Notification of Standard Update - Aerosols Containers and Gas Cartridges

Significant Changes from CGSB-43.123-2010 to CAN/CGSB-43.123-2017

The Canadian General Standards Board has updated the CGSB-43.123 standard on aerosol containers and gas cartridges for the transport of dangerous goods. The 2017 edition has not yet been incorporated into regulations; it will be recommended for regulatory adoption during summer/fall 2017 in the amendment titled Regulations Amending the Transportation of Dangerous Goods Regulations (International Harmonization Update, 2016). There will be a six-month transition period before it comes into force.

The primary changes from the 2010 to the 2017 editions include:

  • a reorganization of the requirements to promote clear language;
  • revised requirements for Transport Canada registration;
  • further cllarification as to which parts of this standard apply to non-specification containers; and
  • revised requirements for the transport of aerosol containers and gas cartridges intended for disposal or recycling.

These updates will provide alignment with the 19th edition of the UN Model Regulations, and will also incorporate equivalency certificates previously issued by the Transportation of Dangerous Goods Directorate.

This page summarizes the most significant changes to the standard for manufacturers, fillers, users and waste transport companies, although not all changes are covered. It is the responsibility of the manufacturer, filler, user or waste transporter of aerosol container or gas cartridge to read and understand the sections of the standard that are applicable to their respective activities, to ensure that they are aware of all the changes.

For Manufacturers of Aerosol Containers and Gas Cartridges

Record Keeping

Records of performed testing must be kept for a minimum of ten years, for all testing that is required by the standard. This, for example, could include:

  • the internal pressure test required for TC-2R specification aerosol containers;
  • the burst testing required on TC-2P and TC-2Q containers and TC-2R aerosol containers;
  • the pressure-relief device testing on TC-2Q and TC-2R aerosol containers; and/or
  • the drop testing and burst testing on TC-2S aerosol containers.

In addition, records of process control documents must be kept, such as bills of purchased materials, as well as information on traceability of lot numbers to the manufacturing date.

Registration Requirements for Manufacturers of TC Specification Containers

  • If a manufacturing facility has a quality management system that conforms to ISO 9001, and if it is registered with a quality management registrar accredited or recognized by the Standards Council of Canada, the registration application can include only a copy of the quality management system Certificate of Registration, instead of the detailed description of the quality management system that was required under the 2010 edition.
  • An application for renewal must be made 90 calendar days prior to the expiry of an existing Certificate of Registration in order for the Certificate to remain valid beyond its expiry date, provided that the Certificate is not revoked by the Executive Director.
  • A transition period clause will allow a Certificate of Registration issued pursuant to CGSB-43.123-2010 to continue to be valid under the updated CAN/CGSB-43.123-2017 without re-application, provided that it has not expired or been revoked.
  • The Executive Director may revoke a Certificate of Registration if the Executive Director deems that the facility is not capable of, or is not complying with the applicable requirements of the standard.

For Fillers of Aerosol Containers and Gas Cartridges

Marking

The date of filling must be marked on all TC specification containers, or the lot number or serial number must be traceable to the date of filling.

Record Keeping

Process control documents, such as lot numbers demonstrating traceability to the date of filling and performance testing records for testing, such as water bath, must be kept for a minimum of 10 years.

For Users of Aerosol Containers and Gas Cartridges

Non-Specification Containers

Clarification has been added that many requirements of this standard, including marking, do not apply to non-specification containers permitted for use under Table 1 of CGSB-43.123-2017.

Use of DOT Specification Containers

A DOT specification aerosol (DOT-2P, DOT-2Q, DOT-2S) may now be used in Canada if the container is authorized by the Code of Federal Regulations (49CFR), and if it is either:

  • manufactured and filled with dangerous goods outside of Canada in accordance with 49CFR; or
  • manufactured outside of Canada in accordance with 49CFR and filled in Canada in accordance with CAN/CGSB-43.123-2017 (this standard).

For Waste Transport of Aerosol Containers and Gas Cartridges

The waste transport requirements from the 2010 edition were significantly updated for the 2017 edition. There are currently many active equivalency certificates issued by Transport Canada to allow for waste transport in larger and more mixed quantities than permitted by the older edition of this standard. The new edition considers the practices surrounding these equivalency certificates, as well as the 19th edition of the UN model regulations’ updated requirements.

In addition to the requirements under which containers are to be packed in strong outer packagings that are ventilated, the standard now lays out the type of outer packaging that must be used. The maximum permitted volume is now established at 1500 L, and permitted outer packaging includes leak-proof non-specification rigid packaging, UN standardized drums and boxes, UN standardized intermediate bulk containers, and UN standardized rigid and leak-proof large packaging. Please refer to clause 9 of CAN/CGSB-43.123-2017 for additional details.

Existing equivalency certificates will expire and will not be renewed.

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