Emergency Response Assistance Plans (ERAPs)
- Section 1: What is an ERAP
- Section 2: Background
- Section 3: When is an ERAP required
- Section 4: Who Requires an ERAP
- Section 5: ERAP Application Process
- Section 6: ERAP Review and Approval Proces
- Section 7: UN numbers not currently in TDGR that require an ERAP
- Section 8: Content of an ERAP
- Section 9: Emergency Response Contractors
- Section 10: Contacts
Part 7 of the Transportation of Dangerous Goods Act 1992, requires that before a person offers for transport or imports certain dangerous goods, the person must have an approved Emergency Response Assistance Plan (ERAP).
The application and supporting information must be forwarded to the following location (electronic format is preferred):
Chief, Response Operations
Transportation of Dangerous Goods
Place de Ville, Tower C, 9th Floor (ASDB)
330 Sparks Street
Ottawa, ON K1A 0N5
Section 1: What is an ERAP
An ERAP or Emergency Response Assistance Plan is a plan that describes what is to be done in the event of a transportation accident involving certain higher risk dangerous goods. The ERAP is required by the Transportation of Dangerous Goods Regulations (TDGR) for dangerous goods that require special expertise and response equipment to respond to an incident. The plan is intended to assist local emergency responders by providing them with technical experts and specially trained and equipped emergency response personnel at the scene of an incident.
The ERAP will describe the specialized response capabilities, equipment and procedures that will be used to support a response to incidents involving high risk dangerous goods. The plan will also address emergency preparedness, including personnel training, response exercises and equipment maintenance. The ERAP plans supplement those of the carrier and of the local and provincial authorities, and must be integrated with other organizations to help mitigate the consequences of an accident. This integration is usually accomplished by working within an incident management system – usually an Incident Command System or ICS. The ICS is a system where multiple authorities and response organizations are integrated into a common organizational structure designed to improve emergency response operations. The Incident Commander is the person with overall responsibility for the response and is usually a senior member of the local fire or police department.
Section 2: Background
The requirement for an Emergency Response Assistance Plan (ERAP) can be traced back to recommendations made by Justice Grange following the enquiry into the 1979 Mississauga train derailment. This derailment caused the rupture of several rail cars, including chlorine and several propane tank cars. The chlorine leak led to an evacuation of approximately 220,000 people, the largest peace time evacuation in North America at the time. The derailment clearly demonstrated a need for specialized response teams and equipment to provide support to first responders during major releases of high risk dangerous goods.
The Grange Commission Report recommended that any shipper of dangerous goods be required to have a Transport Canada approved emergency response plan to control releases of dangerous goods in the event of an accident.
Section 3: When is an ERAP required
Part 7 of the Transportation of Dangerous Goods Act 1992, requires that a person have an approved ERAP before offering for transport or importing certain dangerous goods above a quantity specified in Column 7 of Schedule I of the Transport of Dangerous Goods Regulations. If no number (or reference to a special provision) appears in column 7, an ERAP is not required. If a number appears in column 7 of Schedule I, then we must refer to Section 7.1 of the TDG Regulations.
Section 4: Who Requires an ERAP
A Transport Canada approved ERAP is required by a person who imports or offers for transport a dangerous good consignment that requires an ERAP. Note that for the purpose of the TDG Act and Regulations, a person includes an organization or company. The term "offer for transport" is defined in the TDG Regulations as follows:
Offer for transport means, for dangerous goods not in transport, to select or allow the selection of a carrier to transport the dangerous goods, to prepare or allow the preparation of the dangerous goods so that a carrier can take possession of them for transport or to allow a carrier to take possession of the dangerous goods for transport.
For example, the person that is allowing the carrier to take possession of the dangerous goods (i.e. the person who has the authority to allow access to the product) is offering for transport. There may be more than one person offering the same consignment for transport. The consignor is responsible to ensure the shipping document is in compliance with TDGR, including accurate ERAP information. If a producer/manufacturer of the dangerous goods is involved in the offer for transport from their facility, they must use their ERAP since they are not permitted to use someone else's plan.
Import is defined as follows:
Import means import into Canada, and includes transporting goods that originate from outside Canada and pass through Canada to a destination outside Canada, except when the goods are being transported on a ship or aircraft not registered in Canada.
The importer in Canada is usually the person who is receiving the goods or who is causing the dangerous goods to enter Canada.
If product is transiting through Canada, each carrier that takes possession of the dangerous goods becomes an importer as per the definition of import above (including a Canadian port since they have possession of the dangerous goods for the purpose of transportation). This ensures that there will always be someone in Canada responsible for the ERAP requirement. An ERAP will only be registered to a company that is established in Canada. If, for example, a US based carrier requires an ERAP because the dangerous goods being transported are transiting through Canada, the carrier will have to obtain a power of attorney with an agent in Canada in order to register the ERAP. The power of attorney will ensure that the US based company is subject to Canadian legislation. Similarly, a US based company that is offering for transport may register an ERAP through a power of attorney.
Section 5: ERAP Application Process
The process to register an ERAP can be broken down in these basic steps:
Determine if an ERAP is required for the consignment (see Section 3);
Determine if YOU require an ERAP (are you importing or offering for transport?) – see Section 4 for guidance;
Determine if you will use in-house resources or emergency response contractors for response (or a combination of the two); If the latter, confirm that the emergency response contractor has the capability to respond to the dangerous goods and means of containment; See Section 9 for help in finding response contractors;
Complete a Potential Accident Assessment (PAA) as per 7.2(2)(h) of the TDG Regulations (see Section 8 for a sample PAA);
Prepare or have someone prepare the Emergency Response Assistance Plan (ERAP)(see Section 8 for guidance);
Prepare the ERAP application by filling out form 16-0075E (sample applications are available upon request);
Submit the application to the Chief, Enforcement and Response Operations. You must include a copy of the ERAP, the Potential Accident Assessment and signed agreements with third party response contractors (including mutual aid agreements if the mutual aid is an integral part of your response capability).
Once completed, the application and supporting information must be forwarded to the following location (electronic format is preferred):
Chief, Enforcement and Response Operations
Transportation of Dangerous Goods
Place de Ville, Tower C, 9th Floor (ASDB)
330 Sparks Street
Ottawa, ON K1A 0N5
Section 6: ERAP Review and Approval Process
Once you have submitted an ERAP application to Transport Canada for approval, a Remedial Measures Specialist (RMS) will be assigned to review your file. The RMS may contact you to verify the contents of the application and may request changes or additional information. The timeframe for the review of the initial application by the RMS is typically 15 business days if the information submitted is complete. Once the RMS has completed the evaluation of the application, he/she will make a recommendation for the approval or rejection of the application to the Chief, Enforcement and Response Operations (CERO). If the ERAP is approved, an official approval letter will be issued to the applicant. Product may not be shipped until the approval letter has been received confirming plan approval.
ERAP approvals are issued for a specified period of time. The applicant will have to re-apply prior to the plan expiration. The applicant is encouraged to keep a copy of the original application on file and to modify it as required for future updates.
A unique ERAP registration number will be assigned to your company. This number will have to appear on the shipping documents along with the activation phone number, in accordance with Section 3.6 of the TDG Regulations.
Section 7: UN numbers not currently in TDGR that require an ERAP
Section 8: Content of an ERAP
The emergency response assistance plans must address the following basic elements of emergency response:
Hazard Identification and Analysis
A Potential Accident Analysis must be included in the plan as per 7.2(h) of the TDG Regulations, including an analysis of how an accidental release could occur, potential consequences related to a release and response actions that can be taken to mitigate the release or potential release.
Roles and Responsibilities
The roles and responsibilities of key personnel must be described in the plan, including senior-level management (for authorizations), technical advisors, team leaders, response team members, specialized resources that are critical to the response (e.g. media relations, medical resources).
The plan must include internal and external resources required for response, including response contractors, technical advisors and resources for specialized tasks (e.g. vent and burn).
Third Party Agreements (if applicable)
Third party agreements between the plan holder and the primary response contractor must be provided. Agreements between the primary response contractor and the subcontractors must also be provided describing the product(s) to which the subcontractors will respond and the resources they must supply. All copies of the agreements must be signed.
Emergency Response Procedures
The ERAP must include written procedures for critical tasks (e.g. product transfer, containment). Those procedures may be in a different document if referred to in the ERAP and provided with the application.
The plan must include a contact list for internal and external resources that are required to support the response. For example, this would include contact information for response contractors, suppliers, poison control centres, air or marine charters.
Records must be maintained for training and exercises related to the plan, equipment maintenance and ERAP activation and must be available to TDG Inspectors upon request. Documentation of accident response debriefs is also recommended.
The plan holder must maintain a listing of emergency response activities related to response to products requiring an ERAP including a brief description of the remedial actions taken.
The ERAP must specify the steps necessary for its activation in an emergency. It must include procedures to notify key response personnel.
The plan must describe the response actions that can be implemented to support a response (e.g. containment, confinement, transfer, neutralization)
A situation assessment is required to help responders define critical objectives and priorities for response. The situation assessment must be re-evaluated continuously and must address the following:
- The specific nature of the emergency (e.g. product, releases or potential for release, fire;
- Modifying conditions (e.g. weather, location, topography);
- Potential threats to life, property and the environment;
- Appropriate protective and corrective strategies;
- Re-evaluation of the situation on a continuous basis;
The plan must address mobilization of response resources, including identification of persons with the authority to mobilize resources. Mobilization options must be appropriate for the geographical area of coverage and mode of transport (e.g. consider air and marine transport as appropriate).
The ERAP must address the assessment of damage to the means of containment to determine the best course of action (i.e. product transfer, depressurization, etc.). Resources with expertise in damage assessment must be identified in the plan. The plan should also identify the criteria or methodology used to conduct a damage assessment.
Training and Exercises
Response personnel identified in the ERAP must be trained on critical aspects of the response plan (e.g. product transfers, air monitoring, containment options, Incident command system, etc.). A training matrix must be included in the plan.
Equipment availability and Maintenance
The plan holder or contractor must identify how the response equipment identified in the ERAP is adequate; available from a geographic perspective, can be used in a timely manner and serves its purpose. The response equipment must also be inspected and maintained in a state of readiness. Inspection and maintenance records must be retained and made available to a TDG inspector upon request.
Section 9: Emergency Response Contractors
Emergency Response Contractors and Associations offer a wide range of services to companies or organizations requiring an Emergency Response Assistance Plan (ERAP). The services provided by these contractors or associations may include: guidance and advice, provision of a 24 hours emergency telephone number, development of response plans for the clients, provision of response teams and specialized response equipment necessary to respond to accidents involving dangerous goods, and they may file an Emergency Response Assistance Plan with the Director General on behalf of their clients.
Please note that when resources from a contractor or association are necessary, the person requiring the ERAP must demonstrate a contractual arrangement with the selected contractors or associations before the ERAP is approved. It is also the responsibility of the person requiring the ERAP to verify and ensure that a contractor or association is capable of providing the required response.
Emergency Response Contractors
- Canadian Emergency Response Contractors' Alliance (CERCA): http://www.cerca-aceiu.ca/
For LPG only
- Emergency Response Assistance Canada (ERAC) http://www.erac.org
- Association Québécoise du propane (AQP): http://propanequebec.com/nous-joindre/
For Class 7 only
- Class 7 specialists
Energy Solutions Canada
Stuart Hunt and Associates
Section 10: Contacts
Regional Remedial Measures Specialists
Atlantic Region (PE, NB, NS, NL)
Prairie and Northern Region (SK, AB, MB, NT, NU)
Pacific Region (BC)
Headquarters (for foreign locations)
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