Transportation of Dangerous Goods Regulations are in place to ensure the safe transport of hazardous materials that can pose a risk to public safety. Now that we understand that, let me ask you, what items do your company have that are classed as a Dangerous Goods? How did you determine if they are a Dangerous Good? What mode of transport do you offer these materials? Are you exempt from the regulations in anyway?
These are questions quite often asked. In many cases, companies are unclear regarding their responsibilities and the true requirements of the law. For instance, allowing someone to take possession or to offer (give) a dangerous good to a carrier or waste contractor would require compliance of TDG by all parties unless it meets an exemption. For example when you contract a hazardous waste company to remove and dispose of dangerous goods waste. You as the shipper would be required to fully comply with classifying, labelling, packaging, and documenting of the dangerous goods. Relying on someone else does not necessarily mean you are complying. This is not just in the case for a hazardous waste dangerous good, but in all cases where dangerous goods are transported.
As a shipper of a dangerous good it is your responsibility to determine the appropriate classification. You can accomplish this by checking the information on the Material Safety Data sheet (MSDS), ask the vendor you originally received the product from, or as a last resort, have samples taken for analysis, if it is unknown. Once you have determined what you are shipping you must decide on the appropriate packaging. Many non-compliance issues arise here. How do you know if the packaging complies? Just because it looks safe does not mean it is compliant. In Canada there are standards related to dangerous goods packaging. As the shipper you need to know when they apply and if they apply to your item. These standards, currently, are CGSB, CSA, UN, or D.O.T. Each standard determines the appropriate inner packaging types, closure methods, compatibility of the outside package with the dangerous good, and overall integrity of the package.
Canadian TDG does allow for some relief of these packaging specifications if you can utilize a special case from Part 1 of the TDG Regulations or if you have an Equivalency Certificate (Permit). As long as you are following the terms and conditions of the Equivalency Certificate you may be able to ship without having to use the packaging standards.
Labelling and marking of packaging is usually straight forward. Make sure that they match the documentation you will complete are clear and visible.
This Safety Update was contributed by Kevin Swinden from Global Hazmat
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