Transportation of Dangerous Goods FAQs

You may browse the list of FAQ's by topic or by Part of the TDG Regulation:

  1. TDG General FAQ
  2. Exemptions
    TDG Regulations (Part 1)
  3. Classification
    TDG Regulations (Part 2)
  4. Documentation / Shipping Papers / Waybill
    TDG Regulations (Part 3)
  5. Labels and placards
    TDG Regulations (Part 4)
  6. Containers
    TDG Regulations (Part 5)
  7. Training
    TDG Regulations (Part 6)
  8. Emergency Response Assistance Plan
    TDG Regulations (Part 7)
  9. Accidental Release Report Requirements
    TDG Regulations (Part 8)
  10. Rail Transport
    TDG Regulations (Part 10)
  11. Protective Direction
    TDG Regulations (Part 13)
  12. Equivalency Certificates / Permits
    TDG Regulations (Part 14)

TDG General FAQ

Question: How can I obtain a copy of the TDG Clear Language Regulations?

Answer: Electronic versions of the TDG Act and TDG Regulations can be found online.

Transport Canada does not distribute paper copies of the TDG Act or Regulations. Here is a list of known distributors.

Question: How do I sign up for the Transport Dangerous Goods newsletter?

Answer: The newsletter is available upon request and distributed free of charge to more than 23,000 readers in Canada and abroad. To subscribe to the electronic version, use this link http://wwwapps.tc.gc.ca/Comm/5/ListServ/Lg.aspx and enter your e-mail address. Then select the Transport Dangerous Goods Newsletter under "Safety and Security Group" heading.

To receive the paper version or to request an issue published prior to 2003, please contact the TDG Directorate by email at TDGNewsletter-NouvellesTMD@tc.gc.ca.

Exemptions
TDG Regulations (Part 1)


Exemptions - Overview

Canada's rules for transporting dangerous goods are called the Transportation of Dangerous Goods Regulations (i.e. TDG Regulations). The TDG Regulations have 16 Parts and 3 Schedules.

Unlike the Regulations in the United States, which are called the 49 CFR and only apply to hazardous materials in commerce, Canada's TDG Regulations apply to everyone. They even apply when someone transports dangerous goods such as gasoline, oxygen and propane for personal use. However certain exemptions exist for small quantities or for specific situations. You can find most of these exemptions, which are called "special cases", in Part 1 of the TDG Regulations, under sections 1.15 to 1.48.

Question: How does the 150 kg gross mass exemption (section 1.15) work?

Answer: The "150 kg gross mass exemption" will exempt a person from most parts of the Transportation of Dangerous Goods (TDG) Regulations if they meet all exemption conditions. It is the most commonly used exemption under the TDG Regulations. In fact, most people use this exemption without even knowing it. You use it when you bring small amounts of dangerous goods such as gasoline, propane, paint, etc. home from the place of purchase.

This exemption can only be used if the dangerous goods are available to the general public. In addition, the dangerous good must be transported by the user/purchaser or by a retailer to or from a user/purchaser. This means that carriers, who are not the retailer, cannot use this exemption.

Since you may not transport all dangerous goods under this exemption, it is important to check subsection 1.15(2) first. It will list the products that CANNOT be transported under this exemption.

Below are some key points to remember:

  • The total gross mass of all dangerous goods (i.e. oxygen, propane, gasoline, etc) must not be greater than 150 kg. "Gross mass" includes the weight of the container and all of its contents.
  • The dangerous goods must be packed in containers that weigh 30 kg or less (except for gases – see below).
  • The dangerous goods must be available to the general public and transported by the user/purchaser or by a retailer to or from a user/purchaser.
  • The containers must be designed not to leak under normal conditions of transport.
  • You must not combine this exemption with:
    • exemptions in sections 1.16, 1.21 and 1.22, or
    • With a shipment of dangerous goods that requires a shipping document (i.e. a fully regulated shipment).

When using the "150 kg Gross Mass Exemption" for class 2 gases, there are two important things to remember.

  • If you are transporting a gas such as propane or oxygen, the cylinder must be certified for use in Canada and marked with the letters TC.

Cylinders certified for use in the United States will be marked with the letters "DOT". As a general rule, you may not use cylinders only marked with the letters DOT in Canada. You will find certain exceptions to this rule in section 5.10(2)(c). It's possible that a cylinder can be certified for use in Canada and the US. If this is the case, the cylinder will be marked with the letters "DOT/TC".

  • Flammable gases, such as propane or acetylene, are limited to a cylinder size of 46L.

As with any exemption, if you cannot meet one of the specified conditions, then the exemption does not apply and you must comply with the entire TDG Regulations. This means you might need a shipping document, labelling, placarding, training, a certified container or package, etc.

Question: What is a “Limited Quantity” and how does the exemption work (section 1.17)?

Answer: A limited quantity is a small quantity of dangerous goods to which the general public normally has access, such as aerosol sprays and small cans of paint. Since dangerous goods cannot all be shipped as limited quantities, you need to consult Column 6(a) of Schedule 1. You must not ship dangerous goods as a "limited quantity" when the index in Column 6(a) is "0".

When shipped as limited quantities, dangerous goods (called Hazardous Material or hazmat in the United States) are exempt from several sections of the TDG Regulations. For example, shipping documents, labels, placards, standardized packaging, etc., may be exempted if you meet all of the conditions. It is therefore important to read section 1.17 thoroughly.

When using this exemption, each means of containment (i.e. box, etc.) must have a gross mass of 30 kg or less and display one of the following international  marks:


Image A


Image B (in compliance with International Civil Aviation Organization (ICAO) Technical Instructions by Air)

Until December 31, 2020, instead of the international mark, the means of containment may display:

  • the words "Limited Quantity" or "quantité limitée";
  • the abbreviation "Ltd. Qty." or "quant. ltée";
  • the words "Consumer Commodity" or "bien de consommation";
  • the UN number of each limited quantity of dangerous goods, preceded by the letters "UN", on a square on point (see example below).

The maximum capacity of the inner container (i.e. gas cylinder, etc.) is limited to the number indicated in Column 6(a) of Schedule 1:

  • mass in kilograms (kg), for solids;
  • volume in litres (L), for liquids;
  • capacity of the container in litres (L), for gases.

For example: Methanol (UN1230) may be transported as limited quantities, since the number in Column 6(a) of Schedule 1 is "1". Methanol can be stored in bottles with a maximum volume of 1 litre. These bottles can be placed in a box not exceeding 30 kg in weight. The box must display the international symbol or any of the other aforementioned markings. Lastly, section 1.17 sets no limit on the number of 30 kg boxes that may be transported in a vehicle.

Note:  Class 1 Explosives (i.e. munitions, etc.) cannot be transported in Canada as a limited quantity. The Explosives Exemption is found in section 1.31.

Question: I use medical oxygen (UN1072) for personal use. What are the rules?

Answer: Since the requirements change depending on the type of vehicle you intend to use, this question is divided into three parts.

  1. Personal vehicle
  2. Passenger vehicle (i.e. bus or Taxi) / passenger ship (i.e. Ferry)
  3. Aircraft

1. Personal vehicle

Under section 1.15 of the TDG Regulations, there is an exemption that will allow you to transport a "gross mass" of up to 150 kg of oxygen. The term "gross mass" is defined as the combined weight of the cylinder and its contents.

To use this exemption, the cylinder must be certified for use in Canada and be marked with the letters "TC". Cylinders certified for use in the United States will be marked with the letters "DOT". A cylinder certified for use in Canada and the US will be marked with the letters "DOT/TC".

2. Passenger vehicle (i.e. bus or Taxi) / passenger ship (i.e. Ferry)

Before travelling, you should notify the bus or ferry operator that you plan to transport the compressed oxygen (UN1072). Since they are private companies they have the right to refuse your cylinders for transport.

3. Aircraft

Read Civil Aviation's TIP titled: Passengers with medical oxygen.

Question: How many jerricans of gasoline may I transport in my private vehicle?

Answer: There is an exemption called "150 kg Gross Mass Exemption" that allows you to transport a gross mass of up to 150 kg of gasoline. When using this exemption, the weight of the container and the gasoline may NOT exceed 30 kg. A typical 25 L jerrican of gasoline would most likely weigh less than that. If each jerrican weighed 25 kg, then you could transport up to 6 jerricans (e.g. 25 kg x 6 = 150 kg).

The "Limited Quantities Exemption" (section 1.17) may allow you to transport more than 150 kg without having to comply with the entire TDG Regulations. For more details, please see the following question: What is a "limited quantity", and how does this exemption work (section 1.17)?

For a more detailed explanation of this exemption, please consult the FAQ titled:
How does the 150 kg gross mass exemption (section 1.15) work?

Question: How much propane may I carry when I go camping?

Answer: We will address this question in two parts:

  • Personal vehicle / Recreational Vehicle
  • Ferry

1. Personal vehicle / Recreational Vehicle

Under section 1.15 of the TDG Regulations, there is an exemption that will allow you to transport a "gross mass" of up to 150 kg of propane. The term "gross mass" means the combined weight of the cylinder and its contents (propane). The cylinders may NOT have a capacity larger than 46 litres. For your information, a typical BBQ cylinder has a capacity of approximately 21 litres.

In a recreational vehicle (RV), any propane that is connected to the heating, ventilation, or refrigeration system of the RV, would not count towards the 150 kg limit. This exemption for the propane connected to the RV is listed under section 1.27 of the TDG Regulations. Any additional propane cylinders that you wish to carry, and that are not connected to the RV, would be counted towards the 150 kg limit.

Finally, the cylinder(s) must be certified for use in Canada and be marked with the letters "TC". Cylinders certified for use in the United States will be marked with the letters "DOT". A cylinder certified for use in Canada and the US will be marked with the letters "DOT/TC". As a general rule, you may not use cylinders only marked with the letters DOT in Canada. However, there are certain exceptions to this rule.

For more information on these exceptions, please read the FAQ titled:
"Can I fill a cylinder in Canada that I purchased in the United States?"

2. Ferry

Before travelling, you should notify the ferry operator that you plan to transport the propane (UN1978 or UN1075). Since they are private companies they have the right to refuse your cylinders for transport.

Question: How many cylinders may I carry in my vehicle?

Answer: The answer depends on:

  • the type(s) of gas you are transporting,
  • the size of each cylinder, and
  • the total gross mass of all the cylinders.

Certain exemptions exist for small quantities or for specific situations. You can find most of these exemptions in Part 1 of the TDG Regulations, under sections 1.15 to 1.48. Some exemptions that can be used for gases can be found under section 1.15 and section 1.32.3.

Section 1.15 allows a person to transport a gross mass of up to 150 kg of product. To learn more, please consult the FAQ titled:"How does the 150 kg gross mass exemption (section 1.15) work?"

Most welders and trades persons may use the exemption under section 1.32.3. This means that they do NOT require a shipping document or TDG training. This exemption allows a person to transport up to 500 kg of the gases listed below. When using this exemption, the maximum amount of cylinders is limited to five. The cylinders must be visible from outside the vehicle.

  • UN1001, ACETYLENE, DISSOLVED,
  • UN1002, AIR, COMPRESSED,
  • UN1006, ARGON, COMPRESSED,
  • UN1013, CARBON DIOXIDE,
  • UN1060, METHYLACETYLENE AND PROPADIENE MIXTURE, STABILIZED,
  • UN1066, NITROGEN, COMPRESSED,
  • UN1072, OXYGEN, COMPRESSED, or
  • UN1978, PROPANE;

Note: This list does not include UN1956 Compressed Gas NOS.

Question: Cargo truck tanks are sometimes furnished with additional small tanks, permanently attached to the truck frame and filled with an ammonia solution (UN 2672). Such a tank is rigidly plumbed to the main tank and its purpose is to scrub hydrogen sulphide (H2S) from sour crude oil during the main tank loading. Can the ammonia solution in the scrubber tank be exempted as per section 1.27 taking into account that the ammonia is only used to safeguard the fill-in operation and protect the environment?

Answer: The ammonia contained in the tank (scrubber) is necessary for the safe operation of the means of containment and is necessary for the safety of the people loading and unloading the crude oil. The ammonia and the means of containment used to contain it are therefore exempt under section 1.27. The associated piping system which is mounted to the crude oil tank and containing the crude oil vapours would be subject however to the design and construction requirements of CSA B620 and to the periodic inspection and test requirements of Clause 8.

Question: Does the exemption under section 1.25 apply to all transportation within a facility?

Answer: When a segment of a transportation event is due to occur or has occurred outside the boundaries of a facility, the whole transportation event must be done in compliance with the Regulations, including those segments taking place within a facility.

Question: Can a police officer on travel status and handling or transporting ammunition or ammunition loaded in a firearm be exempt from the TDG Regulations, except Part 6 on Training, according to section 12.4(2) of the TDGR?

Answer: Yes, a police officer is considered on duty while he is on travel status.

Question: What is the intent of section 1.26?

Answer: The Emergency Response Exemption was intended to apply to vehicles dedicated solely to emergency response. It does not apply to vehicles or equipment that might be used in emergency response but are also used for different purposes. Therefore, dangerous goods onboard a vehicle not exclusively used for emergencies are not exempt.

Question: When using a dangerous good (such as ethanol or formaldehyde) to preserve a biological sample (such as a frog or an animal organ) during transportation, should the dangerous good be exempt from the Regulations?

Answer: No, sections 1.19.1 and 1.19.2 do not apply to this situation. They apply only to samples that are believed to be dangerous goods. In this case, the sample is not a dangerous good, it is the substance used to preserve the sample that is a dangerous good.

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: What does subparagraph 1.35(a)(ii) mean regarding the placards or labels displayed on a means of containment that is visible from outside of the road vehicle?

Answer: The provision states that where placards cannot be displayed on all four sides of the tank because of the tank configuration (for example if only two or three of the sides are visible from outside the vehicle), placards are required only for those sides that are visible.

Classification
TDG Regulations (Part 2 - Classification)

Question: What do the letters «N.O.S.» mean?

Answer: N.O.S. means « Not Otherwise Specified ». It describes dangerous goods that do not have a specific entry by name in Schedule 1 of the TDG Regulations.

For example, both gasoline and diesel fuel are listed by name in Schedule 1. If these two substances were mixed, the resulting mixture of these two products would still be regulated as a dangerous good. However, the mixture could no longer be described as "Gasoline" or "Diesel" since it would no longer have a specific name in Schedule 1 of the TDG Regulations. As such, the mixture would be classified as UN1993 - FLAMMABLE LIQUID, N.O.S.

Question: How do I know if my product is regulated under the TDG Regulations?

Answer: Check with the manufacturer/consignor or the material data safety sheet (MSDS) to find out if your product is regulated.

If you are the manufacturer, you must test your product in accordance with Part 2 of the TDG Regulations.

Question: Where can I get my product analyzed for classification?

Answer: The TDG Directorate keeps a list of laboratories that provide dangerous goods analysis and classification.

Please note: The TDG Directorate has not examined or certified any of the laboratories. Laboratories choose to appear on the list. Being on this list does not mean Transport Canada or the TDG Directorate endorse or approve their services.

Question: How do I get my company's name on TDG's list of analysis / classification laboratories?

Answer: If you want your company’s name added to TDG’s list of analysis/classification laboratories, email us at TDGTraining-FormationTMD@tc.gc.ca.

Question: Is new motor oil classified as dangerous goods?

Answer: Generally, no. Why? Because its flash point is too high. The flash point is the lowest temperature at which the liquid (oil) gives off enough vapours to ignite. TDG Regulations do not regulate liquids with a flash point above 60°C. If the liquid has a flash point of 60°C or less, then the product would be classified as a flammable liquid. The lower the flash point, the more dangerous the product becomes.

Please note: Never assume that an oil is not regulated. Always check the material safety data sheet (MSDS) from the oil manufacturer.

Question: Is waste oil classified as dangerous goods?

Answer: Not usually. While dangerous to the environment, Transport Canada does not usually consider used oil or waste oil a dangerous goods unless it is contaminated by other products. This contamination could make the used oil either toxic (PCBs), flammable (gasoline) or corrosive (acids).

Section 2.2 of the TDG Regulations states that the shipper / manufacturer is responsible to determine whether the used oil is a dangerous good or not. One thing you can do to avoid oil becoming a dangerous good is to ensure that you only put used oil in the container and nothing else— no gasoline, no solvent, etc. This keeps your used oil as used oil only, and can be transported as non-regulated under TDG Regulations.

If you still want to ensure that your oil is not regulated, you must test a sample of the waste oil. You may ship small samples under section 1.19.1 of the TDG Regulations.

Finally, shipments of used motor oil may be subject to Environment Canada regulations and provincial regulations. To learn more, visit the Environment Canada website

Question: Can I use a UN number that is not included in the TDG Regulations?

Answer: Yes. Subsection 2.2(4) and Parts 9 and 10 of the TDG Regulations authorize you to use the classification from the:

  • International Civil Aviation Organization (ICAO) Technical Instructions for the transport of dangerous goods by air;
  • International Maritime Dangerous Goods (IMDG) Code for the transport of dangerous goods by ship; or
  • Code of Federal Regulations (49 CFR) (U.S. Regulations) for the transport of dangerous goods by road (Note: The NA numbers for 49 CFR are not permitted in Canada).

Question: Why is molten sulphur considered a Class 4.1 "Flammable Solid", when it is not solid and neither is it flammable when it becomes solid?

Answer: The classification for molten sulphur is taken from the UN Model Regulations. The terms "liquid" and "solid" are defined in the Transportation of Dangerous Goods Regulations and these definitions are also based on the UN Model Regulations. Molten sulphur is loaded and unloaded in a molten state, is transported at an elevated temperature and solidifies after loading; all of which explains the shipping name as well as the risks associated with its transport.

Question: Who is responsible for classification?

Answer: The consignor is responsible for determining the classification of dangerous goods. For dangerous goods included in Class 1, the consignor must use the classification determined by the Department of Natural Resources. For dangerous goods included in Class 7, the consignor must use the classification determined in accordance with the "Packaging and Transport of Nuclear Substances Regulations". For dangerous goods included in Class 6.2, the consignor may use the classification determined by Health Canada or the Canadian Food Inspection Agency.

The consignor may also use the classification of the manufacturer or a previous consignor. However, the consignor is responsible for making a proof of classification available to the Minister. The consignor is also responsible for certifying that the dangerous goods are properly packaged, classified and identified (see Consignor's Certification, section 3.6.1 or FAQ, Part 3).

Question: What is a proof of classification?

Answer: A proof of classification is a document that the consignor must provide upon request to the federal Minister of Transport. This document may be:

  • a test report;
  • a lab report; or
  • a document that explains how the dangerous goods were classified.

The proof of classification must include the following information:

  • the date on which the dangerous goods were classified;
  • if applicable, the technical name of the dangerous goods;
  • the classification of the dangerous goods; and
  • if applicable, the classification method used under this Part or under Chapter 2 of the UN Recommendations.

Documentation / Shipping Papers / Waybill
TDG Regulations (Part 3)

Question: Where can I find a transportation of dangerous goods form?

Answer: In the TDG Regulations, this is called a "shipping document". Transport Canada does NOT issue shipping documents. For a sample shipping document, see our TDG Bulletin entitled: "Shipping Documents".

The consignor (i.e. shipper) is responsible for creating a shipping document. To transport dangerous goods in accordance with the law, the information on the shipping document must meet the requirements set out in sections 3.5 and 3.6 of the TDG Regulations. As of July 15, 2015, the shipping document will also need to include a consignor's certification set out in section 3.6.1.

Here is a sample of a consignor's certification that you can find in section 3.6.1:

"I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, are properly classified and packaged, have dangerous goods safety marks properly affixed or displayed on them, and are in all respects in proper condition for transport according to the Transportation of Dangerous Goods Regulations."

Note: When shipping dangerous goods by air, the shipping document must have red hatchings that slant to the left or right, as shown below.


Question: What is a consignor's certification?

Answer: The consignor's certification is a note on the shipping document confirming that the dangerous goods have been properly classified and packaged, have dangerous goods safety marks properly affixed or displayed on them, and are in proper condition for transport according to the TDG Regulations.

The certification must be made by the consignor or an individual acting on behalf of the consignor, and his or her name (not signature) must appear on the shipping document. The consignor’s certification may appear on the back of the shipping document, as long as it is after the information required under section 3.5.    

The consignor's certification must be one of the five texts proposed in subsection 3.6.1(1).

Here is a sample of a consignor's certification that you can find in section 3.6.1:

"I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, are properly classified and packaged, have dangerous goods safety marks properly affixed or displayed on them, and are in all respects in proper condition for transport according to the Transportation of Dangerous Goods Regulations."

Question: Are the words “Residue – Last Contained” optional? Could these words be a heading?

Answer: The words “Residue – Last Contained” are optional. You have the option of either using the words “Residue – Last Contained” before or after the description of the dangerous goods, as mentioned in subsection 3.5(4), or indicating the quantity of dangerous goods as per paragraph 3.5(1)(d).

Question: Subparagraph 3.5(1)(d) does not specify whether the unit of measure must be recorded in litres for liquids and in kilograms for solids.

Answer: The quantity has never been dependant on the materials' physical state. The Regulations require that whatever is used must be in the SI format as per the given examples.

Question: Regarding single trip deliveries of petroleum crude oil from well site to battery, can one shipping document identifying numerous shipments from well site to battery be left with the consignee at the end of the day?

Answer: Subsection 3.2(6) requires the carrier to provide the consignee with a copy of « a document » (not the shipping document) identifying the dangerous goods for every shipment. This document can be of any type; a waybill would be acceptable. The Regulations also allows electronic documents, therefore something like an email would be acceptable AND the document can be delivered before the dangerous goods are turned over to the person.

Question: How should the quantity of gas contained in a gas cylinder be indicated on a shipping document?

Answer: When completing the information required on a shipping document, the quantity of gases must be indicated by stating, for each means of containment, the volume of the means of containment (e.g. 20 L cylinder) or its gross mass and tare weight.

Question: When the person in charge of the train prepares a consist and later finds out that it is incorrect or incomplete prior to the departure of the train, must the person prepare a new consist or can he just indicate the required changes to the train crew?

Answer: Section 3.3 requires that a consist be prepared by the person in charge of the train and given to a member of the train crew. The information on the consist must be kept up to date by the train crew and kept with the shipping document. This requirement applies when the train leaves the yard and therefore the information included on the consist must accurately correspond to the dangerous goods included in the railway vehicles, as specified in subsection 3.3(2). A draft or preliminary consist issued before the final train arrangement is made does not satisfy the requirements of section 3.3. The consist must include the information required by subsection 3.3(2) corresponding accurately to the train when it is formed and must be prepared in good faith. Therefore, if the person in charge of the train finds out before the departure of the train that the consist is incomplete or incorrect, the person must ensure a new consist is prepared and given to a member of the train crew before the train leaves the yard. A train is defined in the TDG Regulations as: 1) an engine or more than one engine coupled, with or without cars, or a track unit(s) so designated by its operating authority, displaying a marker(s) (as defined in the Canadian Rail Operating Rules); or 2. a number of railway vehicles coupled together moving at a velocity exceeding 24 km/h (15 mph) with at least one railway vehicle containing dangerous goods for which a placard is required to be displayed in accordance with Part 4, Dangerous Goods Safety Marks.

Question: Is it allowable to have an ERAP Plan number and activating telephone number on a shipping document when there are no dangerous goods that require an ERAP on the document?

Answer: A shipping document must contain the information TDG requires for the particular dangerous goods to which it relates but it may also contain any other information the consignor wishes, as long as the required information is easy to identify on the document. Therefore if the document contains what is required by the Regulations, the remainder of the information - including a valid ERAP Plan number and activating telephone number - constitutes "additional information" and does not contravene the TDG Regulations.

Question: Are the « technical names » that appear in parentheses behind some N.O.S. shipping names (such as UN1993 FLAMMABLE LIQUIDS, N.O.S.) considered to be part of the shipping name, or are they considered « descriptive text »? Must they be written in lower case?

Answer: The technical names are not part of the shipping name and are not considered descriptive text. That is why technical names are specifically mentioned in terms of the information required on a shipping document and on a small means of containment, as mentioned in special provision 16.

Question: May words such as « emergency contact » be added to the wording « 24 hour number » on the shipping document?

Answer: Neither subsection 3.4(1) nor the remaining provisions of the regulations will be contravened should the phrase « 24-Hour Number » appear with sufficient extra text to include the word « emergency » such as: « 24-Hour Emergency Number », « 24-Hour Number, for use in case of emergency », « Emergency 24-Hour number » or « 24-Hour Number Emergency Contact ».

Question: What happens when the consignor and carrier are the same person? What about retention of permanent shipping documents?

Answer: If the consignor is also the carrier, then that person must comply with both the consignor and carrier requirements of section 3.11.

Labels and Placards
TDG Regulations (Part 4 – Dangerous Goods Safety Marks)

Question: What placards and UN numbers are required on a compartmentalized highway tank that contains both UN1202 Diesel Fuel and UN1203 Gasoline?

Answer: Subsection 4.19(2) of the TDG Regulations explains how to display UN numbers for gasoline and diesel fuel.

You must display only the UN number for gasoline (UN1203), since it is the product with the lowest flash point. Gasoline has an approximate flash point of -43 °C, while diesel fuel is around 55 °C.

Note: If a compartment contains UN3475 (ETHANOL / GASOLINE BLEND), the UN number "UN3475" must be displayed, in addition to the UN number of the dangerous goods with the lowest flash point on each side and each end of the compartment.

Question: Can you explain the current placarding requirements?

Answer: The requirements for placarding can be found in Part 4 of the TDG Regulations.

Here are the five basic steps:

Step 1 – Placards on a Large Means of Containment (section 4.15)

The basic rule for displaying placards is simple: the primary class placard for each of the dangerous goods in a large means of containment must be displayed on each side and each end of the means of containment, regardless of the quantity.

Step 2 – Subsidiary Class Placards on a Large Means of Containment (section 4.15.1)

A subsidiary class placard is not always required. A placard indicating the subsidiary class of dangerous goods must only be displayed if:

  • an Emergency Response Assistance Plan (ERAP) is required; and
  • the dangerous goods have one of the subsidiary classes listed in section 4.15.1.

Step 3 – UN Numbers on a Large Means of Containment (section 4.15.2)

A UN number must be displayed on a large means of containment if the dangerous goods:

  • require an Emergency Response Assistance Plan; or
  • are a liquid or a gas in direct contact with the large means of containment.

*Note: A UN number must never be displayed on a large means of containment that contains explosives.

Step 4 – Danger Placard - Optional (section 4.16)

DANGER placards are optional. A DANGER placard may be displayed on a large means of containment, instead of any other placard required under section 4.15, if:

  • the large means of containment contains two or more dangerous goods that require different placards; and
  • the dangerous goods loaded into the large means of containment (i.e. vehicle, etc.) are contained in two or more small means of containment.

Subsections 4.16(2) and 4.16(3) describe situations where a DANGER placard cannot be displayed. These subsections must therefore be consulted to ensure that the safety marks are compliant.

Step 5 – Placarding Exemption for Dangerous Goods Having a Gross Mass of 500 kg or Less - Optional (section 4.16.1)

A placard does not need to be displayed on a road vehicle or railway vehicle if the dangerous goods have a gross mass of 500 kg or less. This exemption does not apply to the dangerous goods listed in subsection 4.16.1(2). Here are two examples:

In the first example, a road vehicle contains 400 kg of dangerous goods. These goods are not subject to the restrictions listed in 4.16.1(2), and since the road vehicle contains 500 kg or less of dangerous goods (400 kg), we can use this exemption and not display placards.

In the second example, a road vehicle contains 2,300 kg of dangerous goods. Of this quantity, 2,000 kg are subject to one of the restrictions listed in subsection 4.16.1(2), while300 kg are not subject to any of the restrictions. The 2,000 kg of dangerous goods that are restricted under subsection 4.16.1(2) require a placard, since these dangerous goods can never be exempted from placarding. However, when calculating the gross mass of the load, the gross mass of the non-exempted goods (2,000 kg) must be deducted from the total (in this case2,300 kg). The gross mass of the exempted dangerous goods is therefore 300 kg. Since this is less than the 500 kg limit, there is no need to display placards for these dangerous goods.

In addition to the above five steps, it is also important to consult the sections on explosives and gases (4.17 to 4.18.3).

Question: Can you explain the placarding requirements through an example?

Answer: For an example of how to placard, please review the following scenarios:

What placard(s) and/or safety mark must be displayed for a 400 kg shipment of Methyldichlorosilane (UN1242) in drums transported by road vehicle?

Since the basic rules state that a placard must be displayed for each of the dangerous goods on board regardless of quantity, the Class 4.3 placard must be displayed. A placard does not need to be displayed for the subsidiary classes, since an Emergency Response Assistance Plan (ERAP) is not required for this dangerous goods (which is one of the conditions required for displaying a subsidiary class placard). The UN number also does not need to be displayed, since an ERAP is not required and it is not a liquid or gas in direct contact with the large means of containment (road vehicle).

The DANGER placard cannot be used in this scenario, since we do not have two or more dangerous goods that require different placards. The Placarding Exemption for Dangerous Goods Having a Gross Mass of 500 kg or Less cannot be used either because Class 4.3 is subject to the restrictions set out in subsection 4.16.1(2).

Here is a second scenario:

What placard(s) and/or safety mark must be displayed for 200 kg of Gasoline (UN1203) and 200 kg of Sulfuric Acid (UN1830) transported by road vehicle?

Class 3 and 8 placards must be displayed in accordance with the basic placarding rule found in section 4.15. No subsidiary class placard is needed, since Gasoline and Sulfuric Acid do not have subsidiary classes. No UN number is required either, since these two dangerous goods do not require an ERAP and are not liquids or gases in direct contact with the large means of containment. Therefore, the first option is to display Class 3 and Class 8 placards (without a UN number).

Is it possible to replace these placards with the DANGER placard? Since the means of containment contains two or more dangerous goods that require different placards and the dangerous goods are contained in two or more small means of containment, and are not subject to a restriction under subsection 4.16(2), the DANGER placard may be used instead of the two primary class placards. Displaying the DANGER placard is the second option.

Lastly, can we use the Placarding Exemption for Dangerous Goods Having a Gross Mass of 500 kg or Less? Since the total gross mass of the dangerous goods is 400 kg (i.e. less than the 500 kg limit), and the dangerous goods are not subject to any restriction listed in subsection 4.16.1(2), the third option could be to transport them without a placard.

Question: Is it mandatory to display the DANGER placard (section 4.16) or to comply with the Placarding Exemption for Dangerous Goods Having a Gross Mass of 500 kg or Less?

Answer: No. The use of the DANGER placard, as well as the Placarding Exemption, is optional. You may choose to comply with the basic rule (section 4.15) and display placards for each of the dangerous goods.

Question: Are placards and UN numbers required on a highway tank that only contains a residue of liquid or gas?

Answer: Yes. Placards and UN numbers are required even for residue liquids or gases. However, once the tank has been cleaned and purged, the placards must be removed.

Question: When shipping UN3373 (BIOLOGICAL SUBSTANCE, CATEGORY B) in accordance with section 1.39, do I need to display the Class 6.2 label and the Category B mark?

Answer: No. While section 1.39 exempts the consignor from Part 3 (Documentation) and Part 4 (Dangerous Goods Safety Marks), it does not exempt the consignor from section 4.22.1 (Category B Mark).

Section 4.22.1 states that the Category B mark must be displayed, instead of the Class 6.2 Infectious Substances label, on a small means of containment containing infectious substances included in UN3373, BIOLOGICAL SUBSTANCE, CATEGORY B.

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 does the subsidiary label need to 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: Is a placard with "Drive Carefully" or a similar message considered to be a misleading safety mark, and therefore non-compliant with the TDG Regulations?

Answer: No. Judgement must be used in such cases. It is prohibited to display, on a means of containment or a means of transport, a mark other than a dangerous goods safety mark if the other mark is likely to be confused with a dangerous goods safety mark or is misleading as to the presence or nature of a danger. To be considered misleading, the mark must be similar enough to a safety mark to be mistaken for one.

Note: This scenario would be considered misleading in the United States.

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: 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: When shipping Anhydrous Ammonia from the U.S. to Canada, can I display the American Class 2.2 placard?

Answer: No, we do not allow the American Class 2.2 placard in Canada to represent dangerous goods that are classified in Canada as a Class 2.3. However, one of the acceptable Canadian placards may be displayed together with the American Class 2.2 placard.

In Canada, there are two options for displaying Anhydrous Ammonia placards:

  • Class 2.3 placard and UN number UN1005; or
  • Anhydrous Ammonia placard and, on at least two sides, the words "Anhydrous Ammonia, Inhalation Hazard" or "Ammoniac anhydre, dangereux par inhalation" (section 4.18.2).

Note: In general, labels and placards from the United States are accepted in Canada by virtue of the reciprocity that exists between the two countries. However, this reciprocity does not apply to American labels and placards for dangerous goods included in Class 2.3 and Class 6.1 (paragraph 9.1(1)c)). For these two classes, labels and placards must be those required by the TDG Regulations.

Question: A tank trailer is loaded with gasoline UN 1203. Its next load is diesel UN 1202. However the pump and hoses have not been cleaned and still contain gasoline residue, which placard should be displayed on the trailer, 1202 or 1203?

Answer: Our approach has been to placard for what is on board the vehicle. If it is emptied and refilled with diesel, then the 1202 placards would be displayed.

Container manufacture, selection and use (highway tanks, cylinders, drums, etc)
TDG Regulations (Part 5 – Means of Containment)

Question: What rules apply to slip tanks or tidy tanks?

Answer: The regulations are called the Transportation of Dangerous Goods Regulations (TDG Regulations for short). Part 5 of the TDG Regulations, states that most containers commonly referred to as "slip tanks" or "tidy tanks" must be certified by the manufacturer. This means that it must be manufactured to the Canadian General Standards Board Standard CAN/CGSB 43.146. There are certain times when a certified tank is NOT required. For example:

1) SLIP TANK FOR DIESEL ONLY (450 L limit – Section 1.33)

A tank with a capacity of 450 L or less does not need to comply with any standard if it only contains diesel. You will find this exemption under section 1.33 of the TDG Regulations.

Please note: You may NOT use this exemption to carry gasoline.

Also, when using this exemption:

  • you do NOT need a shipping document (Part 3);
  • the tank or the truck does NOT need labels or placards (Part 4); and
  • you do NOT need to be trained (Part 6).

2) SLIP TANK FOR GASOLINE AND DIESEL (2000 L limit – Section 1.35)

You will find another exemption for slip tanks under section 1.35. This exemption says that when you are transporting gasoline or diesel:

  • you do NOT need a shipping document (Part 3);
  • you do NOT need to display a UN number on the tank (Part 4); (Note: A label or placard must be still be displayed,) and
  • you do NOT need to be trained (Part 6).

You are NOT exempt from Part 5 (means of containment). This means that:

  • the slip tank (i.e. means of containment) must be certified by the manufacturer;
  • tank is subject to periodic inspections by a facility registered with Transport Canada; and
  • the tank(s) is/are limited to a total maximum capacity of 2000 L.

Question: How much diesel / gasoline may I carry in a slip tank?

Answer: The answer depends on whether you plan on using an exemption under section 1.33 or 1.35 of the TDG Regulations. For a more detailed explanation of section 1.33 and 1.35, please read the FAQ titled: "What rules apply to slip tanks or tidy tanks?"

If you do not want to use any of these exemptions, there is no limit. This means that:

  • you will need a shipping document for the product in the tank;
  • you must be trained as set out in Part 6 of the TDG Regulations;
  • you must have a valid training certificate with you at all times;
  • the tank must be must be certified by the manufacturer. This means that it must be manufactured and maintained in accordance with the Canadian General Standards Board Standard CAN/CGSB 43.146 or CSA B620; and
  • the tank is subject to periodic inspections by a facility registered with Transport Canada.

Question: Do I need double walled slip tanks to carry diesel / gasoline?

Answer: No. There are no Transport Canada requirements that currently exist for using "double walled" tanks for transporting products such as diesel fuel, fuel oil or gasoline. Although Transport Canada does not prohibit their use,

  • we do not believe they are necessary for safety, and
  • we do not recommend their use.

Even though it may seem to use a double walled tank to contain leaks, the inter-wall space of double-walled tanks might collect contaminants and moisture that can accelerate corrosion. Also, these tanks make it harder for inspectors to detect corrosion between the tank walls. Conducting effective and adequate periodic inspection of transport tanks is key to preventing leaks and other failures. Since double-walled tanks are more likely to corrode and are more difficult to inspect, they may be less reliable over the long term unless inspectors take sophisticated measures during periodic inspections.

Question: Where can I buy a certified means of containment (cylinder/ highway tank / drum / Intermediate Bulk Container or IBC)?

Answer: You can use the following two links to search our database of facilities registered by Transport Canada in your area:

Question: Can I fill a cylinder in Canada that I purchased in the United States?

Answer:

In some cases yes, however, in other cases a cylinder from the US cannot be filled in Canada.

The table below summarises the types of cylinders that can be used in Canada.

Date the cylinder was originally manufactured Cylinder specification
Before January 1, 1993

Cylinders manufactured before January 1, 1993 can be stamped with either of the following: TC, DOT, CRC, BTC, CTC, or ICC.

The following US specification cylinders must have been in use in Canada before January 1, 1993 and must be re-qualified by a facility registered with Transport Canada prior to filling.

  1. 49 CFR specification DOT-3B, DOT-3BN, DOT-3E, DOT-4AA480, DOT-4B, DOT-4B240ET, DOT-4BA, DOT-4BW, DOT-4D, DOT-4E, DOT-4L, DOT-8 or DOT-8AL, or
  2. 49 CFR specification DOT-39, if the cylinder has a service pressure less than or equal to 6.2 MPa (900 psig).

Reference: Paragraph 5.10(2)(b) or 5.10(2)(c) of the TDG Regulations.

After January 1, 1993 Must be stamped TC. Note: A cylinder may also be dual marked with TC/DOT
To learn more, please read the FAQ titled: "FAQ on Cylinders".

Question: Do trucks that transport batteries (UN 2794) have to comply with the CSA B621 standard given that the batteries (dangerous goods) are "in direct contact with a large means of containment" (i.e. the truck)?

Answer: Yes. Batteries are solid dangerous goods. While the CSA B621 standard does not stipulate the use of a truck of a certain specification to transport solids (Specific Requirement 4, CSA B621), it states that the vehicle must comply with Chapter 4 of the standard. The means of containment must therefore be water-tight and constructed so that neither rain nor road spray can come into contact with the dangerous goods. It must also be dust-tight and not release dangerous goods 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 propane tanks on 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. The propane tanks must comply with section 5.10 of the TDG Regulations.

TRAINING 
TDG Regulations (Part 6)

Question: When do I need training?

Answer: You should always assume you need training. The only time when training is NOT required is when you are using an exemption (i.e. special case). You will find most exemptions in Part 1 of the TDG Regulations from sections 1.15 to 1.48. You will find some other exemptions (Special Provisions) listed in Schedule 2 of the TDG Regulations that may exempt you from the training requirements.

Question: Once a person is trained, who issues the training certificate?

Answer: It's the responsibility of the employer to issue their employee a training certificate once a person has received adequate training.

Question: Is there a standard format for the training certificate?

Answer: No, there is no standard format but the certificate must contain all of the information required by section 6.3 of the TDG Regulations. Even though there is no standard format, we have a sample in our Advisory Notice titled: "Guidelines for training criteria".

Question: Are training certificates transferable from one company to another?

Answer: No, training certificates are NOT transferable. Once an employee has been trained, it's the responsibility of their employer to issue them a training certificate. If a person works for more than one company at the same time, the person would have more than one training certificate.

Question: I'm self-employed contractor. Who issues my training certificate?

Answer: As a self-employed person, you will issue your own training certificate. The purpose of the training certificate is to demonstrate that if someone handles, offers for transport or transports dangerous goods he or she is trained to fulfill their duties.

Question: Do you have a list of organizations that offer TDG training?

Answer: A list of organizations that offer general and specialized TDG training can be found at http://wwwapps.tc.gc.ca/saf-sec-sur/3/train-form/search-eng.aspx

The Directorate has not examined or certified any of the courses offered and the inclusion of this information does not imply endorsement or approval by Transport Canada or the Directorate.

Question: How do I add my company to the list of organizations that provide TDG Training?

Answer: If you wish to have your company's name added to the list of organizations that provide TDG training, please use our online form to submit your information.

Question: What training needs to be provided, by the employer, to employees who must handle dangerous goods for transport? What must their training certificate contain?

Answer: People who handle, offer for transport or transport dangerous goods need to be trained in accordance with the requirements in Part 6 of the Transportation of Dangerous Goods Regulations (TDG Regulations) or operate under the supervision of a trained person holding a valid training certificate. It is also a requirement of the TDG Regulations that the person who is adequately trained and who will perform duties to which the training relates must have in his or her possession a valid training certificate containing the information specified in Section 6.3 of the TDG Regulations.

Question: Can the employer's signature on the training certificate that is issued to the employee be mechanically printed?

Answer: The name of the employer must be indicated on the training certificate. A mechanically printed signature, a scanned signature or any other signature mark produced by the employer is recognized as satisfactory, according to article 6.3(3)(a) of the TDG Regulations.

Question: Paragraphs 6.1(1)(a) et 6.1(1)(b) refer to untrained personnel working in the presence of someone who is trained. Is it acceptable to have untrained personnel doing the work and being watched by a trained person via an on-line camera?

Answer: An untrained person must be working in the presence of and under the direct supervision of a trained person. The Transportation of Dangerous Goods Regulations does not allow supervision to take place via an on-line camera; the trained person must be physically with the untrained person for the notion of « in the presence of » to be complied with.

Emergency Response Assistance Plan (ERAP)
TDG Regulations (Part 7)

Question: Does the person who answers the telephone need to be able to provide technical information about the product being transported?

Answer: The person who answers the telephone must be able to provide technical information to the caller, or be able to find someone who can provide the required information quickly. Placing the caller on hold in order to contact a third person who would have the proper technical information, is acceptable. However hanging up the phone to call someone else or asking the caller to call a different number would NOT be acceptable.

Question: For the purpose of Part 7 of the TDG Regulations, can a foreign (only) based company be the importer of dangerous goods into Canada and apply for an Emergency Response Assistance Plan (ERAP)?

Answer: The TDG Act places responsibility on a person subject to Canadian law to ensure that at the time of import into Canada, the dangerous goods satisfy Canadian laws. Therefore, a foreign (only) based company cannot be an importer of dangerous goods and apply for an ERAP. As such, the application for an ERAP is the duty of a Canadian « importer », in accordance with section 7.1.

Question: What is the status of a freight container of dangerous goods upon arrival at a port in Canada? Who is responsible for it and for any Emergency Response Assistance Plan (ERAP) if the dangerous goods it contains require one?

Answer: Upon arrival in Canada, a freight container of dangerous goods is the responsibility of the « importer ». The importer is the person who imported the container into Canada. If the container is destined for a person in Canada, that person is the « importer » and he is responsible for proper packaging, proper documentation, ERAP and so on. If the container is destined for a person outside Canada, then the carrier is responsible for these matters. (See the definition of « import » in the TDG Act and Regulations.) The container terminal is a « carrier » since the dangerous goods are « in transport » and it has possession of them even if only for storage in the course of transportation. (See the definition of « carrier » and « in transport » in the TDG Act and Regulations.) Therefore a freight container of dangerous goods upon arrival at a port is the responsibility of the person in Canada to whom it is being sent and if there is no such person in Canada, the responsibility of the container terminal.

Accidental Release Report Requirements
TDG Regulations (Part 8)

Question: In the event of an accidental release of dangerous goods from a means of containment, when do I need to make an immediate report?

Answer: If the accidental release consists of a quantity of dangerous goods or an emission of radiation that is greater than the quantity or emission level set out in the table found in subsection 8.1(1), the person who has possession of the dangerous goods at the time of the accidental release must make an immediate report to the persons listed in subsection 8.1(5). When referring to the table, you must consider both the primary and subsidiary class(es) of the dangerous goods that have been released. The requirement to make a report is then based on the lowest applicable quantity.

Rail
TDG Regulations (Part 10)

Question: Is displaying the words « non-odorized » or « not odorized » on a rail tank car of liquefied petroleum gas (LPG) that contains an odorant considered an infraction to the TDG Regulations?

Answer: Displaying « non-odorized » or « not odorized » on rail tank cars is not misleading under the current TDG Act and Regulations as these words are not considered prescribed safety marks. Therefore, this would not be an offence, even if the rail tank car does contain odorized product.

Protective Direction
TDG Regulations (Part 13)

Question: What does Protective Direction No. 31 require?

Answer: Protective Direction No. 31 requires any person who imports or offers crude oil for transport to immediately classify the crude oil if it has not been done since July 7, 2013. Once testing is complete, they must send the Safety Data Sheet (SDS) to the Canadian Transport Emergency Centre (CANUTEC) by fax or email:

Fax: (613) 954-5101
E-mail: canutec@tc.gc.ca

Until the testing is completed, crude oil should be transported as a packing group I as set out in the Transportation Dangerous Goods Act and Regulations.

Question: What are the testing requirements for crude oil?

Answer: Protective Direction No. 31 requires any person who imports or offers crude oil for transport to immediately retest the classification of crude oil, unless the testing was done after July 7, 2013. This testing must be done before the first shipment, essentially at the source.

Section 2.18 and 2.19 of the Transportation of Dangerous Goods (TDG) Regulations specify the requirements for testing flammable liquids such as crude oil. Test results should reflect that the testing was performed according to the requirements listed in Part 2 of the TDG Regulations.

Question: Must transloading facilities test every classification of crude oil?

Answer:  No. We are aware that transloading facilities cannot classify every shipment that contains a mixed load of crude oil. Therefore, if you suspect that the classification has changed due to mixing from different sources, you must classify it as Packing Group 1, as set out in Transportation of Dangerous Goods Regulations, 2.19(2)(a).

Question: What is the deadline to submit the required Safety Data Sheet (SDS) to the Canadian Transport Emergency Centre (CANUTEC)?

Answer:  Protective Direction No. 31 does not include a deadline. It states that any person who imports or offers for transport crude oil (UN1267 or UN1993) must immediately provide a Safety Data Sheet (SDS) to CANUTEC. Therefore, the classification process must start immediately after the Direction was issued. Complying with the Protective Direction No. 31 must be a priority. This includes providing CANUTEC with a copy of the updated SDS.

Question: Must carriers test the classification of crude oil and submit a Safety Data Sheet (SDS) to the Canadian Transport Emergency Centre (CANUTEC)?

Answer:  No. Carriers do not need to test the classification, but they should make sure that the person from whom they accept the crude oil has appropriately classified the product. Carriers also do not need to submit a SDS to CANUTEC. This should be done by the person importing or offering crude oil for transport.

Question: Does Protective Direction No. 31 apply to transporting crude oil by pipeline?

Answer:  Protective Direction 31 applies to road, rail, marine and air transport. It does not apply pipelines. Commodities transported by pipeline are governed by the National Energy Board Act and the Canada Oil and Gas Operations Act.

Question: After testing, just to be on the safe side, can I continue to use Packing Group I if the testing reveals that the substance is Packing Group II or III?

Answer:  No, Section 2.4 of the TDG Regulations states that you must use the shipping name that most precisely describes the dangerous goods and that is most consistent with the class and the packing group determined by the criteria and the tests.

We realise that transloading facilities cannot classify every shipment that contains crude oil from different sources (i.e. mixed load). Therefore, if you suspect that the classification has changed due to mixing from different sources, you may comply with paragraph 2.19(2)(a) of the Transportation of Dangerous Goods Regulations, which instructs you to select Packing Group I.

Question: Does Protective Direction 34 apply to all dangerous goods?

Answer: Yes, Protective Direction 34 applies to all dangerous goods.

Question: Do I need to meet all conditions listed in Protective Direction 34 (1)?

Answer: If your rail tank car meets all four conditions listed in Protective Direction 34 (1), you must mark the rail tank car with the wording "Do not load with dangerous goods in Canada / Ne pas charger de marchandises dangereuses au Canada".

Question: Does Protective Direction 34 apply if the rail tank car does not contain dangerous goods?

Answer: Here are two situations where Protective Direction 34 does not apply:

  1. The rail tank cars do not meet all four conditions of Protective Direction 34, or
  2. The rail tank cars are not transporting dangerous goods.

Note: We believe that it would be a good practice to identify those rail tank cars in case you start transporting dangerous goods or sell the rail tank cars to someone who transports dangerous goods.

Question: Is there a size requirement for the height of the letters of the words on the rail tank car?

Answer: No, but the American Association of Railroads (AAR) has published a Casualty Prevention Circular (CPC – 1281) that contains guidelines on the height of the letters on the rail tank car.

Question: Does Protective Direction 34 apply to rail tank cars coming from the U.S.?

Answer: Yes. Protective Direction 34 applies to any rail tank car entering the Canadian transport system, no matter its origin.

Question: May I use the cars below to carry dangerous goods?

  • cars built with ASTM 515-70 steel with a ring of TC-128 material
  • cars build with TC-128 material with heads of ASTM 515-70 steel

Answer: When a tank car meets all of the conditions set out in the Protective Direction 34, the Protective Direction only applies when the shell is made entirely of non-normalized ASTM A515 grade 70 steel.  If one or more of the shell's cylindrical or truncated conical rings is made of another grade of steel, the PD does not apply.

We understand that most terminations of the non-continuous structure is in the ring made of the heterogeneous steel, because it has superior properties to the ASTM A515-70 steel.

However, if the terminations of the non-continuous structure fall into a ring made of ASTM A515-70 steel, the tank car owner should:

  1. Review the tank car's qualification program developed under CGSB43.147 section 25 or 49 CFR Part 180, in light of the low fracture toughness of ASTM A515-70 steel and the high stress intensity at the termination of this non-continuous structure.

    Because of the car's particular construction, this review should focus on the appropriateness of inspection methods, inspection frequency, and acceptance criteria.

    Owners should conduct the review with a particular focus on the possible use of non-destructive techniques, inspection frequency and the evaluation of the acceptance criteria to ensure that the cracks never grow to critical length.

  2. Develop a pre-trip inspection program for tank cars where the weld terminations are visible to identify crack initiation, and communicate the inspection requirements to customers using the car.

Question: What are exterior heater coils? Why doesn't Protective Direction 34 apply to a tank car that has them?

Answer: Heating coils or pipes circulate a heating fluid such as steam, how water or hot oil that heats the content of the tank car that are highly viscous at low temperatures, before and during unloading. They may be fitted inside or outside of a tank car.

Exterior heater coils are made of moderate strength structural or commercial steel strips welded directly to the tank car bottom shell from one end to the other. Their continuous nature greatly increases the strength of the tank car bottom shell. The coils and their return loops near the heads, provide support where the highest train loads are supplied to the tank, at the end of the draft sill at the bottom shell.

There is no reported catastrophic failure of A515-70 tank cars with exterior heater coils.

Equivalency certificates / Permits
TDG Regulations (Part 14)

Question: What is the difference between an "equivalency certificate" and "permit for equivalent level of safety"?

Answer: They are the same thing. In June of 2009, the TDG Act was amended and the term "permit for equivalent level of safety" was changed to "equivalency certificate" but the meaning remains the same. However, in the TDG Regulations the term "permit for equivalent level of safety" still exists. In the future, the Regulations will include the new term "equivalency certificate".

Question: What is an equivalency certificate and when do I need one?

Answer: You need an equivalency certificate only when you wish to transport dangerous goods in a way that is NOT allowed by the TDG Regulations. For example, you wish to use a type of cylinder that is not allowed in Canada. To use the cylinder, you must apply to Transport Canada for an equivalency certificate and prove that the cylinder is as safe as a cylinder required by the TDG Regulations. Without an equivalency certificate, you may NOT legally transport or fill the cylinder in Canada.

Please note: that there is no guarantee that you will be granted a certificate.

Question: How do I apply for a permit / certificate?

Answer: To learn how to apply for an equivalency certificate please visit the "Equivalency Certificates" section of our website. You may also consult Part 14 of the TDG Regulations.

Question: How long does it take Transport Canada to grant an equivalency certificate?

Answer: While it usually takes three months, more complex cases could take longer. However if the same equivalency certificate already exists for another company, then the application process will likely be shorter. Before we grant a certificate, we may need to consult with Transport Canada engineers or other government departments. This consultation process can delay the approval process.