Enforcement of 4.15(2)

November 2009

Alternate format

Placards and UN numbers must be displayed on a large means of containment in compliance with Part 4, Dangerous Goods Safety Marks of the Transportation of Dangerous Goods (TDG) Regulations. In February 2008, new requirements came into effect with the adoption of Amendment No. 6.

This alert is designed to address issues regarding the applicability of subsection 4.15(2) of the TDG Regulations. Different interpretations of this subsection were made because of the ambiguity of its wording. Accordingly, subsection 4.15(2) can be interpreted to allow placards and UN numbers to be displayed two different ways when dangerous goods are contained in a large means of containment and are placed inside another large means of containment such as a trailer.

Subsection 4.15(2) reads as follow:

If dangerous goods are in a means of containment that is inside a large means of containment and a placard is required to be displayed but that placard is not visible from outside the large means of containment, the placard must also be displayed on the large means of containment. In addition, if a UN number is required to be displayed but is not visible from outside the large means of containment, the UN number must also be displayed on the large means of containment.

Using the example below, we will illustrate the two different methods to display placards and UN numbers.

Example:

The following two dangerous goods are placed in Intermediate Bulk Containers (IBC) and then placed inside a closed trailer.

  • 1500 L of UN3263, Corrosive solid, basic, organic, N.O.S., Class 8, PG II

  • 1500 L of UN1866, RESIN SOLUTION, flammable, Class 3, PG II

Option 1

Reproduce each primary class placard and UN number that are required to be displayed on a large means of containment in accordance with subsection 4.15(2) on the outer large means of containment (trailer).

Each IBC must display the primary class placard and UN number. Those primary class placards and UN numbers must then be reproduced on the trailer.

[image] [image]


Option 2

Consider the trailer as the means of containment containing the dangerous goods. Since the dangerous goods are not in direct contact with the large means of containment (trailer), the table of subsection 4.15(1) may be used to consider what placards and UN numbers must be displayed on the trailer.

This way, each IBC must display the primary class placard and UN number as illustrated below.

[image] [image]

Additionally, the trailer must display each primary class placard or the DANGER* placard as permitted by column 2 of item 3 of the table. See illustration below.

[image] [image]

- or -

[image]

* Currently, the use of the DANGER placard is only allowed when two different primary class placards are required and the dangerous goods do not require an Emergency Response Assistance Plan (ERAP), and when they are not a Class 7, or a Class 1, Explosives that meet any of the conditions of subsection 4.15(1).

A proposal to amend Part 4, Dangerous Goods Safety Marks has recently been drafted. Following public consultation, changes will be made to this part in order to clarify when placards and UN numbers must be displayed on large means of containments. The new proposed amendment would clearly prevent the use of a DANGER placard to replace primary class placards on an outer large means of containment when large means of containment are contained within. In this situation, the option of using the DANGER placard on the outer large means of containment would not exist anymore.

In light of the above and to ensure compliance with subsection 4.15(2) during this transition period, industry should contact their Transport Canada, Regional Transport Dangerous Goods Office or their Provincial/Territorial inspector community to inquire about the applicable enforcement policy.

To find out more, please contact the regional Transport Dangerous Goods Office in your region:

Atlantic:

  • Moncton, NB: Toll free: 866-814-1477, Fax: 506-851-7042;
  • Dartmouth, NS: Toll free: 866-814-1477, Fax: 902- 426-6921;
  • St. John's, NL: Toll free: 866-814-1477, Fax: 709-772-3072.

Quebec: 514-283-5722, Fax: 514-283-8234,

Ontario: 416-973-1868, Fax: 416-973-9907,

Prairie and Northern (Alberta, Saskatchewan, Manitoba, Yukon, NWT, and Nunavut):

  • Toll Free: 888-463-0521 or 204-983-3152
  • Winnipeg, MB: Fax: 204-983-8992;
  • Saskatoon, SK: Fax: 306-975-4555

Pacific:

  • New Westminster 604-666-2955, Fax: 604-666-7747

Or visit the TDG website at: www.tc.gc.ca/tdg/safety/menu.htm



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