How to apply to manufacture aerosol containers and gas cartridges

Obtain a copy of the applicable standard, CGSB 43.123 from the CGSB.  Once obtained, review the standard, in particular the design and manufacture sections to make sure your facility is in compliance.

Clause 7 of CGSB 43.123 then lays out the registration requirements and what must be submitted in your application for registration with Transport Canada.

If you are in the business of making DOT specification aerosols in accordance with 49CFR, note that the primary differences between 49CFR and CGSB 43.123 requirements are:

  1. Requirements of what must be submitted for registration (Clause 7)
  2. The marking that must be on the can
  3. If you are making plastic aerosols, CGSB 43.123 requires a 4th batch of samples conditioned at low temperature for the drop test.

Examples of the type of information expected to be submitted for each part of Clause 7 are below.  If successful, you will receive a Certificate of Registration for your facility.

Submit the application via email to MOCRegister-RegistreContenant@tc.gc.ca

CGSB 43.123 Clause 7.2 Initial Registration

7.2.1     A manufacturer of aerosol containers and/or gas cartridges shall obtain a Certificate of Registration from the Director prior to the application of markings in compliance with Section 5 of this standard.  The registered manufacturer must perform its functions at the location stipulated on the Certificate of Registration unless the Certificate authorizes the facility to conduct these activities elsewhere.

    •     Submit a sample marking that demonstrates that the requirements of Clause 5 are met. See Clause 5.1 of CGSB 43.123 for what is required.  The markings must make the can traceable to the manufacturing facility where it is made.

7.2.2     The following information shall be submitted in the application for registration:

  1. Name, address and telephone number of the applicant 
    •   Include a business license or registration that shows the legal name of the company.
    •   Indicate the specification of cans the facility will manufacture (specify TC-2P, TC-2Q, etc)
    •   Include an example drawing of a can for each specification identified to enable verification that the requirements of the standard for wall thickness, diameter, openings, etc. have been met.
  2. Symbol of the applicant, if applicable
    •   Indicate what the symbol used on the cans will be.  This can be an M# that has been assigned to the applicant by the US DOT, any symbol or company name.  This symbol must be printed on the can as per Clause 5 of CGSB 43.123.  If successful in the application process, this symbol will serve as the registered mark on the Certificate of Registration issued to the company.
  3. Description of the manufacturing processes  
    •   Include a description of how the cans are manufactured as well as the material used. A procedure or flowchart are examples of documents that would demonstrate the process.
  4. Manual detailing quality control, testing and inspection procedures and 
    •   If the applicant’s facility is in the business of making and filling cans, the registration requirements focus primarily on the manufacture of the specification cans.
    •   The procedures must address the lot testing that is required by CGSB 43.123 for the specifications being made, examples are burst testing, leak testing, drop testing.
  5. Description of the quality management system.
    In relation to Clause 7.2.2 d) and e) above, provide documentation (e.g., procedures, work instructions, checklists and forms, etc.) associated with the following items (as applicable):
    •   Purchasing of raw materials and inspection of incoming product
    •   Material identification and traceability
    •   Forming/Welding (as applicable)
    •   Marking
    •   Inspection and testing
    •   Finishing processes (e.g. painting, labeling)
    •   Non-conforming product
    •   Drawing and design control – development of new designs and revisions to existing designs
    •   Record retention policy
    •   Control of monitoring and measuring devices (calibration of equipment and devices used in the manufacturing, inspecting, and testing of cans)
    •   Monitoring and measurement of processes
    •   Monitoring and measurement of product
    •   Preservation of product
    •   Internal audits
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