Let’s start by saying that Transport Canada (TC) remains the authority responsible for carrying out inspections, audits, and has the responsibility to strengthen the Transportation of Dangerous Goods (TDG) Act and Regulations within Canada. That said, when TC conducts inspections of dangerous goods shipments, it must go through all aspects of the TDG to identify elements of non-compliance.
It is understood that a TDG violation can result in a fine, contravention, or even imprisonment. TC maintains an index of offenses, and there is a list of commonly observed offenses. Basically, the responsibilities for TDG rest with the various stakeholders in the transport process, but the four named in the TDG are; handling, transport request, shipper (including importer), and transport.
The sender is the one who holds the majority of the responsibilities and to demonstrate this, here are the most important:
- Training requirements
- Identification and classification of dangerous goods
- Selecting means of containment
- Packaging requirements and packing instructions
- Emergency Assistance Response Plan (if applicable) – ERAP
- Marking & Labeling of packaging
- Provide carrier the required placards for large means of containment
- Completion of the shipping document
- Report in case of release
Now let’s ask a quick question.
In your opinion, selecting from the list of responsibilities above, which do you think is the most common offense encountered by TC inspectors?
a) Training requirements
b) Classification of dangerous goods
c) Selecting of means of containment
d) Marking & Labeling
e) Shipping document
If you answered e), you have the right answer! And yes, of all the infractions committed by shippers, it is the shipping document that represents the greatest difficulty from a TDG compliance perspective. This element of non-compliance alone accounted for 36% of the violations. However, if a person has adequate training according to his duties and responsibilities, he should be able to complete this document in due form.
Let’s review the information that is required to appear on the shipping document. To find out what is required, refer to Part 3 of the TDG in section 3.5. Let’s start by saying that there is no mandatory format. The document can be completed in English or French for a domestic shipment, and the information must be legible and indelible. However, there is a specific requirement and format for air shipments. Therefore, the document must include at least the following information:
- Name and address of consignor (the physical place where the DG is shipping from)
- Date of shipment
- Emergency phone number in case of an incident preceded by the mention: 24 Hour number: XXX-XXX-XXXX
- The document must contain a consignor certification (declaration of your responsibility)
- The document must contain the name of the individual who completed the shipping document (in UPPER CASE letters but a signature is not required)
- The description of DG in accordance with the specific sequence as per TDG:
- UN number preceded by the prefix UN
- Shipping name (+ technical name in brackets if DG has the special provision 16 in column 5 of schedule 1 of TDG) and the regulation requires that the most dangerous substance predominantly contributing to the hazard)
- Primary hazard class (and the subsidiary in brackets – if applicable)
- Packing group in roman numerals (applies to classes 1, 3, 4, 5, 6.1, 8 and 9)
- The mention “toxic by inhalation” if special provision 23 applies
- the number of small means of containment for each shipping name (the type of packaging is not required in Canada)
- the quantity of dangerous goods and the unit of measure (SI units) for each DG described (except for explosives which must be expressed in “net explosive quantity”)
To help you below is an example of a shipping document with the mandatory information:
In addition, it is also required to add additional information for very specific cases, as stipulated in part 3 article 3.6 of the TDG:
- Number of the emergency response assistance plan and the phone number associated with the ERAP
- Flashpoint when in maritime transport
- The words “Marine pollutant” or if it is a pesticide that is a pollutant, the name, and concentration of the active ingredient
- In the case that the DG requires a regulated and critical temperature control (applicable for certain DG of class 4.1 and 5.2)
- Any additional information applicable to radioactive materials
To help you below is an example of a shipping document with additional information:
In conclusion, if you respect the rules as stipulated by the TDG, you should no longer have problems with an inspection by a TC inspector!
Penalties and delays due to improper shipping documents are preventable. Make sure your team is properly trained to current regulatory requirements.
Remember that ICC regulatory specialists are always available to assist you and answer your technical questions.
We have all the products you need to ensure your staff is properly trained and informed.
Dangerous Goods Bills of Lading, Laser, Bilingual (English/French), 100/Pack
Hazmat Bills of Lading, Laser, Packages of 100