The recent amendments to the federal Transportation of Dangerous Goods
Regulation (TDGR) have created challenges for waste managers/shippers due to inconsistencies between the federal/provincial waste manifest form.
In order for a waste manifest to qualify as a TDG shipping document, the information must be provided in the order prescribed in TDGR s.3.5 - UN No., Shipping Name, Class, Packing Group. However, the current waste manifest requires the information be entered as Prov. Code, Shipping Name, Class, UN No., Packing Group, Quantity Shipped, Units, Packaging (No./Code), Physical State.
Earlier this year, the Canadian standard Movement Document/Manifest (adopted by Canadian provinces and territories for use in waste shipments across Canada) was modified to include the required consignor certification statement and signature which was required by TDGR s. 3.6.1 as of July 15, 2015. For more information, please refer to the June 17, 2015 post - Documentation Requirements for Dangerous Goods Including Wastes.
The provincial regulatory bodies must wait on Environment Canada to modify the Movement Document/Manifest. Completion of the manifest must meet provincial waste requirements as well as Federal TDG regulations.
In Ontario, the MOECC does not have any plans currently to revise the manifest document to account for these discrepancies. Dr. Dianne Saxe, one of Canada's leading environmental lawyers, has written a blog post in relation to some of the steps you can take to handle these issues at your facility. To view that post, please click here.
Note: While Dr. Saxe's post provides a general guide to this subject matter, it is recommended you seek specific advice in regards to your facility requirements.
In Alberta, Alberta Environment and Parks (AEP) is allowing the manifest form to be completed by proceeding the UN Number before the shipping name in the shipping name column of the manifest. AEP has also updated their manifest attachment sheet to be in compliance with TDGR. For more information on this, please refer to the AEP's Hazardous Waste Manifest System.
For more information about waste manifests and the TDGR, please contact Mark Roehler.