Waste Handling Must Follow TDG

There are several upcoming requirements which will affect the handling of wastes in respect to their TDG requirements.

Classification of Dangerous Goods Including Waste Streams

TDG Part 2.2.1 states that a Consignor who allows a carrier to transport dangerous goods or imports dangerous goods is responsible for proof of classification for the dangerous goods information used on the shipping document.  This proof must be maintained for five (5) years and must be in a document that explains classification (i.e. test report, lab report, explanatory document) and include the following information:

  • Date on which dangerous goods were classified;
  • If applicable, the technical name of the dangerous goods;
  • The classification of the dangerous goods; and
  • If applicable, the classification method used under this Part or under Chapter 2 of the UN Recommendations.

For UN1267 (Petroleum Crude Oil) and UN1268 (Petroleum Distillates N.O.S.), special provision 92 states that proof of classification must be done on the basis of sampling and analysis.  The document used to explain the sampling method must include the following information:

  • The scope of the method;
  • The sampling apparatus;
  • The sampling procedures;
  • The frequency and conditions of sampling; and
  • A description of the quality control management system in place.

It is important to understand that the above applies not only to products but also waste. Any material shipped as a dangerous good, including waste, needs to have proof of classification of the determination of the UN number. If the waste stream is UN1267 or UN1268 then the waste stream must have been sampled and analysed in order to determine the appropriate classification.

Documentation Requirements for Dangerous Goods Including Wastes

The Canada Gazette Part II amendment (SOR/2014-306), published December 31, 2014 which included a 6 month transition period, called for modification of TDG Part 3.5(1)(c) which requires that dangerous goods descriptions must be in the order of Columns 1, 2, 3 and 4 of TDG Regulations, Schedule 1 or UN number, Shipping Name, Class (Subsidiary Class) and Packing Group.

TDG Part 3.6.1 states that as of July 15, 2015, a Consignor must state their name and make a Consignor’s Certification on any shipping document containing dangerous goods.  This certification can be authorized by 49 CFR, ICAO Technical Instructions, IMDG Code, or UN Recommendations.  Alternatively, you would use the TDG certification language which is as follows:

“I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, are properly classified and packaged, have dangerous goods safety marks properly applied or displayed on them, and are in all respects in proper condition for transport according to the Transportation of Dangerous Goods Regulations.”

The Canadian standard Movement Document/Manifest adopted by Canadian provinces and territories for use in waste shipments across Canada has been recently updated to include the new certification requirements of a Consignor.  You will note that this certification requirement states that the correct classification under TDG is used (note Part 2.2.1 above).  However, the manifest description for dangerous goods is not in compliance with Part 3.5(1)(c) of TDG as the description is still shown as Shipping Name, Class, UN No. and Packing Group.
 
If the Movement Document/Manifest is not modified and adopted by provincial/territorial authorities by June 30, 2015, with the correct TDG description order, which is not likely to occur, then all dangerous goods waste shipped on a Movement Document/Manifest must be accompanied by a bill of lading with the correct TDG description.

Questions?

For more detailed information in regards to waste handling, please contact:

Mark Roehler