Safety Awareness Materials and FAQ

  1. Safety Awareness Kit for the General Public
  2. Safety Awareness Kit for Communities/Municipalities
  3. Safety Awareness Kit for First Responders
  4. Safety Awareness Kit for Industry

If you would like to receive updates on our Safety Awareness Kits, please email us at:
TC.TDGSafetyAwareness-SensibilisationalasecuriteduTMD.TC@tc.gc.ca

FAQs

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

TDG General FAQ

Question: How can I obtain a copy of the Transportation of Dangerous Goods (TDG) Regulations?

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. However, here is a list of known distributors.

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

Answer: The TDG Newsletter is available upon request and distributed free of charge to more than 20,000 readers in Canada and abroad. To subscribe to the electronic version, click on this link:
http://wwwapps.tc.gc.ca/Comm/5/ListServ/Lg.aspx and enter your e-mail address. Then select the Transportation of Dangerous Goods Newsletter under "Safety and Security Group" heading.

Exemptions
TDG Regulations (Part 1)

Exemptions - Overview

Canada's rules for transporting dangerous goods are called the Transportation of Dangerous Goods (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 1.49.

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 he/she meets 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). 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 (e.g., oxygen, propane, gasoline, etc.) must not be greater than 150 kg. "Gross mass" includes the weight of the means of containment (MOC) and all of its contents.
  • The dangerous goods must be packed in MOC 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 MOC 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 or 1.22, or
    • With a shipment of dangerous goods that requires a shipping document (e.g., 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 United States. 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 capacity 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 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 outer means of containment (e.g., 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 dangerous goods in the inner means of containment (e.g., a box inside another box):

  • if solids, have a mass that is less than or equal to the number shown in column 6(a) of Schedule 1, when that number is expressed in kilograms;
  • if liquids, have a volume that is less than or equal to the number shown in column 6(a) of Schedule 1, when that number is expressed in litres; or
  • if gases, including a gas in a liquefied form, are contained in one or more means of containment each of which has a capacity less than or equal to the number shown in column 6(a) of Schedule 1, when that number is expressed in litres.
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 (e.g., bus or Taxi) / passenger ship (e.g., 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. This exemption can be used for spare cylinders that are being transported as long as the valves are in the closed position. A person requiring the oxygen during transport should use the exemption under Section 1.18

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".

For a more detailed explanation on cylinders purchase in the United States, please read the FAQ titled:

Can I fill a cylinder (Scuba, paint ball, BBQ, etc) in Canada that I bought in the United States?

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

2. Passenger vehicle (e.g., bus or Taxi) / passenger ship (e.g., 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

Refer to Section 12.14 of the TDG Regulations for domestic flights or the International Civil Aviation Organization (ICAO) Technical Instructions for international flights.

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

Answer: There is an exemption titled "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 means of containment 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 (i.e., 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. Note that a typical BBQ cylinder has a capacity of approximately 21 litres.

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?

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 U.S. 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 1.49. Some exemptions that can be used for gases can be found under Sections 1.15 and 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;
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). These small tanks are 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 transportation is due to occur or has occurred outside the boundaries of a facility, the whole transportation must be done in compliance with the TDG Regulations, including those segments taking place within a facility.

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

Answer: Yes. Since a police officer is considered on duty while he is on travel status, he can transport ammunitions or ammunitions loaded in a firearm onboard an aircraft.

Question: What is the intent of Section 1.26?

Answer: The Emergency Response Exemption applies 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 TDG 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 dangerous goods 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 one label for the primary class and one label for the subsidiary class be displayed on a small means of containment for each dangerous goods transported in the small means of containment. When a label is required to be displayed, 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, beside the primary class label. Therefore, a label (s), the shipping name and UN number must be displayed on cylinders containing a dangerous good. If the cabinet that contains the cylinders has a volume of 450 L or less, it would be considered a small means of containment. Therefore, the label(s), the shipping name and UN number would also need to be displayed on the cabinet. If the required dangerous goods safety marks displayed on it are visible from outside the vehicle, the requirement of Paragraph 1.32.3(d) would be satisfied.

Question: Can you explain the requirements of Subparagraph 1.35(a)(ii) in regards to 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 means of containment because of its configuration (i.e., if only two or three 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 safety data sheet (SDS) 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. As such, 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 tdg-tmd@tc.gc.ca.

Question: Is new motor oil classified as dangerous goods?

Answer: Generally, new motor oil isn't classified as dangerous goods since its flash point is too high. The flash point is the lowest temperature at which the liquid (oil) produces 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 safety data sheet (SDS) from the oil manufacturer.

Question: Is waste oil classified as dangerous goods?

Answer: While dangerous to the environment, Transport Canada does not usually consider used oil or waste oil a dangerous good 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 if the used oil is classified as 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 means of containment and nothing else— no gasoline, no solvent, etc. This can prevent contamination of your used oil and as a result, can be transported as non-regulated under TDG Regulations.

If you 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 transportation of dangerous goods by road. Note: The NA numbers in the 49 CFR are not permitted in Canada.
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 by the Canadian Nuclear Safety Commission in accordance with the "Packaging and Transport of Nuclear Substances Regulations, 2015". 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 Part 2 of the TDG Regulations 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 provide 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 Part 3 of the TDG Regulations. Since July 15, 2015, the shipping document also requires a consignor's certification as 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.

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 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 certifications 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. As stated in Subsection 3.5(4), if conditions are met, you have the option of either using the words "Residue – Last Contained" before or after the description of the dangerous goods 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 TDG Regulations require that the unit of measure 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 and as such, a waybill would be acceptable. The TDG 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 capacity 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 reference number and activation 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 required information as set out in the TDG Regulations for the particular dangerous goods to which it relates. However, it may also contain any other information the consignor wishes, as long as the required information is easy to identify on the shipping document. Therefore, if the shipping document contains the required information, the remainder of the information - including a valid ERAP reference number and activation telephone number constitutes "additional information" and does not contravene the TDG Regulations.

Question: Are the « technical names » that appear in parentheses for 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. The technical names are specifically mentioned on a shipping document and on a small means of containment if required by Special Provision 16. There are no set requirement in terms of upper or lowercase letters.

Question: What happens when the consignor and carrier are the same individual? 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 when and how to display placards and UN numbers on a compartmentalized large means of containment.

As per the requirements, you must display a Class 3 placard and 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 AND GASOLINE MIXTURE, 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 placarding requirements 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 transported 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.

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 Subsection 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), while 300 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't 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 case 2,300 kg). The gross mass of the exempted dangerous goods is therefore 300 kg. Since the amount 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 pertaining to explosives and gases (Sections 4.17 to 4.18.3).

Question: Can you explain the placarding requirements through examples?

Answer: For examples of how to placard a shipment, 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 placarding rule states that a placard must be displayed for each of the dangerous goods transported in a large means of containment 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 good (which is one of the conditions required for displaying a subsidiary class placard). Also, the UN number does not need to be displayed since an ERAP is not required and it is not a liquid or a gas in direct contact with the large means of containment (road vehicle).

The DANGER placard cannot be displayed 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 Class 8 placards must be displayed in accordance with the basic placarding rule found in Section 4.15. No subsidiary class placard is required, 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 the restrictions listed under Subsection 4.16(2), the DANGER placard may be displayed 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 (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 the dangerous goods without any 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 placarding 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 and UN numbers must be removed.

The placarding exemption for dangerous goods having a gross mass of 500 kg or less can't be used since the gross mass includes the mass of the means of containment (highway tank in this example).

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: Subsection 4.10(3) of the TDG Regulations 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 class labels be on the same side.

Question: When dangerous goods 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 the 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 TDG Regulations, but it would not be considered misleading if it was 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. Judgment 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 any 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 dangerous goods 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 one label for the primary class and one label for the subsidiary class be displayed on a small means of containment for each dangerous goods transported in the small means of containment. When a label is required to be displayed, 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, beside the primary class label. Therefore, a label (s), the shipping name and UN number must be displayed on cylinders containing a dangerous good. If the cabinet that contains the cylinders has a volume of 450 L or less, it would be considered a small means of containment. Therefore, the label(s), the shipping name and UN number would also need to be displayed on the cabinet. If the required dangerous goods safety marks displayed on it are visible from outside the vehicle, the requirement of Paragraph 1.32.3(d) would be satisfied.

Question: When shipping Anhydrous Ammonia (UN1005) 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 placards for UN1005, Anhydrous Ammonia:

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

Note: Since anhydrous ammonia is subject to Special Provision 23, please refer to Schedule 2 for more information.

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 highway tank is loaded with UN1203, Gasoline. Its next load is UN1202, Diesel. However, the pump and hoses have not been cleaned and still contain gasoline residue. Which UN number 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 UN1202 should be displayed.

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.

Question: Can a forward facing placard be positioned at a 45 degree angle on a truck trailer?

Answer: No. Subsection 4.15 (1) of the TDG Regulations states that the placards must be displayed on each side and on each end of the large means of containment. Therefore, the display of a placard on a truck trailer in a 45 degree angle (see image) would be considered a non-compliance. Subsection 4.6 specifies that a placard must be visible.

Display of a placard in a 45 degree angle is considered a non-compliance.

Question: If a road train or combination vehicle (multiple trailers being pulled by one truck) is carrying dangerous goods, is it required to reproduce a dangerous good placard at the rear of the last trailer if the last trailer does not contain dangerous goods?

Answer: No. When dangerous goods are placed in a road train, such as A, B or C train trailers, placards must only be displayed on all 4 sides of the trailer that contains the dangerous goods. Displaying a placard on the rear trailer would be considered misleading as to the presence of dangerous goods if it does not contain dangerous goods.

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: Part 5 of the Transportation of Dangerous Goods (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 transport 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 states 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 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;
  • the tank is subject to periodic inspections by a facility registered with Transport Canada; and
  • the tank(s) is/are limited to a total maximum combined 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 these sections, 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 dangerous good in the tank;
  • you must be trained and hold a valid training certificate as set out in Part 6 of the TDG Regulations;
  • the tank 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

Even though it may seem safer 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 links to search our database of facilities registered with 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 U.S. cannot be filled in Canada.

The table below summarizes 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 U.S. 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: 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 TDG 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: The propane tanks must comply with Section 5.10 of the TDG Regulations. However, if the propane tanks are required for heating units that are necessary to maintain environmental conditions, then Section 1.27 might apply.

Question: Are hot-air balloons propane cylinders subject to the Transportation of Dangerous Goods (TDG) Regulations?

Answer: Yes. The TDG Regulations apply to hot-air balloons propane cylinders that are removed from the hot-air balloon and transported:

  • To a launch site, or from a landing site;
  • For filling purposes; or
  • When the hot-air balloon is no longer in flight-ready condition.

Therefore, the cylinders must, amongst other things, be accompanied by a shipping document, display the appropriate dangerous goods safety marks, and they must be selected and used in compliance with the appropriate standard.

However, Section 1.27 of the TDG Regulations provides an exemption for cylinders required for the operation of a hot-air balloon. In order to use this exemption, the cylinder must be in flight-ready condition (i.e. ready to fly) and attached to the hot-air balloon. If these requirements are met, TDG Regulations does not apply.

Question: Which standards apply to the transportation of hot-air balloon propane cylinders?

Answer: The TDG Regulations requires that cylinders used to transport compressed gas must be manufactured in accordance with the CAN/CSA B339 standard.

Furthermore, such cylinders must be selected and used in accordance with the CAN/CSA B340 standard.

If an existing cylinder does not comply with the TDG Regulations, a person may apply for an equivalency certificate in order to continue using them for a short period of time and find a suitable replacement.

Training
TDG Regulations (Part 6)

Question: When do I need training?

Answer: You should always assume you need training. The only time 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 1.49. You will find some other exemptions listed in Schedule 2 (Special Provisions) 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 is the employer's responsibility to issue a training certificate once his/her employee has received adequate training.

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

Answer: No. Even though there is no standard format, the certificate must contain all of the information required by Section 6.3 of the TDG Regulations. You will find a sample of a training certificate in our Bulletin titled: TDG Training.

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

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

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

Answer: A self-employed person will issue his/her own training certificate. The purpose of the training certificate is to demonstrate that if someone handles, offers for transport or transports dangerous goods, he/she is trained to fulfill his/her 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 TDG 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 TDG 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 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 found in Part 6 of the Transportation of Dangerous Goods (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 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 Paragraph 6.3(3)(a) of the TDG Regulations.

Question: Paragraphs 6.1(1)(a) and 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 TDG 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.

Question: Is there any reciprocity regarding a valid training document issued to a U.S. driver transporting dangerous goods on a road vehicle in Canada?

Answer: Yes. Subsection 6.4 (1) of the TDG Regulations states that if a valid document was issued to a driver of a road vehicle indicating that the driver is trained in accordance with Sections 172.700 to 172.704 of the 49 CFR (Code of Federal Regulations), it is recognized as a valid training certificate as required in Part 6 of the TDG Regulations.

Question: How the U.S. training document does differs from the Canadian training certificate?

Answer: In the U.S., drivers transporting HazMat (dangerous goods) in quantities that require placards must successfully complete a state-level exam required by Section 383.93 of the 49 CFR (Code of Federal Regulations). The state will then add a HazMat endorsement to their Commercial Driver's Licence.

In Canada, Canadian drivers are not required to have a HazMat endorsement on their driver's licence when transporting dangerous goods.

Question: What is considered a valid training document according to the Canada-U.S. reciprocity agreement?

Answer: Transport Canada recognizes:

  • The HazMat (dangerous goods) endorsement of the Commercial Driver's Licence;
  • A copy of the certification stipulated in Section 172.704 (d) (5) of the 49 CFR (Code of Federal Regulations); or
  • A TDG training certificate issued under Part 6 of the TDG Regulations.

It is important to note that the U.S. Department of Transportation–Federal Motor Carrier Safety Administration will accept a Canadian driver's TDG training certificate in lieu of a HazMat endorsement.

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: 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, etc. 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 considered 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.

Reporting Requirements
TDG Regulations (Part 8)

Question: What are the types of reports that could be required under Part 8 of the TDG Regulations?

Answer:

  1. Reports for the transportation of dangerous goods by Road, Rail and Marine
    • Emergency Report – Road, Rail or Marine Transport (Section 8.2)
    • Release or Anticipated Release Report – Road, Rail or Marine Transport (Section 8.4)
    • 30-Day Follow-Up Report (Section 8.6)
  2. Reports for the transportation of dangerous goods by Air
    • Dangerous Goods Accident or Incident Report — Air Transport (Section 8.9)
    • 30-Day Follow-Up Report (Section 8.11)
    • Undeclared or Misdeclared Dangerous Goods Report (Section 8.14)
  3. Reports Relating to Security – All Modes of Transport
Question: What is the definition of release?

Answer: As per Section 1.4 of the TDG Regulations, a release means, in relation to dangerous goods:

  1. a discharge, emission, explosion, outgassing or other escape of dangerous goods, or any component or compound evolving from dangerous goods, from the means of containment being used to handle or transport the dangerous goods; or
  2. an emission, from a means of containment being used to handle or transport dangerous goods, of ionizing radiation that exceeds a level or limit established under the "Nuclear Safety and Control Act".
Question: What are examples of anticipated releases?

Answer: Usually, when there is an anticipated release of dangerous goods, the integrity of the means of containment is compromised. However, there was no release of dangerous goods yet.

For example:

  • An incident has occurred and dangerous goods will likely have to be transferred to another means of containment.
  • A means of containment is damaged to the extent that its integrity is compromised and dangerous goods could be released.
  • A means of containment is lost in navigable waters.
Question: What is the definition of public safety?

Answer: As per the Transportation of Dangerous Goods Act, 1992, public safety is defined as: the safety of human life and health and of property and the environment.

Question: If there is a release or an anticipated release of dangerous goods, when should an individual make an Emergency Report?

Answer:

For a release of dangerous goods

The person who had the charge, management, or control of the means of containment at the time of the incident should make an Emergency Report if the dangerous goods released are in excess of the quantity set out in the table found in Section 8.2 of the TDG Regulations AND if the release endangers public safety.

For an anticipated release of dangerous goods

The person who had the charge, management, or control of the means of containment at the time of the incident should make an Emergency Report if the dangerous goods anticipated to be released would be in excess of the quantity set out in the table found in Section 8.2 of the TDG Regulations AND if the anticipated release could endanger public safety.

Question: To whom should the Emergency Report be made to?

Answer: To local authorities responsible for responding to emergencies. You can find a list, by province, of local authorities on this page: https://www.tc.gc.ca/eng/tdg/emergencies-reporting-411.htm.

To learn more on information to include in the Emergency Report, refer to Section 8.3 of the TDG Regulations.

Question: When should an individual make a Release or Anticipated Release Report?

Answer:

  1. If an Emergency Report was required; AND
  2. If the release or anticipated release of dangerous goods results in any of the consequences listed in Subsections 8.4 (2) and (3) of the TDG Regulations.

Note: When a Release or Anticipated Release Report is required, the person who made the report, or his/her employer, must make a 30-day Follow-Up Report. For more information on the 30-day Follow-Up Report, refer to Sections 8.6 and 8.7 of the TDG Regulations.

Question: To whom should the Release or Anticipated Release Report be made to?

Answer:

  • CANUTEC at 1-888-CAN-UTEC (226-8832), 613-996-6666 or *666 (cell phone);
  • The consignor;
  • In the case of dangerous goods included in Class 7, Radioactive Materials, the Canadian Nuclear Safety Commission;
  • In the case of a ship, a Vessel Traffic Services Centre or a Canadian Coast Guard radio station.

To learn more on what information to include in the Release or Anticipated Release Report, refer to Section 8.5 of the TDG Regulations.

Question: When should an individual make a Loss or Theft Report?

Answer: Any person who had the charge, management, or control of the dangerous goods immediately before the loss of theft must, as soon as possible after the loss of theft, report it by telephone to the persons listed in Subsection 8.16 (3) if the lost or stolen dangerous goods are in excess of the quantity set out in Subsection 8.16 (2) of the TDG Regulations.

To learn more on what information to include in the Loss or Theft Report, refer to Section 8.17 of the TDG Regulations.

Question: When should an individual make an Unlawful Interference Report?

Answer: The person who had the charge, management or control of the dangerous goods must, as soon as possible after the discovery of the unlawful interference, report it by telephone to the persons listed in Subsection 8.18 (2) of the TDG Regulations.

To learn more on what information to include in the Unlawful Interference Report, refer to Section 8.19 of the TDG Regulations.

Question:In Part 8, we often refer to "a closure of…". What is considered a closure?

Answer:

Facility

In the transportation of dangerous goods, a facility closure refers to the full or partial closure of any facility where dangerous goods are handled.

For example:

  • A release occurs on loading dock No. 10 of a plant. The plant closes one dock for the day for cleaning, though the plant's other departments continue operations.
  • A derailment occurs in the yard of a plant. The lines are closed for a few hours while responders transfer the cargo to another tank car and place the derailed tank car back on the rails.

Railway Line

For example:

In the transportation of dangerous goods, a railway line is considered closed when traffic is impossible for any period of time (whether for a few minutes, a few hours or a few days) due to a release or anticipated release of dangerous goods.

  • A train carrying dangerous goods derails on the main railway line, causing a release due to damage to a tank car. Trains cannot move until the site is cleaned up.
  • A tank car carrying dangerous goods is involved in a collision at a level crossing. Railways are closed until the site is cleaned up.

Road

In the transportation of dangerous goods, a road closure is any change in the traffic patterns of a private or public roadway including its full or partial closure, whether due to the release of dangerous goods or their transfer in the event of an anticipated release.

For example:

  • After a release occurs on the westbound Highway 417, one westbound lane is temporarily closed while the two eastbound lanes remain open to traffic.
  • A tank truck is on its side in a ditch on a rural road and the dangerous goods are transferred to a second tank truck. After creating a buffer zone with pylons, traffic is allowed through one lane at a time.
  • A train derails, and a release occurs on the railway lines near a road. The road is closed to all traffic to protect the public, secure the perimeter and do clean-up.
Question: In Part 8, we often refer to a facility. What is considered a facility?

Answer: In the transportation of dangerous goods, a facility is a permanent or temporary building (or part of a building) used for the handling of dangerous goods.

Question: When should an individual make a Dangerous Goods Accident or Incident Report (Air) if there is a release or anticipated release of dangerous goods?

Answer:

For a release of dangerous goods

When there is a release of dangerous goods that are being offered for transport, handled or transported at an aerodrome, an air cargo facility, or by aircraft, the person who had the charge, management, or control of the means of containment at the time of the release should make a Dangerous Goods Accident or Incident Report (Air) if:

  • The dangerous goods released are in excess of the quantity set out in the table found in Section 8.9 of the TDG Regulations; AND
  • The release endangers public safety; AND
  • The release of dangerous goods results in any of the consequences listed in Subsection 8.9 (3) of the TDG Regulations

For an anticipated release of dangerous goods

When there is an anticipated release of dangerous goods that are being offered for transport, handled or transported at an aerodrome, an air cargo facility, or by aircraft, the person who had the charge, management, or control of the means of containment at the time of the anticipated release should make a Dangerous Goods Accident or Incident Report (Air) if:

  • The dangerous goods anticipated to be released could be in excess of the quantity set out in the table found in Section 8.9 of the TDG Regulations; AND
  • The anticipated release could endanger public safety; AND
  • The anticipated release of dangerous goods could result in any of the consequences listed in Subsection 8.9 (3) of the TDG Regulations.

Note: When a Dangerous Goods Accident or Incident Report (Air) is required, the person who made the report, or his/her employer, must make a 30-day Follow-Up Report.

For more information on the 30-day Follow-Up Report, refer to Sections 8.11 and 8.12 of the TDG Regulations.

Question: To whom should the Dangerous Goods Accident or Incident Report (Air) be made to?

Answer:

  • CANUTEC at 1-888-CAN-UTEC (226-8832), 613-996-6666 or *666 (cell phone);
  • In the case of dangerous goods included in Class 7, Radioactive Materials, the Canadian Nuclear Safety Commission;

To learn more on what information to include in the Dangerous Goods Accident or Incident Report, refer to Section 8.10 of the TDG Regulations.

Question: When should an individual make an Undeclared or Misdeclared Report and to whom?

Answer: A person must make an Undeclared or Misdeclared report as soon as possible after discovering, at an aerodrome or air cargo facility or on board an aircraft, dangerous goods that are not accompanied by the documentation or dangerous goods marks set out for the dangerous goods in Parts 1 to 6 and 8 of the ICAO Technical Instructions.

The report must be made to CANUTEC at 1-888-CAN-UTEC (226-8832), 613-996-6666 or *666 (cell phone).

To learn more on what information to include in the Undeclared or Misdeclared Report, refer to Section 8.15 of the TDG Regulations.

Question: What is considered an undeclared or misdeclared dangerous good?

Answer: As per Section 8.14 of the Transportation of Dangerous Goods Regulations, a dangerous good is considered undeclared or misdeclared when it is:

  • Not accompanied by the documentation or dangerous goods marks prescribed by the International Civil Aviation Organization Technical Instructions; and
  • Discovered at an aerodrome, an air cargo facility, or on board an aircraft.
Question: A dangerous good has been incorrectly labeled or incorrectly identified on a shipping document and the air operator/carrier has not accepted to transport it. Is an undeclared or misdeclared dangerous good report required?

Answer: No. An undeclared or misdeclared dangerous good report must not be made when the package has not been accepted by the air operator/carrier.

Question: A dangerous good is found to be incorrectly labeled or incorrectly identified on a shipping document after it was accepted for transport by the air operator/carrier. Is an undeclared or misdeclared dangerous good report required?

Answer: Yes. An undeclared or misdeclared dangerous good report must be made after the package has been accepted by the air operator/carrier and is discovered at:

  • An aerodrome;
  • An air cargo facility; or
  • On board an aircraft.

Road Transport
TDG Regulations (Part 9)

Question: Does Transport Canada consider “cross-docking” (the process of transferring dangerous goods from one vehicle to another before reaching their final destination) to be reshipping for the purposes of Section 9.4 of the TDG Regulations?

Answer: Yes, Transport Canada does consider cross-docking as “reshipping”. Therefore, as stated in Section 9.4 of the TDG Regulations, the large means of containment containing dangerous goods must have placards displayed on it in accordance with Part 4 of the TDG Regulations. The carrier may NOT transfer American placards to the new vehicle in Canada.

Note: American labels may remain on the small means of containment if the shipping document contains a notation that the safety marks comply with the 49 CFR.

However, if the imported dangerous goods remain in the vehicle that crossed the border, and the carrier simply changes the truck-tractor or the driver before continuing to its final destination, the American placards may remain on the vehicle, as stated in Section 9.1 of the TDG Regulations. Note that labels and placards displayed for dangerous goods included in Class 2.3 or Class 6.1 must be in accordance with Part 4 of the TDG Regulations.

Rail Transport
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.

Air Transport
TDG Regulations (Part 12)

Question: Are survival kits exempt from the Transportation of Dangerous Goods (TDG) Regulations when transported by aircraft?

Answer: The Canadian Aviation Regulations (CARs) require an aircraft to carry survival equipment that provides ways to start a fire, take shelter, drink or purify water and visually signal their distress.

While the CARs don't mention protection from bugs, bears and other wild creatures when describing survival kits, Section 1.27 of the TDG Regulations exempts many dangerous goods on board a means of transport that people need for their safety.

This means that:

  1. Aircraft survival kits that are carried for the safety of persons onboard are exempted from the TDG Regulations. The kit may contain "explosives" such as the actuating cartridges (cartridges, power device of Division 1.4C and 1.4S) used to inflate an article such as a dingy, or signal devices such as smoke and illumination signal flares.

    NOTE: Even though Subsection 1.27(2) of the TDG Regulations states that ammunition cannot be transported under this exemption, there is a provision under Part 8 of the International Civil Aviation Organization (ICAO) Technical Instructions that allows a person to transport onboard an aircraft up to 5 kg of cartridges (i.e. ammunition classified as UN0012 or UN0014) provided certain conditions are met.

  2. Spare aircraft survival kits (UN3072) handled, offered for transport or transported as cargo must fully comply with TDG Regulations.

  3. Personal survival kits someone carries for use at destination must also fully comply with TDG Regulations. For example, someone being taken to a remote area to conduct survey activities may carry bear spray / pepper spray for protection. In this situation, the survival equipment is not for the aircraft and the person transporting it must either:

    1. a. Apply for an equivalency certificate, or
    2. b. Package the dangerous goods according to the requirements of Part 12 and the ICAO Technical Instructions.

Note: A 2001 Commercial and Business Aviation Advisory Circular (CBAAC) No 184 entitled "Stowage and Packaging of Survival Equipment and Emergency Flares" contains this same message in more technical terms.

Protective Direction
TDG Regulations (Part 13)

Question: Can you provide guidance or simplify protective direction no.36?

Answer: A summary of Protective Direction 36 has been published on the TDG website. However, it doesn't replace the official legislative document also found on the TDG website.

Question: Are all products classified as UN1268 PETROLEUM DISTILLATES N.O.S. subject to the requirements of Protective Direction 38 (PD 38)?

Answer: No. PD 38 was designed to remove the use of legacy DOT 111 tank cars from crude oil service. If a person uses UN 1268 Petroleum Distillates N.O.S. shipping name to transport crude oil, then the requirements of PD 38 apply. Refined petroleum products, such as mineral spirits, paint thinner, etc., are not subject to PD 38. Section 3 of PD 38 defines "Crude Oil" as NOT being a "Refined Petroleum Product". The intent of PD 38 was to only capture crude oil or slightly diluted crude oil classified as UN1268 PETROLEUM DISTILLATES N.O.S.

Part 2, Classification of the TDG Regulations specifies that a person is required to use the most appropriate shipping name when offering for transport a dangerous good, including crude oil.

Note: Starting May 1, 2025, all Class 3 Flammable Liquids will solely be transported in a tank car that meets or exceeds the TC117, TC117R or TC117P specification.

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 for an equivalency certificate to Transport Canada 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 on 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, 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.

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