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Part 4 - Safety Marks

Dangerous Goods



Question

Is it necessary to meet one of the conditions listed in paragraph 4.15(1) before going to the table?

Answer

The words « if » and « or » imply that at least one of the conditions of subsection 4.15(1) must be met before going to the table.



Question

Under section 1.39, one must display the mark illustrated in Part 4, Dangerous Goods Safety Marks, for infectious substances included in Category B: the mark is a diamond-shaped mark with UN3373 in it. As section 1.39 does not indicate that Part 4, Dangerous Goods Safety Marks, does not apply, must the Class 6.2, Infectious Substances label (three crescents superimposed on a circle) also be displayed?

Answer

Yes, the label for class 6.2, Infectious Substances (three crescents superimposed on a circle) must also be displayed. The exemption of section 1.39 allows the transportation of Category B infectious substances without the requirement of a shipping document under certain conditions. One of these conditions is the display of the Category B mark, as illustrated in Part 4, Dangerous Goods Safety Marks: the mark consists of a diamond shape with UN3373 in it. As section 1.39 does not provide an exemption from Part 4, Dangerous Goods Safety Marks, the primary class label (three crescents superimposed on a circle) must also be displayed in accordance with section 4.10. Therefore, in accordance with sections 1.39, 4.10 and 4.22.1, the two safety marks must be displayed: the Class 6.2, Infectious Substances label and the Category B mark. Please note that Class 6.2, Infectious Substances includes substances of Category A and substances of Category B. Displaying the Class 6.2, Infectious Substances label indicates the presence of infectious substances of Category A, Category B or both categories. One should not conclude that the display of the Class 6.2, Infectious Substances label implies that Category A substances are present (either alone or with Category B substances) because the display of the Class 6.2, Infectious Substances label is required for both categories. The TDG Directorate is considering an amendment to sections 1.39 and 4.22.1. The intent of this amendment is to require only the Category B mark on small means of containment containing infectious substances included in UN3373, BIOLOGICAL SUBSTANCE, CATEGORY B, instead of both the Class 6.2, Infectious Substances label and the Category B mark. With this amendment, the transportation of UN3373, BIOLOGICAL SUBSTANCE, CATEGORY B will be more closely harmonized with the requirements of international regulations.



Question

Section 4.6 of the TDG Regulations states that dangerous goods safety marks must be visible, legible and displayed against a background of contrasting colour. Could you define contrasting colour?

Answer

A contrasting background refers to the surface immediately surrounding the placard. This surface must be large enough to create, from a distance, a perception of different colour immediately surrounding the placard, also producing a contrasting effect with the colour of the placard. There is no prescription in the TDG Regulations as to how the contrasting colour effect should be obtained, or what should be considered an effective contrast. Common sense should prevail in this matter.



Question

Where should the subsidiary label be affixed on a small means of containment?

Answer

Currently subsection 4.10(3) of the TDGR states that when a subsidiary class label is required, it must be displayed on any side of the small means of containment except top or bottom. There is no requirement for both primary and subsidiary label to be on the same side; however we do recommend, when there is sufficient space, that both primary and subsidiary labels be on the same side.



Question

When dangerous goods that are classified as class 2.3 are transported from the United States into Canada, the large means of containment are placarded with the poison inhalation placard as required by 49 CFR. When these large means of containment are returned to the U.S., the TDG Regulations requires that the Class 2.3 placard be displayed. Can we display both the poison inhalation placard and the Class 2.3 placard on the large means of containment at the same time to satisfy the requirements of both 49 CFR and the TDG Regulations?

Answer

Yes, both the poison inhalation placard and the Class 2.3 placard may be displayed at the same time. The poison inhalation placard is not a prescribed - dangerous goods - safety mark under the TDGR, but it would not be considered misleading if it were displayed on a large means of containment at the same time as a class 2.3 placard.



Question

A road vehicle is transporting 5 cylinders of propane each properly labeled in accordance with the requirements of sections 4.10 to 4.12. The cylinders are stored in a cabinet on the back of the vehicle; if the cabinet is labeled with the proper safety marks so that the labels are seen from outside the vehicle, would this satisfy the requirements of subsection 1.32.3?

Answer

Section 4.10 of the TDG Regulations requires that a label be displayed on all dangerous goods in transport in the small means of containment. Sections 4.11 and 4.12 require that the shipping name and UN number of the dangerous goods be displayed on a small means of containment, besides the label showing the primary class, when a label is required to be displayed by 4.10. A label, the shipping name and UN number of the dangerous goods must be displayed on cylinders that contain a dangerous good. If the cabinet that contains the cylinders is smaller than 450L it would be considered a small means of containment and therefore a label, the shipping name and UN number of the dangerous goods would also need to be displayed on the cabinet. If the cabinet is a small means of containment and the labels displayed on it are visible from outside the vehicle, the requirement of paragraph 1.32.3(d) would indeed be satisfied.



Question

Dangerous Goods Advisory Notice TP9554E Volume 5 shows full color placards for each class and others with a white square for insertion of UN numbers. Can we as a carrier use the white squared style placards, without insertion of UN numbers for shipments over 500 kg, not requiring an ERAP and under 4000 kg?

Answer

No, placards must be as illustrated in the Appendix to Part 4 of the Transportation of Dangerous Goods Regulations. When UN numbers are required to be displayed, the Regulations require the number to be displayed either on an orange panel besides the primary class placard or within a white rectangle on the placard; this is the only instance where a white square can be displayed on the placard.



Question

Is the use of the « Drive Safely » placard or other similar messages on placards considered a misleading safety mark and therefore a violation under TDGR?

Answer

No, in Canada misleading safety marks are those that mislead as to the presence of dangerous goods or the nature of the danger posed by the goods. Such placards are however considered misleading in the United States.



Question

Our company is developing a consolidated North American product line with common labeling and packaging for products so they can be produced and shipped from anywhere within the US or Canada to anywhere in either country whenever possible. The US has a requirement to include « RQ » in front of or following the shipping name for products that are in excess of the reportable quantity for a regulated material. Is this acceptable for shipments within or originating in Canada? When a product is otherwise not regulated under either DOT or TDG, but requires the « RQ » designation, in the US it is assigned to Class 9 with « RQ, Environmentally Hazardous Substances, N.O.S. » with the chemical name in brackets. Is this designation acceptable for shipments within or originating in Canada or would something different have to be done?

Answer

« RQ » in front of a shipping name is acceptable in Canada - it does not break the sequence of information. Within Canada, if a consignor determines, according to the criteria provided in Part 2 of the TDGR, that a substance is included in Class 9, then the appropriate shipping name must be selected and all the regulations (documentation, safety marks, packaging, training, reporting, etc.) must be complied with unless there is an exemption. It must be noted that section 1.11 of the TDGR applies for transport between Canada and the United States of substances that are regulated in the United States but not in Canada.



Question

Can I display the anhydrous ammonia (UN1005) placard with the class 2.2 primary class placard for a shipment of anhydrous ammonia coming from the United-States into Canada?

Answer

This is not permitted for anhydrous ammonia. The class 2.2 primary class placard must never be used in Canada for anhydrous ammonia. However, it is permitted to simultaneously display the applicable Canadian and the Class 2.3 American placards. For example, one of the permitted Canadian placards(class 2.3 primary class placard or anhydrous ammonia placard, UN1005) and the American class 2.3 bearing the « inhalation hazard » marking may be displayed at the same time on a highway tank.

Date modified:
2012-02-15