Small hazards

If a mechanic puts a propane tank from his barbeque into the trunk of his car, he’s just another backyard chef. If he puts it into his work truck and heads out on a road call, he may now be a hazardous goods hauler, subject to Transport Canada’s Transportation of Dangerous Goods (TDG) Act and Regulations.

Since new federal dangerous goods rules took effect in August 2002, anyone driving a service vehicle with welding gases, propane, or many other items common to a repair truck may be doing so illegally. If the items are classed as dangerous goods, and the driver has no training certificate issued by his employer (or himself, if self-employed) and a shipping document, he could be in violation.

Even dispatchers who schedule work involving dangerous goods, warehouse workers who may move such goods, and clerical staff who prepare the documents require TDG training.
Penalties for violating these rules can be stiff–up to $50,000 per person per day for a first offence, and up to $100,000 for each subsequent offence where the person didn’t take “all reasonable measures” to comply with the Act.

Compliance boils down to training and certification, correct approvals for cylinders and other containers, and proper fastening devices in the truck to ensure they stay in place. In reality, it’s the tanker trucks, cylinder delivery trucks, and recycling facilities that keep hazmat officers busy. And these inspectors don’t have the authority to stop a vehicle at the roadside when they suspect a problem–that’s up to police or a provincial transport officer.

However, if you’re not well versed in hauling hazardous goods but suspect the rules apply to you, take a proactive approach and invite officers to help make sure you comply, says Transport Canada dangerous goods inspector Bill Suddard. He routinely conducts compliance reviews for businesses, focusing on training, documentation, vehicle markings, means of containment, and product classes.

Rules for service vehicle operators are less onerous if they’ll never carry more than 500 kilograms of hazardous material and no more than five cylinders or containers. In that case, markings on the outside of the truck, for example, are not required.

There are things every service truck operator should know, however:

1. What’s in the truck? The shipping document must include number of cylinders, cylinder size, shipping name and description, classification, and UN number (a United Nations identification mark for hazardous materials that is recognized worldwide). It also should list emergency contact information in the event of an accident.
2.
The document is important because it tells police or fire officials at the scene what to expect, advises Suddard. Keep it in a pocket on the driver’s side door.

3. Markings. Each hazmat container must have a diamond-shaped dangerous goods label with shipping name and UN number. Safety certification marks stamped into the shoulder of the cylinder, for example, should include a Transport Canada TC (or CTC) certification number. Some tanks are dual certified as TC/DOT. (DOT certification is U.S. and therefore not, by itself, valid in Canada).
4.
Suddard says he still sees tanks that are expired despite recently having been returned with new valves from the recycler. There also will be a marking that identifies the style of tank-8AL, for example, stands for thick aluminum.

3. Securing the load. As on the big trucks, you need to restrain tanks and other hazmat containers. Most people use chains, straps, or some type of secure shelving. “A lot of this is just plain common sense,” notes Suddard.

4. Am I trained? There are a number of training institutions listed at www.tc.gc.
ca/tdg–many provide train-the-trainer programs so one employee can take a course and come back and teach his co-workers.

5. Who to call? If there’s trouble, the driver should call their employer and CANUTEC–the Canadian Transport Emergency Centre. CANUTEC is a service operated around the clock by Transport Canada to assist emergency-response personnel in handling dangerous-goods emergencies. Their bilingual advisory staff specialize in emergency situations and can interpret technical information about any dangerous goods on board. Although they don’t dispatch spill-response teams themselves, CANUTEC’s experts can provide over-the-phone (voice or fax) information including chemical, physical, and toxicological properties and incompatibilities of dangerous goods; health hazards and first aid; fire, explosion, spill, or leak hazards; and remedial actions for the protection of life, property, and the environment.
6.
Federal regs say CANUTEC must be called in any incident involving radioactive or infectious materials, and various provincial or municipal regulations may suggest or require contact in certain other circumstances. However, a call to CANUTEC does not replace the spill-reporting processes demanded by these authorities as per their individual legislation.
CANUTEC’s emergency number is 613/996-6666 (call collect), or cellular *666. For other purposes, use 613/992-4624 to phone, or fax at 613/954-5101. CANUTEC is on the web at www.canutec.gc.ca.

Transport Canada rules are just one layer among many with respect to dangerous goods. There are provincial transport rules, federal and provincial environmental regulations, and Workplace Hazardous Material Information System (WHMIS) requirements.

The most important point to remember, Suddard says, is that you don’t have to be carrying explosives or gasoline to be a hazmat hauler. If the law says you’re a hazmat hauler, that’s what you are. To not comply, he says, is like playing with fire