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6. Part 5 - Means of Containment

Part 5 - Means of Containment

• Do trucks that transport BATTERIES, UN2794 require to comply with CSA B621 since the batteries (the dangerous goods) are « in direct contact with a large means of containment », namely the truck itself?

• Is a « cluster pack » of cylinders itself a means of containment or is it a number of means of containment permanently connected together?

• Are the propane tanks of paving equipment required to comply with section 5.10 of the TDG Regulations, when transported down on the highway and used on highway paving jobs?

Question

Do trucks that transport BATTERIES, UN2794 require to comply with CSA B621 since the batteries (the dangerous goods) are « in direct contact with a large means of containment », namely the truck itself?

Answer

Yes, these batteries are solid dangerous goods. CSA B621 does not require that a specification vehicle be used in transporting solid dangerous goods (Specific Requirement 4, CSA B621), but that the vehicle otherwise comply with Clause 4 of the standard. The means of containment must therefore be watertight and constructed so that neither rain nor spray can come into contact with the dangerous goods. It must also be dust-proof, sift-proof and constructed so that the dangerous goods are securely retained under normal conditions of transport.

Question

Is a « cluster pack » of cylinders itself a means of containment or is it a number of means of containment permanently connected together?

Answer

At first glance, permanently manifolded cylinders in a cluster pack would seem equivalent to a compartmentalized tank that is a single means of containment with sections within it. However, each cylinder is a self-contained unit that can exist apart from the others while the compartments in a tank are integral to the tank. On this basis, the Directorate believes that a « cluster pack » of cylinders is not a single means of containment but a number of them permanently connected together.

Question

Are the propane tanks of paving equipment required to comply with section 5.10 of the TDG Regulations, when transported down on the highway and used on highway paving jobs?

Answer

There is no exemption in the TDG Regulations for paving equipment. For the transport of propane by road, the means of containment used must comply with section 5.10 of the TDGR; therefore, only vehicles compliant with the TDGR while loaded with propane should reach a highway job site.

Date modified:

2012-02-15

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