IHU 2019 Proposed Amendment: Pre-Gazette I Consultation

In late March, Transport Canada posted a notice on their public website regarding a pre-Gazette I consultation on proposed amendments to the TDGR. The consultation was distributed to selected stakeholders by email on March 4.

This proposal is the latest in a series of international harmonization updates (“IHU”) to incorporate changes to reflect the current editions of the UN Model Regulations (UN Recommendations), ICAO Technical Instructions for air, and the IMDG Code for ocean shipment. In addition, the Canada-US Regulatory Cooperation Council work planning effort has suggested several items that would facilitate reciprocity in shipping dangerous goods between the two countries.

UN Recommendations

  • Updating to 20th edition and preparation for 21st edition.
  • Incorporate packaging updates by adopting 3rd edition TP14850 (pending repatriation to CGSB as standard CGSB-43.150-xx), normalize EC-allowed practices on batteries; allow UN3175 in FIBC 13H3 & 13H4.
  • Marking/Labeling: text on labels, banana labels on cylinders, require orientation arrows for liquids, marine pollutant, and Lithium Battery Mark on overpacks.
  • Language issues under review, include determining the options on the use of either or both English/French and circumstances when a different second language might appear (i.e. foreign sourced material).


  • Consider adding provisions for optional hazard class text on placards – see also marking/labeling.
  • Allow US placards for re-shipping road/rail within Canada. In addition to text issues, this would allow re-shipping with US Class 7, 8 or 9 placards where the horizontal divide is not at the mid-point.

A separate issue is to consider use of the US “inhalation hazard” placard design, either as an option or as a requirement. Presumably, even if rejected as an option/requirement for Canadian sourced shipments, it might be incorporated into the (currently denied) “first destination” provision of TDGR s. 9.1 and 10.1.

Special Provisions

  • Various changes are under consideration to align with UN, IMDG, and/or US versions. Some of these will replace the need for equivalency certificates that are currently issued.

Proposed changes to other sections will also reduce the need for some existing equivalency certificates.

US Reciprocity – Other:

  • Pressurized tanks in water pump systems and extend to allow gases currently provided for in TDG equivalency certificates.
  • Marking packages, in addition to shipping documents, of “non-odorized” LPG.
  • Incorporate provision in TDGR 9.1 and 10.1 to prepare shipments in Canada destined for the US using 49 CFR requirements – albeit with some restrictions as outlined in the current (1)(a)-(c) and (2) of each section. Modifications on restrictions for safety marks (including labels and placards) may be included in these sub-sections based on other consultation topics discussed above.

There may be additional items currently covered by 49 CFR “exceptions” that could be examined if stakeholders included them in comments.

An example that may be of interest is the 49 CFR 173.154(d) exemption for Class 8 substances that are only corrosive to steel or aluminum. Presumably, since the equivalent exemption is not found in the TDGR, paragraph (2) in 9.1 and 10.1 would still prohibit receipt to the first destination and subsequent shipment as prepared in the US. Given the tendency for supplier SDS to refer to exempt or excepted substances as “Not Regulated” under “Transportation Information”, there is room for possible non-conformance by Canadian Consignors receiving or re-shipping these substances. It may be worth it for those stakeholders who are potentially affected to submit a comment.

The comment period on the pre-Gazette proposals is open until May 27, 2019.

A summary of the 31-page “Let’s Talk Transportation of Dangerous Goods” proposal is available on the Transport Canada website:

A copy of the detailed consultation document may be requested by emailing the “Join in…” link on the summary page.

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.