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Due to the large number of changes and the lack of a
grace period, users of the TDG Regulations are
scrambling to ensure compliance. A brief overview
is provided below, a more detailed 'Part by Part'
explanation can be found
here.
Exemptions
Of interest to many smaller companies are the changes to
the commonly used exemptions available when dealing with
smaller quantities of dangerous goods:
Section 1.15 the Personal Use Exemption has been
replaced with the 150 kg Gross Mass Exemption, which
exempts anyone from Part 3 (Shipping Document), Part 4
(Safety Marks), Part 5 (Means of Containment), Part 6
(Training), and Part 8 (Accidental Releases) of the
regulations so long as the dangerous goods are contained
in one or more means of containment; each of which has a
gross mass of less than or equal to 30 kg, and the gross
mass of the total does not exceed 150 kilograms. The
restrictions have been expanded as well. (See section
1.15 of the TDG Regs for more details).
In Section 1.16 the 500 Kg Gross Exemption, Part
3 (Documentation), Part 4 (Safety Marks), and Part 5
(Means of Containment) of the regulations do not apply
so long as the dangerous goods are contained in one or
more means of containment; each of which has a gross
mass of less than or equal to 30 kg, and the gross mass
of the total does not exceed 500 kilograms. Restrictions
on this exemption have been expanded as well.
Please note that this exemption now requires 'all
persons' who are using it, to have a TDG Training
certificate.
Changes to Schedule 1 “Index of Dangerous Goods”
Hundreds of parameters have changed in the entire
Schedule 1 portion the TDG Regulations. This includes
changes to “Classification”, “ERAP Index Values” and
applicable “Special Provisions”. This includes the
reclassification of Anhydrous Ammonia and several
additional placards / labels.
Special provision 42, commonly referred to as the
‘welding exemption’ has been revoked but a new exemption
1.32.3 Class 2, Gases, in Small Means of Containment
states that Part 3 (Documentation) and Part 6 (Training)
do not apply to five or fewer cylinders of a gross mass
of which is less than 500 kg and when the labels on the
cylinders can be seen from outside the road vehicle. The
number of Class 2 gases this exemption applies to has
also been expanded.
Dangerous Goods Safety Marks
Part 4, the TDG placards and labels and when to display
them, has been amended as well.
If the DANGER placard can be displayed, then it can
continue to be used as long as placards are required
instead of having to change to a class placard if the
load changes and only one class of dangerous goods
remain in the large means of containment.
New dangerous goods safety marks for UN1005, ANHYDROUS
AMMONIA, UN3383, BIOLOGICAL SUBSTANCE, CATEGORY B, and
fissile radioactive materials have been introduced.
Conclusion
The entire Amendment 6 can be found here:
Canada Gazette: Amendment 6
With this amendment being the most significant in 6
years, TDG retraining is recommended for
many people who had their training prior to Feb 20,
2008.
Transport Canada is currently amending the TDG
Regulation webpage, and an updated Clear Language
Edition of the TDG Regulation is available from YOW
Canada's TDG Regulations web page:
TDG.
YOW Canada is available for consultation on any impact
Amendment 6 may have on you or your organization's TDG
obligations.
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