Under the Transportation of Dangerous Goods Act, shippers are responsible for classifying dangerous goods, completing documentation, selecting the proper means of containment and displaying dangerous goods safety marks on the container.
Proper classification is crucial in ensuring safety as misclassified goods pose a risk of not being appropriately handled or transported in a safe manner. In October 2013, Transport Canada issued a Protective Direction requiring any person who imports or offers for transport to retest the classification of their crude oil if that testing has not been completed since July 7, 2013 and in the interim to ship it as Packing Group I – the highest level of risk.
Transport Canada is conducting further research into crude oil properties, behavior and hazards through the collection and chemical testing of samples at different sources in the supply chain to ensure dangerous goods are properly classified, tested and verified.
Following the results of this research, the Department will conduct a targeted inspection campaign to verify the classification of rail car shipments and to further enhance its oversight of the transportation of dangerous goods.
Transport Canada will be recruiting engineering and scientific experts to support its oversight capacity in verifying the proper classification of dangerous goods and to provide technical advice to inspectors in the field.
Over the longer term, the Department will reassess the factors contributing to misclassification, and develop and implement a rigorous strategy to address these issues through inspection, regulatory amendments, and other courses of action.
In April of this year, Transport Canada issued Protective Direction 33 requiring shippers of specific hydrocarbons – including petroleum crude oil – to develop Emergency Response Assistance Plans (ERAPs). Targeted inspections have confirmed industry compliance with this Directive.
In July 2014, a regulatory amendment was approved that allows TDG inspectors to conduct a more thorough verification of classification of dangerous goods. This amendment now means that industry must prove the results of their testing and the validity of their testing methods.
By combining these actions with longer term measures to improve regulation and inspection, Transport Canada will ensure that dangerous goods transported in Canada are properly classified, tested and verified.