How do I determine the shipping name when there are several possible shipping names? Shipping name is the name of the dangerous good as it appears in column 2 of Schedule 1. There may be occasions when several different shipping names can be used. The shipping name is selected in the following hierarchical order:
1. Specific chemical name (e.g., acetone, sulfuric acid, etc.)
2. Chemical family name (e.g., alcohol, ketone, etc.)
3. Product usage (e.g., pesticide, adhesive, fuel, etc.)
4. Generic risk (e.g., flammable, toxic, etc.)
When the shipping name is not a specific name such as a family name, then these shipping names are followed by N.O.S. N.O.S. means Not Otherwise Specified. It is used for dangerous goods that do not have a specific entry by name in Schedule 1. For example, both gasoline and diesel are listed by their name in Schedule 1. However, if these two substances were mixed, the resulting mixture of these two products would still be regulated as a dangerous good. However, the mixture could no longer be described as “Gasoline” or “Diesel” since it would no longer have a specific name in Schedule 1. As such, the mixture would be classified as UN1993 – FLAMMABLE LIQUID, N.O.S.
What are the steps a consignor or shipper must follow when shipping dangerous goods?
The following steps must be followed in the order they are presented below.
- Train employees in TDG and issue certificate before they handle the dangerous goods.
- Ensure a competent person who has been trained in TDG determines the classification of the product.
- Ensure a competent person who has been trained in TDG selects the appropriate container or packaging.
- Ensure a competent person who has been trained in TDG selects labels or placards for the containment (e.g., containers such as drums and pails, tanks, etc.) and applies the labels or placards on the containment.
- Ensure a competent person who has been trained in TDG prepares the shipping papers and any other documents such as Emergency Response Assistance Plan (ERAP) that are required under the TDG Regulations.
- Ensure the carrier has the correct shipping papers and that the truck has the correct placards before it is loaded.
If the shipping name is not a specific name, then the technical name of the most dangerous substance needs to be provided in brackets as required in Special Provision 16 in Schedule 2. For example, the shipping name for a mixture that consists of 80% gasoline and 20% diesel will be: FLAMMABLE LIQUID, N.O.S. (gasoline)
What is a proof of classification?
A proof of classification is a document that the consignor must provide, upon request, to the federal Minister of Transport. This document may be:
- a test report,
- a lab report, or
- a document that explains how the dangerous goods were classified.
The proof of classification must include the following information:
- the date on which the dangerous goods were classified,
- if applicable, the technical name of the dangerous goods,
- the classification of the dangerous goods, and
- if applicable, the classification method used under Part 2 of the TDG Regulations or under Chapter 2 of the UN Recommendations.
Can I use a UN number that is not included in the Canadian TDG Regulations?
Yes. Subsection 2.2(4) and Parts 9 and 10 of the TDG Regulations authorize you to use the classification from the:
- International Civil Aviation Organization (ICAO) Technical Instructions for the transport of dangerous goods by air,
- International Maritime Dangerous Goods (IMDG) Code for the transport of dangerous goods by ship, or
- Code of Federal Regulations (49 CFR) (U.S. Regulations) for the transportation of dangerous goods by road. Note: The NA numbers in the 49 CFR are not permitted in Canada.
What documents do I need to prepare to ship dangerous goods?
As a minimum, the shipping document must contain:
- Consignor’s name and address in Canada
- Date of shipment
- Description of the dangerous goods in the following order:
- UN number (e.g., UN1230)
- Dangerous goods shipping name (e.g., Methanol)
- Primary class and subsidiary class (e.g., 3(6.1)), with the compatibility group letter, following the primary class, for explosives
- If applicable, the packing group in roman numerals (e.g., I, II or III)
- If applicable, the words “toxic by inhalation” or “toxic – inhalation hazard” for dangerous goods subject to Special Provision 23
- The quantity in metric measurement (e.g., kg or L) for transport originating in Canada
- For Class 1, Explosives, the quantity must be expressed in net explosives quantity (NEQ) in kg. For explosives subject to Special Provision 85 or86, it must be expressed in number of articles or NEQ
- For Class 2, Gases, the quantity must be indicated by stating, for each means of containment, the capacity of the means of containment
- The 24-hour number of:
- an individual who works for the consignor who can provide technical information on the dangerous goods without breaking the telephone connection made by the caller, or
- the telephone number of a person who is not the consignor, such as CANUTEC, but who is competent to give the technical information. NOTE: In order to use the CANUTEC’s telephone number, the consignor must receive permission, in writing, from CANUTEC, or
- an organization or agency other than CANUTEC. The shipper must ensure that the organization or agency has current, accurate information on the dangerous goods the consignor offers for transport and, if the organization or agency is located outside Canada, the telephone number must include the country code and, if required, the city code.
- The consignor’s certification.
In some cases, you may need to include more information, such as:
- The number of small means of containment (i.e., capacity of 450 L or less) that require labels
- The technical name or the statement “not odorized”
- The Emergency Response Assistance Plan (ERAP) number and its activating telephone number
- The flash point if the product is a Class 3, Flammable Liquids and is being transported on a ship (e.g., gasoline, diesel, etc.)
- Special instructions such as the control and emergency control temperatures of Classes 4.1 and 5.2
- The words “marine pollutant” for dangerous goods that are marine pollutants under Section 2.7 of Part 2 and are being transported on a ship
- For a pesticide that is a marine pollutant being transported on a ship, the name and concentration of the most active substance in the pesticide
Are there specific requirements to follow when loading when dangerous goods in the vehicle?
Yes. When dangerous goods of different classifications (e.g., Class 3 flammable liquids and Class 8 corrosives) in containers are loaded in a vehicle, the goods may need to be segregated if the dangerous goods are incompatible (i.e., the products may react together in case of a spill).
In general, segregation applies to packages as well as to transport vehicles. The intention is that:
- incompatible substances must not be combined in the same packaging,
- packages containing substances that are incompatible must be isolated from each other within the same means of transport, and
- at other times, packages containing substances that are incompatible must not be shipped within the same means of transport.
Is there reciprocity between Canada and USA for TDG?
Generally, yes there is. However, there are some exceptions.
Training documents – Transport Canada recognizes:
- the HazMat (dangerous goods) endorsement of the Commercial Driver’s Licence,
- a copy of the certification stipulated in Section 172.704 (d) (5) of the 49 CFR (Code of Federal Regulations), or a
- a TDG training certificate issued under Part 6 of the TDG Regulations.
The U.S. Department of Transportation – Federal Motor Carrier Safety Administration will accept a Canadian driver’s TDG training certificate in lieu of a HazMat endorsement.
Does the training certificate expire?
Yes it does. The expiration date differs for different modes of transport. The certificate is valid for:
- 24 months (2 years) after its date of issuance for transport by aircraft.
- 36 months (3 years) after its date of issuance for other modes
Labels and placards – In general, labels and placards from the United States are accepted in Canada by virtue of the reciprocity that exists between the two countries. However, this reciprocity does not apply to American labels and placards for dangerous goods included in Class 2.3 and Class 6.1 (Paragraph 9.1(1)c)). For these two classes, labels and placards must be those required by the TDG Regulations.
What happens if I do not comply with the TDG legislation?
The penalties for not complying are substantial. For example, any person who contravenes or disobeys the TDG Act can be charged with:
- up to $50,000 for a first offence,
- subsequent offences of up to $100,000,
- and up to 2 years of imprisonment for indictable offences