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TDG Update for Spill Reporting

As of June 1st, 2016, there are two major changes to the Transportation of Dangerous Goods Regulations. First off, the information for Lithium Batteries has been updated to align with international air regulations. The other major change was the update to Canadian reporting for spills.

The update for Lithium Batteries did not come as a surprise. As of April 1st, 2016, international air regulations have forbidden the transport of lithium ion batteries when being shipped by themselves, without equipment. This follows the same restriction that was put in place last year for lithium metal batteries and it’s due to how difficult it can be to deal with fires arising from problem batteries. Both types of Lithium Batteries by themselves (without equipment) may only fly via Cargo Aircraft and in order to do so, they must meet the provisions of the relevant Packing Instructions from the ICAO Technical Instructions.

Transport Canada issued a protective direction (PD 35) earlier this year to ensure that these requirements were being met in the interim, and on June 1st, they became formalized in the TDG Regulations. These requirements relating to Lithium Batteries must be followed immediately.

 

The other updates to the TDG Regulations, including the major update to spill reporting, have an optional transition period of 6 months when either the old version or the new requirements may be followed. Come December 1st, 2016, everyone must adhere to all the new information from the update.

The most noticeable difference is the quantity threshold table from TDG Part 8 for how much can be spilled before reporting is required.

  1. a) Class 2, which now requires that a spill is reported for any quantity, whereas before, leaks from very small cylinders were not even really considered; and
  2. b) Class 3, 4, 5, 6.1, and 8, which now distinguish between Packing Groups. For some Packing Group III commodities, the quantity allowances have actually increased (Class 4, 6.1, and 8), but in general the limitations are harsher than in the past, which isn’t necessarily a bad thing.

Transport Canada predicts the quantity of annual spill reports to double in the first year with this new requirements. This regulatory change is a smart long-term move that can help with ongoing safety. If you consider that you would alert your coworkers of any spill in your workplace that might affect them, then the broadening of the scope of reporting requirements from Transport Canada can be thought of as a way to help people nationally by better understanding more problematic situations and hopefully suggest future improvements.

There are two big ideas to take away when considering spills:

First, instead of being called an “accidental release” as it was in the past, the TDG Regulations now just use the word “release” to describe spills. This way, it’s clear that any intentional release still fits the in the scope of spill reporting requirements.

Second, “Air Reports” has been given its own sub-section in Part 8 which now includes information about undeclared and misdeclared dangerous goods.

The full list of changes can be found in the Canadian Gazette II found here:
http://www.gazette.gc.ca/rp-pr/p2/2016/2016-06-01/html/sor-dors95-eng.php

 

 

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