Regulatory Affairs
February 28, 2023

Amendments to the TDG Act, 1992 (Part 12 and International Harmonization Update)

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In an effort to harmonize with international dangerous goods requirements, the Transportation of Dangerous Goods regulations (TDGR) are being modernized to the latest international codes and American U.S. 49 CFR.

The following are the specific changes for propane:

1. ‘Non-odourized’ will now be required to be marked on a container of liquified petroleum gases (LPG) where mercaptan has not been added:

The odourization of LPG is useful for detecting potential leaks when the product is used as a fuel, however, LPG may also be used as a propellant in household aerosol products where odorizing the gas would provide no benefit and would result in a less desirable product. The U.S. regulations require words on a means of containment containing ‘non-odourized LPG’ but there was no equivalent requirement in the TDGR. Without this safety protocol in place, first responders would be unaware of the hazards posed by these dangerous goods if they were ever involved in an incident.

2. The 100-litre capacity limit of containers increased to 110-litres to better reflect the actual capacity of the cylinder size:

The current capacity limits in the TDGR gas provision do not reflect the capacities of cylinders in use today, which creates compliance issues when cylinders are transported under this provision. For example, the current limit is 100 litres per cylinder; however, the actual capacity of a 100 lb cylinder is 110 litres. The provision is being revised to reflect this.

3. Changes to safety markings:

The requirements for dangerous goods safety marks are being updated to include the following changes:

  • Allow for the use of placards as illustrated in the UN recommendations as well as those prescribed under the U.S. 49 CFR, including the display of text as long as it does not obscure the symbol;
  • Allow reduced-size labels and banana labels on the shoulder of a cylinder, and labels reduced in accordance with ISO 7225 standard on small cylinders;
  • Allow for the reduction of the dimensions of placards and labels up to a minimum size of respectively 100 mm x 100 mm and 30 mm x 30 mm; 
  • Specify that all labels displayed on a means of containment be positioned to be seen from a single vantage point; and 
  • Clarify the minimum size for UN numbers on small means of containment and intermediate bulk containers.

4. Allowances for the application of additional international regulations:

Para (3) Section 1.3.1 of the regulations is amended by adding the following in alphabetical order:

ANSI/WSC PST

means the ANSI/WSC PST 2000/2016, Pressurized Water Storage Tank Standard, February 2016, published by the Water Systems Council. (ANSI/WSC PST)

CGA C-7

means the CGA Standard C-7, Guide to Classification and Labeling of Compressed Gases, published by the Compressed Gas Association, Inc. (CGA), as amended from time to time. (CGA C-7) 

5. Subsection 1.16(1) of the regulations before paragraph (a) is replaced with the following:

1.16 (1) Parts 3 to 5 do not apply to the offering for transport, handling or transport of dangerous goods on a road vehicle, a railway vehicle or a vessel on a domestic voyage if

16 Paragraph 1.21(1)(e) of the Regulations is replaced by the following:

  • (e) the dangerous goods are not included in
    • (i) Class 1, unless they are included in Division 1.4 and in compatibility group S,
    • (ii) Division 2.1, if they are in a cylinder with a capacity greater than 46 L,

17 Paragraph 1.22(1)(e) of the Regulations is replaced by the following:

  • (e) the dangerous goods are not included in
    • (i) Class 1, unless they are included in Division 1.4 and in compatibility group S,
    • (ii) Division 2.1, if they are in a cylinder with a capacity greater than 46 L, 

6. Class 2 dangerous goods cylinder label changes:

If the dangerous goods are included in Class 2 and are contained in a cylinder, instead of displaying the labels required in subsection (1), the cylinder may be marked in accordance with Appendix A of CGA C-7. 

12.31 (1) Dangerous goods that are included in Division 2.1, except UN1950, AEROSOLS, may be offered for transport, handled or transported in accordance with section 12.30 of these Regulations if Table 3-1 does not forbid the transport of the dangerous goods.

(3) The dangerous goods referred to in subparagraphs (2)(a)(ii), (iii), (v), (vii), (ix) and (xi) may be identified by the UN number UN1075 and the shipping name LIQUEFIED PETROLEUM GASES instead of the UN number and shipping name identified for them.

7. Subsection 1.50(1) of the regulations before paragraph (a) is replaced with the following:

  • 1.50 (1) Sections 5.1.1, 5.2 and 5.5 and subsections 5.10(1) and (2) do not apply to the offering for transport, handling or transport of UN1978, PROPANE, in a cylinder if

Limited Access Location — Division 2.1, Flammable Gases

12.31 (1) Dangerous goods that are included in Division 2.1, except UN1950, AEROSOLS, may be offered for transport, handled or transported in accordance with section 12.30 of these Regulations if Table 3-1 does not forbid the transport of the dangerous goods.

(2) Despite the word “FORBIDDEN” in columns 10 and 11 of Table 3-1, dangerous goods may be offered for transport, handled or transported on board a passenger aircraft in accordance with section 12.30 of these Regulations if

  • (a) the dangerous goods are
    • (i) UN1001, ACETYLENE, DISSOLVED,
    • (ii) UN1011, BUTANE,
    • (iii) UN1012, BUTYLENE,
    • (iv) UN1049, HYDROGEN, COMPRESSED,
    • (v) UN1055, ISOBUTYLENE,
    • (vi) UN1060, METHYLACETYLENE AND PROPADIENE MIXTURE, STABILIZED,
    • (vii) UN1077, PROPYLENE,
    • (viii) UN1954, COMPRESSED GAS, FLAMMABLE, N.O.S.,
    • (ix) UN1969, ISOBUTANE,
    • (x) UN1971, METHANE, COMPRESSED, or NATURAL GAS, COMPRESSED with high methane content, or
    • (xi) UN1978, PROPANE;

  • (b) the dangerous goods are contained in a cylinder with a water capacity of less than or equal to 110 L; and

  • (c) the total water capacity of all cylinders containing the dangerous goods, transported on board the aircraft, is less than or equal to 132 L.

(3) The dangerous goods referred to in subparagraphs (2)(a)(ii), (iii), (v), (vii), (ix) and (xi) may be identified by the UN number UN1075 and the shipping name LIQUEFIED PETROLEUM GASES instead of the UN number and shipping name identified for them.

 

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