Placarding of trucks carrying totes – Clarification to Canadian requirements

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Courtesy of The Compliance Center (ICC)

A new interpretation of the Transportation of Dangerous Goods Regulations (TDG) will affect the way vehicles carrying large means of containment, such as tote tanks, will be placarded.

In general, TDG section 4.15 allows the “DANGER” placard to be used on vehicles or other large means of containment that are carrying goods requiring two or more placards. However, Amendment 6 (which was released February 20, 2008), included a new paragraph, 4.15(2), which states:

“(2) If dangerous goods are in a means of containment that is inside a large means of containment and a placard is required to be displayed but that placard is not visible from outside the large means of containment, the placard must also be displayed on the large means of containment. In addition, if a UN number is required to be displayed but is not visible from outside the large means of containment, the UN number must also be displayed on the large means of containment.”

For some time, the actual interpretation of this section was in doubt. The Transport Canada website (www.tc.gc.ca) carried an interpretation that, when placarded packagings such as totes were put into a large means of containment such as a vehicle or freight container, that they should be treated like smaller packages. That is, while each tote would be placarded as a bulk container, the vehicle carrying them may use DANGER placards if the totes contained goods in different classes, and that UN numbers were not required, unless the whole shipment was subject to the display of UN numbers according to the table in section 4.15.

However, this interpretation was controversial, and road inspectors in many provinces are basing enforcement on a more straightforward reading of the paragraph. Their opinion is that this paragraph requires the vehicle to display all class placards, and all the UN numbers, shown on the placarded containers inside. So, for example, if a truck were carrying one tote containing SULPHURIC ACID, Class 8, UN1830, and one tote containing ACETONE, Class 3, UN1090, the vehicle would have to display, on all four sides:

• Class 8 placards
• Class 3 placards
• Both UN numbers

The UN numbers may be displayed either in the centre of the placard, or on orange panels beside the placard. If several containers have the same class, but different UN numbers, only one class placard needs be displayed per side, but all the UN numbers must be displayed.

ICC is now advising shippers in provinces such as British Columbia, Alberta, Ontario and Quebec to consult and follow the interpretation of their provincial authorities. However, this may have far-reaching consequences to companies’ placarding procedures, particularly if they have based these off the previously-posted interpretation from Transport Canada. Transport Canada has said that they are currently working on revising the section to make the requirements clearer and easier to apply. A preliminary draft of this proposed amendment should be available on the Transport Canada website in the near future.

If you have any questions regarding this topic, please contact the Regulatory Specialists at ICC The Compliance Center Inc. We can assist you with all your placarding needs.

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