On January 16, 2020, the CPA met with Transport Canada regarding difficulties imposed by the current requirements of TP 14877, Containers for Transport of Dangers Goods by Rail. Current wording requires railcars be loaded at summer ullage if the railcar is to be stored at any time en route to its destination. Rail cars are frequently required to be disconnected during engine switching and can sometimes be disconnected from the engines for short times off-site or while waiting to be unloaded onsite.
The current wording in TP 14877 would make loading railcars at winter ullage next to impossible due to the above mentioned stops. The CPA also believes this requirement places added cost and unnecessary burden on rail users. TC indicated they were open to discussing these issues and will be contacting rail companies to clarify their concerns. The CPA is planning to meet with TC at the end of February once these discussions have taken place.
For more information, visit TP14877 section 61 of Transport Canada's website.