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TDG/GHS Hazardous Waste in Canada are you AWARE OF and if not why not

Waste generally refers to any material, non-hazardous or hazardous, that has no further use, and which is managed at recycling, processing, or disposal sites.

In Canada, the responsibility for managing and reducing waste is shared among the federal, provincial, territorial and municipal governments. For instance, municipal governments are responsible for collecting and managing waste from homes for recycling, composting, and disposal, while provincial and territorial authorities are responsible for the approval, licensing and monitoring of waste management operations.  Generators of liquid industrial and hazardous wastes must manage the classification, registration, transfer and disposal of these wastes in a prescribed manner. These wastes are regulated and monitored from the moment of generation to their ultimate destination; a term often referred to as “cradle to grave”.

Remember under GHS it notes GHS (Globally Harmonized System for the Classification and Labelling of Chemicals and Chemical Mixtures). The GHS is based on 2 main principles:

  • It is essential to have adequate information about the characterization of the chemical substance or mixture, including its stability;
  • Classification is based on the intrinsic properties (the hazards) of the chemical substance or mixture concerned and does not address exposure to the chemical or mixture. In addition, it is important to understand that there are no complete exemptions from the scope or application of the GHS as a whole for any particular type of chemical or mixture (product) or any specific use, although, at certain stages of the life cycle of the chemical or mixture, other hazard communication approaches than the labelling requirements included in the GHS may take precedent. For proper management of potential hazardous wastes, it is essential to have adequate information about the hazards linked to the waste and the subsequent human and environmental risks inflicted by exposure to the waste of concern.

In contrast to waste characterization, chemical substance or mixture characterization for the GHS includes: purity, possible presence of contaminants, composition (if a mixture), concentration of components and composition of the diluent or diluents, normal storage, transport and use conditions

GHS is not a risk assessment instrument as the exposure to the hazardous condition is not considered in classification. For example, a very hazardous substance or mixture (e.g., a strong corrosive) may pose a very low risk of harm to people or property damage during transport (if the corrosive substance/mixture is securely contained in a non-leaking container). Similarly, a substance/mixture with an almost negligible health hazard (e.g. the substance sugar) may pose a very high risk of individual fatality if ingested in substantial quantities over a long period (life-threatening cardio-vascular diseases).

GHS to classify and label wastes is only possible when: · The waste is sufficiently characterized, i.e., the composition of the waste considered for classification is known and well documented. With due care, exception may be made for inert and other components of the waste that are known to be nonhazardous;

  • From the characterization of the waste there is sufficient evidence that components of the waste will not interact to form (a) new component(s) or cause (a) synergistic effect(s);
  • The waste composition is stable and will not vary appreciably over time;
  • The waste composition is homogeneous throughout the total volume of the waste considered; and
  • Once characterized and documented, no other or similar wastes have been added to the characterized waste unless from documented characterization of the waste to be added it can be concluded that both wastes are substantially equivalent with respect to their composition. Considering this, it is generally not possible to use the GHS to assign a particular hazard classification to a waste. Examples of particular wastes that may, as an exception to this, be classified in accordance with the GHS are likely to be at best limited to:
  • well-defined and well monitored wastes from the normal production processes for certain industrial products (e.g., pharmaceutical and pesticide production)
  • well characterized and GHS classified waste chemical substances or mixtures (e.g., waste mineral oils, solid or liquid pesticide waste, residual amounts of paint or cleaning compounds)

The recent amendments to the federal Transportation of Dangerous Goods Regulation (TDGR) have created challenges for waste managers/shippers due to inconsistencies between the federal/provincial waste manifest form.

In order for a waste manifest to qualify as a TDG shipping document, the information must be provided in the order prescribed in TDGR s.3.5 – UN No., Shipping Name, Class, Packing Group.  However, the current waste manifest requires the information be entered as Prov. Code, Shipping Name, Class, UN No., Packing Group, Quantity Shipped, Units, Packaging (No./Code), Physical State.

Hazardous wastes and hazardous recyclable materials typically exhibit hazardous characteristics, such as toxicity, corrosivity or flammability to name just a few. In Canada, these characteristics are defined by taking into account the hazard criteria established under the Transportation of Dangerous Goods Act andTransportation of Dangerous Goods Regulations, as well as specifically listed wastes and materials in the schedules of the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR).

TDG Part 3.6.1 states that as of July 15, 2015, a Consignor must state their name and make a Consignor’s Certification on any shipping document containing dangerous goods.  This certification can be authorized by 49 CFR, ICAO Technical Instructions, IMDG Code, or UN Recommendations.  Alternatively, you would use the TDG certification language which is as follows:

“I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, are properly classified and packaged, have dangerous goods safety marks properly applied or displayed on them, and are in all respects in proper condition for transport according to the Transportation of Dangerous Goods Regulations.”

The Canadian standard Movement Document/Manifest adopted by Canadian provinces and territories for use in waste shipments across Canada has been recently updated to include the new certification requirements of a Consignor.  You will note that this certification requirement states that the correct classification under TDG is used (note Part 2.2.1 above).  However, the manifest description for dangerous goods is not in compliance with Part 3.5(1)(c) of TDG as the description is still shown as Shipping Name, Class, UN No. and Packing Group.

If the Movement Document/Manifest is not modified and adopted by provincial/territorial authorities by June 30, 2015, with the correct TDG description order, which is not likely to occur, then all dangerous goods waste shipped on a Movement Document/Manifest must be accompanied by a bill of lading with the correct TDG description.

Hazardous wastes and hazardous recyclable materials can be in different forms such as solid, liquid, gas, sludge or paste. They can come from a myriad of sources such as residues from industrial operations, manufacturing processing plants and hospitals, or they can be obsolete materials such as waste lubricants and pesticides. More information about the generic types of potentially hazardous wastes and activities that may generate them is available in Environment Canada (EC)’s Guide to Classification.

Due to the dangerous properties of these materials and the fact that they may pose a risk to human health or the environment in certain conditions, special recycling and disposal operations must be undertaken at authorized facilities to ensure their environmentally sound management and continued protection of human health.

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