been shipped as UN2468 in the past. However, the test report O.1 came back and said our material is not an oxidizer. What does that mean for the next time we ship the product?
A: If you have proof that your product is no longer a hazardous material, then you do not have to ship it as such. It does not meet the classification criteria set out in 49 CFR starting in §173.50.

TDG wallet card requirements

Q: I have worked with a courier company for quite some time and am wanting to start my own transport business. Can you explain the TDG wallet card requirements to me?
A: First of all, you will need training in the TDG if you do not already have it. The wallet card is something kept by all drivers as proof of training in these regulations. It would be shown to any inspectors who ask for it. A larger version or wall plaque is given to your employers for use within their facility to indicate proper training and certification has occurred for those drivers.

Reflective placards

Q: Are reflective placards still required under TDG?
A: Reflective placards are no longer a requirement of TDG Part 4. However, you must apply placards appropriately as set out in this Part.

WHMIS 2015 timeline

Q: Where are we on the WHMIS 2015 transition timeline? My company is still receiving products with old and new WHMIS information on them.
A: We understand your frustration. Canada is currently in Phase 3 of the transition to new WHMIS 2015. It will end on November 30, 2018. For manufacturers, importers and distributors that means you must be in full compliance with the new HPR (Hazardous Product Regulations) or WHMIS 2015. Employers though can still comply with old or new WHMIS. After December 1, 2018 EVERYONE must be in compliance with WHMIS 2015.
Karrie Ishmael

Karrie Ishmael

Karrie started with the company in 1988 and has worked in a variety of capacities including customer service, sales, management, and marketing. In her current role as Regulatory Manager, she manages and supports ICC's efforts in supplying value-added services including training and SDS services to our clients. She is knowledgeable in a variety of regulations. She actively participates in a multitude of associations including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.


  • Avatar Nirements to me? A: First of all, you will need training in the says:

    Specifically where does TDGR specify the requirements for the size of a training certificate, least of all the provisions for a wallet sized card or for that matter any size for a certificate?

    Norman Loiseau

    • Avatar Regulatory says:

      Thank you for your comment, Norm. I believe there is a misunderstanding here. My point was a smaller version of the training certificate, usually a wallet-sized card is kept with the driver at all times. There is no specified size in the regulations.