Transport Canada Proposes New Packaging Requirements

Transport Canada has issued a proposed packaging standard for small means of containment (non-bulk packaging). If adopted, this standard would establish a number of new requirements, and create, for the first time, packing instructions for small means of containment in Canada.

Currently, Canada's Transportation of Dangerous Goods Regulations (TDG) address small means of containment for classes 3, 4, 5, 6.1, 8 and 9 by reference to a standard from the Canadian General Standards Board (CGSB). This standard, CGSB-43.150-97, gives specifics for the testing and approval of UN-specification (performance) packaging, and some general rules for use, but does not prescribe specific packaging for individual substances. If adopted, the new standard TC-14850, "Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and 9, a Transport Canada Standard", will replace the CGSB standard. In addition to addressing testing and approval procedures, TC-14850 will include a detailed section on selection and use of containers, which will cover topics such as:

• Filling and closing,
• Special requirements for air transport,
• Pressure testing for packagings for liquids (for all modes),
• Requirements for verifying compatibility, and
• Salvage packagings

Finally, the standard includes specific packaging instructions based on shipping descriptions.

According to Stéphane Garneau, Superintendent of Intermediate Bulk Containers and Small Means of Containment, the TDG Regulations will, eventually, be amended to replace the reference to the old standard with TC-14850. Transport Canada plans to publish a draft for consultation of this amendment, with the option for comments on both the amendment and the standard. Once the comments have been considered, they will proceed with publishing the amendment in the Canada Gazette I, and eventually Canada Gazette II, where the amendment will become official. The expected timeframe for the consultation draft of the amendment is "some months from now," since Transport Canada is still finalizing several previous amendments.

The implications of this new approach to packaging are far-reaching. The new standard can be viewed or downloaded at Transport Canada's website.