Thursday, May 27, 2004
Introductory Remarks and Presentation of the TDG Act and the Review Process
Mr. Raymond Auclair, Director of Research Evaluation and Systems, Transport Dangerous Goods, opened the meeting with a presentation on the TDG Act and the purpose and procedures of the review.
Here is a copy of the slide presentation on the Review and the Act used by Mr. Auclair.
Following the presentation period, there was time reserved for questions and answers. We received questions and comments about the TDG Act, the TDG Regulations, the program and the review process itself. We have tried to summarize the topics in this list. Some portions of the answers were added after the fact for the purpose of encouraging future discussions.
B-6 Readily available documents. (in regards to the railway industry). It was noted that employees carrying dangerous goods should be made aware and be able to see the manifest.
This appears to be more of an OSH issue (e.g., WHMIS) than a TDG issue. However, the comment will be passed on to the decision-makers in the review of the TDG Act.
D-3 Fixing the wording. The phrases “immediate notification” and “security breach” were brought up for clarification.
A-5 TDG Security Clearance Certificates. Participants were concerned that this would apply to all people and for all Dangerous Goods. Distinction between ERAP and non-ERAP DG's should be made. And application only to ERAP DG's would be better. (creation of a 2 tier system). Also, issues were raised concerning the privacy of individuals who would apply for such a certificate and the criteria used to screen in/out.
As the discussion only dealt with general concepts, participants are encouraged to send their specific comments to us (TDGAct@tc.gc.ca) so that we may compile them for the decision-makers. As written, A-5 does include the possibility that the requirement could be made applicable to all dangerous goods, not only ERAP. Because proposals deal, so far, only with existing security clearance systems that are provided by and controlled by government agencies (e.g., FAST, by customs) topics such as privacy had not been raised yet.
There were other issues raised, strictly concerning regulations; they are submitted to the TDG Regulations team.
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