Wood preservation facilities, general recommendations: chapter A-11

11. Transportation of Preservative Solids, Solutions and Wastes

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The transportation and cross-border movements of preservative (pesticides) solids, solutions and the wastes generated by their use may be regulated under some or all of the following federal regulation:

• Transportation of Dangerous Goods Regulations (TDGR) (15)
• Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR)
• Interprovincial Movement of Hazardous Waste Regulations (IMHWR)
• Treated wood exported to another country may be subject to the Export Control List. This list contains substances whose export is controlled because their manufacture, import and/or use in Canada is prohibited or severely restricted, or because Canada has accepted, through an international agreement, to control their export.

Dangerous goods to be transported should be classified according to the TDGR and any additional requirements under provincial jurisdiction with authority. Requirements may vary from province to province. Facilities should contact their local Transport Canada office for classification requirements for preservative solids, solutions and the wastes generated by their use. Facilities need to ensure that the transportation of all preservatives and contaminated wastes need to conform with provisions of the TDGR. These Regulations cover, among other things, packaging, shipping documentation, interprovincial and Canada-U.S. shipments, labelling and placarding and the reporting of environmental emergencies.

The purpose of the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations is to ensure that hazardous waste and hazardous recyclables that are transported across international borders (to be exported, imported, or to transit through Canada) are managed appropriately to protect the environment and human health. The EIHWHRMR apply to anyone (individuals or businesses) who exports, imports or conveys in transit, for disposal or recycling purposes, waste or material that is considered to be hazardous under the EIHWHRMR. A permit issued by Environment Canada is required and carriers must have this permit with them during all stages of a movement, as well as a legal movement document (formerly known as a manifest).

The Interprovincial Movement of Hazardous Waste Regulations ensure that movements of hazardous waste and hazardous recyclables are properly classified and tracked. Shipments must be accompanied by a movement document. Consignor, consignee and all carriers must complete certain portions of movement document and once completed a copy of the document must be sent to the authorities of the province of origin and of the province of destination.

According to the article 2.2 of the TGDR, the consignor is responsible for determining the classification of dangerous goods. This activity is normally done by, or in consultation with, a person who understands the nature of the dangerous goods such as a manufacturer, a person who formulates, blends or otherwise prepares mixtures or solutions of goods or laboratory technologist or technician.

Table 27 provides recommendations on the transportation procedures for preservative chemicals. These procedures are based on good operating practices as well as conditions required under the TDGR.