Guide to help you prepare your emergency response assistance plan

This guide is for anyone who plans on applying for approval of an emergency response assistance plan (ERAP). Review the following information in full to learn what steps you can take ahead of time to help you apply.

Disclaimer

This guide is for information purposes only and has no legal force or effect. If there is a conflict between this guide and the Transportation of Dangerous Goods (TDG) Act or the TDG Regulations, the TDG Act and TDG Regulations take precedence.

In this guide, a release or anticipated release of dangerous goods that require an ERAP in the course of their handling or transporting that endangers, or could endanger, public safety is shortened to “a release or anticipated release”.

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Getting started

Do you need an ERAP?

Before you start, make sure you need an ERAP for your dangerous goods consignment. To find out, consult the Guide to find out if you need an ERAP along with section 7.2 of the TDG Regulations.

Before you apply for approval of an ERAP, you should be familiar with the TDG Act and the TDG Regulations. You should also:

  • be aware of the properties of the dangerous goods that will be transported
  • understand the risks and consequences of a release or anticipated release

Before you start applying, we recommend that you complete your potential incident analysis (PIA), have signed agreements for third party response, if applicable, and write your ERAP.

Creating your potential incident analysis (PIA)

A PIA must be included in your ERAP application, as per paragraph 7.3(2)(m) of the TDG Regulations. This is usually the starting point to developing your ERAP. It helps you understand what can happen during an incident and how to address a release or anticipated release.

Your PIA must include, at a minimum, the following four scenarios.

Scenario 1: An anticipated release of dangerous goods

For example, a TC412 tanker carrying hydrochloric acid involved in a rollover (e.g., slid down an embankment and is currently five feet below grade on its side) with no apparent loss of contents.

Scenario 2: The release of less 1% of the dangerous goods in a means of containment

For example, a full DOT105J500W rail car inspected in a rail yard is giving off an odour of chlorine at the protective housing.

Scenario 3: The release of more than 50% of the dangerous goods in a means of containment

For example, multiple intermediate bulk containers (IBCs) were punctured and are leaking in a road trailer that has been involved in a motor vehicle collision.

Scenario 4: The exposure to fire of a means of containment that contains dangerous goods

For example, a full TC 412 carrying hydrochloric acid is involved in a motor vehicle collision. As a result of the collision, dangerous goods have been released and a fire is burning. Both the released dangerous goods and the means of containment are exposed to the fire.

What to include for each scenario

For each scenario, you must explain:

  • the possible consequences of the release or anticipated release
  • the measures, organized by tier, to be taken in response to the release or anticipated release for each scenario
  • the identification of the persons responsible for taking the measures
    • In addition to persons who will respond on your behalf, you may include persons responsible for taking measures not identified in the ERAP. For example, you may identify municipal first responders in your PIA.

If your ERAP covers more than 1 dangerous good, match a dangerous good with a scenario that is most likely to happen, based on your activities that require an ERAP. You may provide more than 4 scenarios, if you'd like, but the PIA is not intended to cover every possible scenario.

For example, if your ERAP covers 3 dangerous goods, UN1202, UN1267 and UN1789, you could use UN1789 for scenarios 1, 2 and 3 and use UN1267 for scenario 4.

View an example of how to format your PIA

Using third parties for response

You may not have all the resources in place to respond to a release or anticipated release by yourself. Resources identified in your ERAP may include your own, those of third party responders or a combination of both. All responders must be trained, knowledgeable and equipped to respond to a release or anticipated release in a timely, appropriate, safe and coordinated manner.

Types of third party responders

There are 2 types of third party responders:

  • Emergency response contractors are, for example, third parties that you hire to provide resources, including response personnel and/or equipment on your behalf, for response at the site of a release or anticipated release
    • You may choose to hire a primary response contractor to manage a response network for you
      • This network may include response sub-contractors and/or mutual aid partners
    • A response sub-contractor is an response contractor that is part of a response network for your ERAP
  • Mutual aid partners are, for example, organizations that share and exchange resources with your company to facilitate the response at the site of a release or anticipated release
    • Mutual aid partnerships are generally not for profit.

We do not maintain a list of third party responders. It is your responsibility to find persons suitable to assist you in responding to a release or anticipated release.

Contents of agreements

If you use third parties for response, agreements must be included with your ERAP application, as per paragraph 7.3(2)(h) of the TDG Regulations.

A third party responder agreement is an agreement between you and a third party listed in your ERAP that will provide technical or emergency response advice, and/or provide resources to respond to a release or anticipated release on your behalf.

For the purposes of applying for approval of an ERAP, an agreement should describe the nature of the services provided. It must be a signed document and should include, for example, the:

  • person providing the services or support
  • person receiving the services or support
  • date the agreement is signed
  • date the agreement expires, if applicable
  • dangerous goods, modes of transport and means of containment that apply
  • geographical areas covered
  • conditions of the agreement
  • ERAP reference number, if available
  • phone numbers to initiate the services or support

You may have one or many agreements. All third party responders listed in your ERAP must be part of an agreement.

During the review of your ERAP application, signed agreements serve as evidence that there are measures in place to respond to a release or anticipated release. All agreements must be valid during the approval period of the ERAP and reflect the actual resources that can be provided. If conditions of the agreement change during your approval period, you must update your ERAP application.

Agreement signatures

The signatures required in an agreement will vary depending on the type of third party responder agreement.

A response contractor agreement must be signed by both the applicant and one or many response contractors depending on the nature of the agreement. For example, an agreement can be a document signed by the applicant and:

  • a single response contractor per response location
  • a single response contractor for multiple response locations
  • several response contractors for multiple response locations
  • the primary response contractor and the response sub-contractors for multiple locations
  • the primary response contractor that is signing on behalf of response sub-contractors
    • These sub-contractors must be listed in the agreement
    • This agreement must refer to one or many agreements signed between the primary contractor and the sub-contractors, which must be included in your ERAP application

A mutual aid agreement must be, at minimum, signed by the person offering the mutual assistance.

What to include in your emergency response assistance plan (ERAP)

An ERAP is a document that, according to subsection 7(2) of the TDG Act, outlines what to do to respond to a release or anticipated release. ERAPs may include information that is similar to what is required in your ERAP application.

Format and contents of your ERAP

There is no specific format for an ERAP. Write your ERAP in a way that ensures it meets both Transport Canada requirements and your business needs. You can also use the Emergency Preparedness and Response CAN/CSA-Z731-03 standard as a guide as you're writing your ERAP.

Your plan should include a title, table of contents and a list of tables and figures, if applicable. Consider including the following content in your ERAP:

Contact information

Include contact information for all internal and external persons required to support the response. This could include, for example:

  • technical advisors
  • response contractors
  • suppliers of resources critical to the ERAP (for example, climate-controlled trailers, monitoring equipment)
  • poison control centers
  • charters for transport into remote areas by air or marine

Also include the contact information of individuals from your company that will act as the liaison with Transport Canada for this ERAP.

Roles and responsibilities

Describe the roles and responsibilities of key personnel involved in implementing the plan, reporting or responding to a release or anticipate release, including:

  • senior-level management for authorizations
  • technical advisors
  • team leaders
  • response teams
  • mutual aid partners
  • any other persons who are critical to the implementation of the plan or the response

The roles and responsibilities of personnel should align with the response actions in your PIA. When describing the roles and responsibilities, you can include, where applicable:

  • contact information
  • the dangerous goods responded to
  • an overview of actions that could be taken
  • relevant training and experience on those dangerous goods
  • equipment that can be used or brought to respond
  • geographic area covered

Classification of dangerous goods

Identify the dangerous goods that require an ERAP, including their:

  • UN number
  • proper shipping name
  • class (and subsidiary classes, if applicable)
  • packing group or category

Only include dangerous goods that require an ERAP .

Means of containment and modes of transport

Identify the specific means of containment (container or packaging) for each dangerous goods. Include a specification sheet for more complex means of containment with, for example, valve arrangements and/or possible leak points.

Consider including:

  • information on the capacity of the means of containment
  • valve and fitting arrangements
  • overpacking or secondary/tertiary means of containment
  • how the dangerous goods are normally loaded and unloaded from the means of containment

Indicate the modes in which they will be transported (by air, rail, road or marine). If known, consider including:

  • the name of the carrier(s) that will be transporting the dangerous goods
  • the major highways, railways, airlines and airports or bodies of water used to transport the dangerous goods

Geographical areas of coverage

Identify the area in which the dangerous goods will be transported. Consider adding a map showing the geographical areas covered by the ERAP.

Resources for response, including personnel and equipment

Include both in-house and third-party response locations. Each response equipment location should have a list of the response equipment as well as the technical advisors, team leader groups and response teams who will respond from the location should there be a release or anticipated release.

All response equipment must be inspected and kept ready. You also need to keep inspection and maintenance records and make them available to us upon request.

Emergency response actions

Describe the expected actions to respond to a release or anticipated release. Consider describing the following:

  • initial response actions
  • defensive response actions
  • offensive response actions
  • fire-fighting actions

Also include procedures for critical response actions (for example, product transfer, depressurization), and necessary equipment for these actions. Those procedures and the equipment list may be in a different document, as long as they are referred to in the ERAP and you provide them with your application for approval.

Damage assessment

Address how to assess damage to the means of containment in order to determine the necessary response (for example, non-intervention, product transfer, depressurization). Identify resources with expertise in damage assessment in your plan and consider describing their experience and training.

Training and exercises

Outline any training and exercises you will do to ensure all parties will respond to a release or anticipated release in a timely, appropriate, safe and coordinated way.

Training and exercises should involve the means of containment and equipment described in the ERAP. You must keep records for all training and exercises related to the ERAP, and be ready to provide us these records upon request. A record must include the date, location and activities of the training, along with a signed list of participants.

Plan implementation

Specify the steps necessary to implement your ERAP during a release or anticipated release. Include procedures to notify key response personnel, such as a technical advisor or a team leader.

For example, describe what happens after the ERAP telephone number is called, including:

  • the information that will be collected by the person answering the telephone
  • how technical advisors or ERAP team leaders will be connected to a caller requesting technical or emergency response advice
  • who will implement the ERAP and make the ERAP implementation report to CANUTEC

Consider creating an incident assessment form that would be used by the person answering the ERAP telephone number. Use this form to take notes relevant to make the ERAP implementation report.

Mobilization and deployment of resources

Address the mobilization (preparation to deploy) and deployment of response resources. Also identify the people with authority to do this, including:

  • the number of people who are available to respond
  • any travel arrangements you need to make for these people
  • cross-border procedures for response personnel and equipment

The deployment options must be appropriate for the geographical areas covered in your ERAP. You should consider deployment by air or marine modes for remote areas, if applicable.

Safety information

Include information on the hazards associated with the dangerous goods in your plan. Depending on the nature of the hazards, consider including:

  • symptoms and routes of exposure
  • first aid strategies
  • exposure limits such as immediately dangerous to life or health (IDLH) or time-weighted average exposure value (TWAEV)
  • chemical properties and their hazards
  • lower explosive limit (LEL) and upper explosive limit (UEL) values
  • selection of personal protective equipment (PPE)

Refer to the Emergency Response Guidebook (ERG) for your dangerous goods. Include a safety data sheet (SDS) for all dangerous goods in the plan, or reference them. All information must be current.

Communications

Demonstrate how you and, if applicable, your third parties will maintain communication between your response personnel as well as other agencies, when responding to a release or anticipated release. Be sure to consider areas in which cellular service may be limited.

Appendices

You can append the following to your ERAP document, if applicable:

  • signed agreements with third party responders
  • training matrices of responders and summaries of previous trainings
  • equipment lists from each response location
  • revision history for the ERAP document
  • SDS, product information and relevant ERG guide pages
  • incident assessment forms
  • other relevant contacts

Contact us

TDG Response Operations Group
Transport Canada
Email: ERAPapplications@tc.gc.ca
Telephone: 613-993-7161
TTY: 1-888-675-6863

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