Twelfth night

Transport Canada has published Amendment 12 to the Transportation of Dangerous Goods (TDG) Regulations for informal comment. That period has closed but the ruling will eventually reappear in Canada Gazette Part I for a formal comment period.

The proposals, which have hitherto been touted as Amendment [Z], cover a number of areas, but most importantly the placarding of cargo transport units, the use of the new Limited Quantity mark, and the definition and marking of overpacks.

Probably the most important proposed change is an amendment to sub-section 1.17(4) of the TDG Regulations to permit the use of the newly agreed Limited Quantity mark. This is a rather urgent matter, since without it goods transported internationally by land, sea and air under the revised Limited Quantity provisions adopted elsewhere (certainly in the US and in ADR countries) would need to be re-marked for transport within Canada.

Most of the other proposed changes are intended to clarify the requirements for the marking and placarding of transport units and the marking and labelling of packagings. Some of these are designed to repair problems that were introduced in earlier amendments, particularly the notorious Amendment 6. In particular, Section 4.16 will be rewritten to more clearly explain the use of the ‘DANGER’ placard, something that had been causing shippers problems and was subject to differing interpretations by enforcement agencies in the Canadian provinces. It also harmonises with requirements under the US Hazardous Materials Regulations (HMR).

Another important change is found in Section 4.18, which deals with the placarding of large means of containment for UN 1005 anhydrous ammonia and oxidising gases of Class 2, as well as particular placarding requirements for tube trailers.

An amendment to the appendix to Part 4 of the Regulations will introduce conformity with international provisions for the design of labels and placards for organic peroxides of Division 5.2, and replaces the existing marine pollutant mark with the new ‘dead fish and tree’ symbol – although the example shown appears to have a very thick horizon line, as has already been erroneously shown in some other sources.

Other proposed changes include:

(a) a new definition for ‘overpack’ in Section 1.4;

(b) a new sub-section 1.43.1 on the exemption from the labelling requirements for Class 7 radioactive materials under certain conditions;

(c) revised texts for Sections 4.2 (misleading dangerous goods safety marks) and 4.9 (removal of dangerous goods safety marks);

(d) a completely revised Section 4.15 on the placarding of large means of containment, including the indication of subsidiary hazard, UN number, and the location and visibility of placards; and

(e) the use of the fumigation sign (Section 4.21).

The Bulletin will advise readers when the proposed amendments are published for formal comment.