TDG – More on SOR/2014-306

By January 13, 2015 January 29th, 2020 Transportation of Dangerous Goods

Further to the observation in our blog published on January 12, 2015 (ERAP changes under SOR/2014-306): We have requested clarification from Transport Canada so that our training course material will accurately reflect the obligations of those involved in TDG.

The response we have received from the Regulatory Branch of Transport Canada confirms that:

    • 7.1(6) will be re-worded in a January 28th Gazette Notice to correct “railway vehicle” to “rail tank car”;
    • Inspectors will be instructed to not take enforcement action for road transportation under the listings in 7.1(6) as amended, pending an additional amendment to revert to the original intent excluding road transportation ERAP requirements for the listed UN numbers;

  • The formal proposal to amend the amendment will be recommended in the next regulatory package, “likely March of 2015”.

According to the Transport Canada “Forward Regulatory Plan 2014-2016, Proposed Regulatory Initiatives”, the only outstanding TDGR item in the plan is to amend Part 8 regarding release reporting criteria (which could include expanding current requirements):

“Description of the Regulation: This proposal amends Part 8 of the Transportation of Dangerous Goods Regulations, which set out reporting criteria and information requirements. The amendment will introduce reporting requirements for dangerous goods that are lost, stolen or unlawfully interfered with.”

The second part of the above “Description…” apparently includes adding requirements similar to the 2009 Interim Order 001, which lapsed in 2011, i.e.:
http://www.tc.gc.ca/eng/tdg/clear-interimorders-loststolen-311.htm

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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.

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