One of the most frequently asked questions regarding the Transportation of Dangerous Goods (TDG) Regulations is "What do I need to know to comply?" This question usually prompts us to ask in return "Have you been trained in the TDG Regulations?" Training is the key to complying with the Regulations. A person must be able to find information in the Regulations, determine if a product is a dangerous good, determine if the dangerous goods are regulated and finally be able to use the Regulations. Each of these points is elaborated.

1. Training in the TDG Regulations

The TDG Regulations require that any person who handles, offers for transport and/or transports dangerous goods be trained or working under the direct supervision of someone who is trained. The responsibility to ensure people are trained and the manner in which this training is to be conducted rests with the employer. All trained persons must hold a training certificate. The training must be based on the duties that the person is expected to perform and to the dangerous goods that he/she is expected to handle, offer for transport or transport. (Part 6 of the TDG Regulations). For example, the person who completes the shipping document must be trained on the requirements of Part 3 - Documentation. For more information, please consult the Advisory Notice on Training Guidelines.

2. Finding information in the TDG Regulations

The TDG Regulations are broken down into 16 parts and 3 schedules. The parts provide the regulatory requirements for the transportation of dangerous goods. The schedules provide additional information that complement the parts.

3. Determining if a Product is a Dangerous Goods

It is the consignor's responsibility to classify a substance, product or organism to determine if it is a dangerous good. There are two ways to classify goods:

• Schedule 1 - Classes 1 to 9, or
  
  
• Part 2 - Classification.

Schedule 1 lists the dangerous goods by UN number and provides information on all classes of dangerous goods, such as, classification, quantity exemptions and limitations, special provisions and emergency response plans.

Part 2 defines the criteria of the nine classes of dangerous goods and is usually referred to when the dangerous goods are not listed by name in Schedule 1.

Always refer to Schedule 1 first. Find the UN Number of the dangerous goods under Column 1 in Schedule 1. If the UN number is not known, refer to the shipping names alphabetical index in Schedule 3 to search the UN number.

Forbidden Dangerous Goods

Schedule 3 lists the dangerous goods shipping names in alphabetical order. It includes dangerous goods that are forbidden for transport. Schedule 1 also forbids dangerous goods from being transported when the word "forbidden" is shown in column 3, class.

4. Determining if Dangerous Goods are regulated

Verify if any special provision numbers are present under Column 5 of Schedule 1. Special provisions are found in Schedule 2, and may provide an exemption from certain parts or sections of the Regulations.

If there are no special provisions in Schedule 2 exempting dangerous goods, verify sections 1.15 to 1.46 - Special Cases in Part 1. Some of the exemptions are partial, that is, they may be exempt from certain sections or parts of the Regulations with some conditions. The conditions of the exemption must be strictly adhered to.

For example section 1.25 states:

"These Regulations do not apply to dangerous goods that are transported solely within a manufacturing or processing facility to which public access is controlled."

If there are no exemptions in Schedule 2 - Special Provisions or Part 1 - Special Cases, the dangerous goods are fully regulated.

Modal Requirements

Parts 9, 10, 11 and 12 deal specifically with a mode of transport, respectively, road, rail, marine and air.

Permits

Permits may also allow a relief from certain requirements of the Act and the Regulations. The conditions of the permit must be strictly adhered to. Two types of permit exist:

• Permit for Equivalent Level of Safety¹
  (when conducting an activity in a manner that is as safe or safer than complying with the Act and Regulations)
  
  
• Emergency Permit
  (when dealing with an emergency in which there is a danger to public safety)

1 Application for a permit is made to the Minister or a designated person (Transport Dangerous Goods Directorate, Transport Canada)

5. Using the Regulations

The Regulations apply to dangerous goods if they are not exempted in Schedule 2 - Special Provisions or Part 1 - Special Cases. In addition to training, classification, special provisions and special cases, the following requirements of the Regulations also apply.

• Filing an emergency response plan with the TDG Directorate for all dangerous goods to be transported or imported in quantities greater than those specified in Column 7 of Schedule 1. The products, for which a quantity is specified, in Column 7 are the ones that are considered most dangerous. The requirements to file an emergency response plan are found in Part 7.



• Determining the mode of transport. Refer to Parts 9, 10, 11 and 12 for requirements specific to road, rail, marine and air transport.



• Determining the allowable quantity per means of transport for passenger carrying ship, passenger road and railway vehicle in columns 8 and 9 of Schedule 1. There are no quantity limits for other means of transport (i.e. cargo shipments).



• Selecting the appropriate means of containment for the dangerous goods as required in Part 5. Refer to the Means of Containment Advisory Notice.



• Displaying the dangerous goods safety marks required in Part 4 (i.e. labels, proper shipping name, UN number). Refer to the Safety Marks Advisory Notice.



• Completing the shipping document in accordance with the requirements found in Part 3. Refer to the Shipping Document Advisory Notice.

Accidental Release and Imminent Accidental Release Report Requirements - Any accidental release and imminent accidental release as specified in Part 8 must be reported by the person having possession of the goods. There is also a requirement for the employer to complete a follow-up report within 30 days.

This advisory notice was produced to facilitate understanding of the TDG Regulations. For specific information, the Act and Regulations must be consulted.