Update: Federal – Transport Canada’s Client Identification Database could become a regulatory nightmare
On January 22, 2020, Transport Canada (TC) hosted a webinar to present the finalized approach for the Client Identification Database (CID), which was meant to address issues and identify unaddressed concerns. The CPA attended the webinar to obtain further information on the new CID requirements and what they would entail for plan participants.
The CPA learned that TC is planning to launch the new database in January 2022. Also presented was additional information about affected parties who will be required to provide their information if they fall into one of the TC TDG database requirements. Effectively, anyone who handles, offers to transport, transports, or imports TDG listed items will be required to provide information in the proposed database to help regulatory personnel respond to dangerous goods incidents.
The CPA believes that this added database is further duplication of requirements that are already mandatory, including: Transport Canada’s emergency response assistance plans (ERAPs) and its Canadian Transport Emergency Center – CANUTEC, as well as Environment and Climate Change Canada (ECCC) Environmental Emergency (E2) Plans. It appears that the existing databases for each of these separate requirements are not shared amongst these and other federal government entities. When the CPA raised the question as to how this information would be shared, TC indicated it would only be shared within TC entities and not with other government organizations due to privacy concerns.
The CPA is discouraged to learn that the federal government does not always share information between federal regulatory bodies. Furthermore, threshold levels for the Transportation of Dangerous Goods database are established at a lower level and are completely different from ECCC E2 plan requirements for Schedule 2, a similar, duplicate database.
The CPA will continue to advocate to ensure the database is not repetitive of other registration processes, that federal agencies begin to work together to eliminate database duplication, and that any new federal database is designed to simplify processes to collect data on required products rather than add to the confusion that already exists.
If you have any comments on the database, please contact Robert Loenhart at robertloenhart@propane.ca or 613-683-2274.
