Plain Talk About Canada’s New TDG Rules

Q: I’ve seen Transport Canada’s proposed new “plain language” dangerous goods regs. Aside from the obvious changes to the format, what are the other big changes from the current rules?

A: The federal government has completely rewritten the regulations, taking out the “legalese” and turning it into plain English. At the same time, they’ve made several changes that will affect trucking companies across Canada.

This hasn’t come out of the blue-Transport Canada consulted with shippers and carriers while they were rewriting the regulations, and many of the trucking industry’s concerns have been taken into account. The proposed rules are closer to the U.S. requirements and more in line with international air and marine regulations. Transborder shipments and road/rail transfers should be simpler and smoother.

Your company might have to update the list of dangerous goods you carry to reflect new shipping names and UN numbers (they’re no longer called Product Identification Numbers, or PINs). Here are some other changes that could affect your operation:

LTCs: Dangerous goods that are shipped in small enough quantities and secure enough packaging are considered to be Low Threat Consignments (LTCs) and will be exempt from the regulations, replacing the consumer commodities and limited quantities exemptions. Less-than-truckload carriers will need to be familiar with the new definition and with conditions that might require Low Threat Consignments to be marked or documented.

Placards: Placarding rules are simplified but will take into account the requirement for the shipper to have an Emergency Response Assistance Plan (ERAP) for certain types and quantities of dangerous goods, so the placarding charts and guidelines you give your drivers may have to be revised. The good news is that placards for flammable liquids like gasoline will no longer have to be retroreflective-ordinary (and less expensive) placards can be used instead.

Labels: Shippers will have to label for the subsidiary risk of a product as well. Drivers may notice that dangerous goods like methanol show a Poison label as well as the Flammable Liquid label they’re used to seeing.

Class 9 has changed considerably, and the old exclamation mark label will be replaced with the international symbol for Miscellaneous dangerous goods, which has vertical stripes in the top half of the label.

Documents: The shipping document will no longer have to include the name of the carrier or consignee, the shipper’s signature, or a document identification number, but it must show additional information like the shipper’s postal code. If your drivers use a checklist to accept dangerous goods it will have to be updated.

Although there are allowances for documents to be sent or stored electronically, the driver must still carry a paper copy with the dangerous goods.

Training and Certification: Drivers will need to know that the Regulations have changed, and be retrained in the specific areas that affect them. All of your training courses, driver’s handbooks and reference materials will have to be revised.

Additional details will be required on each certificate of training, including the employer’s address (complete with postal code) and the employee’s signature, so most carriers will have to issue new certificates even if they do not retrain all their drivers right away.

It is still up to each employer to decide what constitutes adequate training, but under the new regulations you might be required to show a dangerous goods inspector your company’s training courses and classroom materials.

Transition Period: When the regulations come into effect there will be a six-month phase-in period to comply with the new requirements, during which drivers will have to be ready to carry dangerous goods prepared under either the old or the new regulations. At the very least you’ll need to distribute an information bulletin as soon as the transition period begins.

The deadline for comments on the “plain language” regulations is Nov. 5, 1999. Barrie Montague of the Ontario Trucking Association is coordinating an industry response on behalf of the Canadian Trucking Alliance. You can call him at 416/249-7401, or contact your provincial trucking association for more information.

If you want a summary of the changes, plus the whole 750-page text of the proposal, go to Transport Canada’s Web site, www.tc.gc.ca/tdgoods/general/main_e.htm.