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.: