The new Transportation of Dangerous Goods (TDG) Clear Language Regulations came into force on August 15, 2002, replacing the 1985 TDG regulation. Subsequently, on January 1, 2003, a significant change to the Clear Language Regulations that impacts both hazardous waste and non-hazardous solid waste managers took effect. The amendment deals with packaging and intermediate bulk containers (IBCs) used to transport Class 3 (flammable liquids), Class 4 (flammable solids, spontaneously combustible, dangerous when wet), Class 5 (oxidizers and organic peroxides), Class 6.1 (toxic), Class 8 (corrosives) or Class 9 (other regulated material) dangerous goods.
The revised regulations require that all containers — including drums, boxes, pails, barrels or IBCs (450 litres or less) — must now be certified with a safety mark to indicate they were manufactured in compliance with a standard. A certification safety mark is any design, symbol, word, number or abbreviation that is displayed on a container to indicate compliance with a safety standard.
New safety standards also require that containers be re-conditioned after each TDG movement. Container re-conditioning should now be performed by approved persons (according to requirements outlined in the regulations) and re-conditioned containers are subsequently certified.
Furthermore, to remain in compliance, some containers must be inspected and tested at intervals specified by the regulation or standard. Each container should have a date indicating when and who performed the inspections and tests.
There are several uncertainties that exist with regard to the new container standards. For instance, there’s confusion about the ability of an industrial user to purchase a dangerous material in a certified container, use the material and place the spent or waste material back in the same container for transport. It’s also unclear whether this re-use of the container requires that the container be re-conditioned first. Certain private parties have already requested that Transport Canada clarify this issue.
Most container hauling regulations in Canada are based on United Nation standards so that they are internationally recognized.
Rob Cook is executive director of the Ontario Waste Management Association. E-mail Rob at firstname.lastname@example.org