UPDATE – Federal: Most member-proposed changes on "Containers for Transportation of Dangerous Goods by Rail" standard met with positive feedback
Transport Canada continues its work on revising the former TP14877 standard and reverting it back to its status as a Canadian General Standards Board (CGSB) National Standard of Canada. TP14877 is a standard for “Containers for Transportation of Dangerous Goods by Rail”. (See previous story here.)
The CPA set up a sub-committee composed of members that met to discuss needed changes to the standard.
As a voting member of the CGSB committee that was set up to revise the standard, the CPA submitted member feedback, and received generally positive feedback from the committee.
Reaction by TC and the CGSB committee to members’ requested changes include:
1. CPA members’ request: Replace wording “replacement in kind” so that alternative parts could be used on a tank car.
Response: TC initially refused to implement this requested change, however, the committee requested further examples that shows how this wording is problematic.
Required action: The CPA will need to get multiple examples from members to respond to the committee’s request before the next meeting.
2. CPA members’ request: A proposed addition to 3.67(b)(i) to add allowance to change the rupture disc gasket and surge protector gaskets.
Response: TC indicated they will provide alternative language to allow to include the above gaskets in the clause.
Required action: The CPA will monitor TC’s language to ensure that it meets members’ needs.
3. CPA members’ request: Change the winter load requirements to add the wording “except for normal rail switching operations to allow the car to move from it’s original location to the consumers final destination”.
Response: TC accepted as per members’ suggestion.
Required action: None.
4. CPA members’ request: Change the “one time movement” clause, which is causing issues with movement of cars requiring repair, with alternative language that would allow for an exemption of the one time move.
Response: TC indicated that they would accept an exemption to move a car requiring repair to an adjacent property owned or leased by the same party and the property must be within 3 kms of the original location.
Required Action: CPA will monitor TC’s suggested changes to ensure they meet members’ needs.
5. CPA members’ request: The addition of guidance regarding the assessment of damage on tanks.
Response: TC refused the request for added guidance regarding assessment of damage on tank cars due to the request falling outside the scope of the standard. This request is covered under the Association of American Railroads Field Manual.
Action required: None.
While most changes were tentatively accepted, TC will still need to write the new language and bring it back to the committee for their input.
The CPA will continue to monitor progress to have the above requested changes implemented in the next version of this standard.
Any questions or added information can be directed to robertloenhart@propane.ca.
