TDGR Amendment 12 – Expected July 2, 2014

Updated Safety Marks

Reliable sources have indicated that the December 2012 proposal to overhaul placarding and other safety markings is expected to be published in the Canada Gazette Part II on Wednesday, July 2, 2014.

This amendment is intended to improve the harmonization between the marking requirements in the Canadian TDGR (Transportation of Dangerous Goods Regulations) and the various current international (UN Recommendations, 49CFR, ICAO, and IMDG) regulations.

Significant Changes

Although not an exhaustive list, significant changes, based on the original Gazette I notice, include: introduction of defined “overpacks” and their markings, implications in the LQ (“Limited Quantity”) provisions, etc.; phasing out of the older Class 5.2, LQ, Marine Pollutant, Fumigation marks in favor of the international versions; relaxation of the need to remove safety marks while any quantity of DG remain; completely re-working the Part 4.15 placarding requirements, including severely restricting the use of the “Danger” placard (e.g. only for loads of “small means of containment”), limiting the 500 kg exemption options; allowing the use of 2 placards or 4 labels (with UN #s) on IBC (“intermediate bulk containers”) totes; adding a requirement to mark “toxic-inhalation hazard” on Special Provision 23 DG packages; and other changes.

Word has it that the amendment will take effect July 14, although (again based on the original proposal) there may be transitional provisions for some aspects.

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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.