TODG Detailed Outline:
Clear Language Update

 

SIGNIFICANT CHANGES

1          General                                  

In most cases the Clear Language Regulations offer, where possible, ways to comply with the current DG Regulations and still be in compliance with the Clear Language requirements. 
   
More products require an Emergency Response Assistance Plan (ERAP).

Elimination of North American PIN’s. All PIN’s are now UN (United Nations).

A consignor can delegate the consignor’s responsibilities in writing to another person.  The consignor is still liable and cannot delegate the ERP duties.

New definitions for “Consignor”, “in transit” and “offer for transport”.

 2  Training

Air training increased to two (2) years from one year.
           
Additional training maybe required for specification safety marks and packaging standards.

New requirements for the employer to provide enhanced training, training records and a
description of the training materials used.

New offence for an employer to direct or allow a non-trained person to undertake any dangerous activities, unless under the direct supervision of a trained person.

Certain aspects of training have been enhanced and now include:            

• The classification criteria and classification as defined in Section 1.4
• Shipping names  (New) 
• Use of Schedules 1, 2 and 3 (New)
• Shipping documents
• Safety marks
• Certification of safety mark requirements, safety requirements and safety standards for means of containment
• Emergency Response Assistance Plans  (New)
• Reporting requirements
• Safe handling and transportation practices (New)
• Proper use of equipment
• Reasonable emergency measures
• Air Transport training (New)
•  Marine transport (New)

New certificate information including
-   name and signature of the employee
-   name and signature of the employer
-   company address to include the postal code
-   more detail on the aspects of training and

-  date of expiry is to follow the words “expires on”.

A new requirement that all standard packaging must remain ‘in standard’ while they are in use.

5  Safety Marks

 Adoption of a new label and placard for Explosives 1.6.

Class 9  explanation safety mark eliminated.

New labels and placards for:

-   OXYGEN, COMPRESSED, UN 1072
-   OXYGEN, REFRIGERATED LIQUID, UN 1073
-   COMPRESSED GAS, OXIDIZING, N.O.S., UN 3156 and
-   LIQUIFIED GAS, OXIDIZING, N.O.S., UN 3157

Elimination of the label and placard for Class 6.1 Packing Group III (use only the 6.1 label
and placard)

Introduction of a placard for Class 6.2

New label and placard for Class 9

The introduction of an “elevated temperature” sign.

No mention of upright arrows for liquids.
 
Labeling Rules

A new requirement that all subsidiary classification, if any, must be shown. These labels are
the same as a primary class label. Location of this label is not mentioned.

Packages of radioactives must have two sets of labels. (Sec 441 –IAEA).

Elimination of multiple sets of labels for small containers larger than 2 m3.

Labels not required on a small container if it is inside another small container (labels required
only on the outer packaging).

Placarding Rules

Item	Description	Placard Required	UN Number Required
1	Dangerous goods have the same UN number and an ERAP is not required for them	Primary class placard	UN number if the dangerous goods are a liquid or in direct contact with the large means of containment, or in a quantity greater than 4,000 kg and offered for transport by one consignor
2	Dangerous goods have the same UN number and an ERAP is required for them	Primary class placard	UN number
3	Dangerous goods have different UN numbers and an ERAP is not required for any of them	DANGER placard alone or the primary class placard for each of the dangerous goods, except that explosives must always be identified by a primary class placard	None
4	Dangerous goods have different UN numbers and an ERAP is required for at least one of them	Primary class placard for each of the dangerous goods for which an ERAP is required and, if the remaining dangerous goods meet any condition in paragraph (1)(a) or (b) and (a) if the dangerous goods are in the same primary class, that primary class placard; or (b) if the dangerous goods are in different classes, the DANGER  placard alone or the primary class placard for each of the dangerous goods, except that explosives must always be identified by a primary placard	UN number for each of the dangerous goods for which an ERA P is required
5	Dangerous goods have different UN numbers and an ERAP is required of each of them	Priamary class placard for each of the dangerous goods	UN number for each of the dangerous goods

Primary class Placards with UN Numbers on transport units for all products needing:

-   an ERAP, 
-  liquids, or gases in direct contact with the large means of containment
- quantities greater than 4,000 kgs and offered for transport by one consignor
- and subsidiary class placards if this product has a subsidiary class of Class 1, Class 6.1
            due to inhalation toxicity,
-          Class 4.3,  and Class 8 and
-          new shipping names for Class 7 substances.

RADIOACTIVE MATERIAL, URANIUM HEXAFLOURIDE, FISSILE, UN2977 or RADIOACTIVE MATERIAL, URANIUM HEXAFLQURIDE, UN2978

Danger Placard if mixed load of different UN Numbers and over 500 Kg .

Marine pollutant labels and placards are required if on a ship but labels are not required if in
small quantities in small containers. Placards are not required for less than 500 kg in large
containers.

Retro-reflective placards are no longer required.

Elevated temperature placarding requirements for Classes 3 & 9.

 6  Documentation

Standard shipping document currently used is now required for all shipments other than the
few identified as “Special Cases” or by a Special Provision ( for example SP37).

No requirement for consignee name and address or carriers name.

No requirement to sign shipping document.

Date the shipping document was prepared or first given to the carrier.

“Residue Last Contained” followed by shipping name can used if quantity is less than 10% of the means of containment.  Cannot be used for Classes 2 and 7.

Waste manifest no longer part of Clear Language.
 
An unbroken 24 hour telephone number where a consignor or other organization can be reached for technical information.

Consignor must ensure carrier has a shipping document.

Class 7 has additional shipping document requirements. (Sec. 447 of the IAEA).

Train Consist requirements.

Additional Shipping documents:

Section 1.16  500 kgs exemption. (List of primary and subsidiary classes and number of packages and no more than 30kgs per package.  Eg: Class3(8) number of means of containment -10) DOES NOT APPLY TO:

• Forbidden items
• Requires a control or emergency temperature
• Primary or subsidiary Class 1
• Class 2.1 with water capacity greater than 46 L
• Class 2.3
• Class 4 PG I
• Class 5.2 unless they are limited quantities
• Class 6.1 PG I and 6.2
• Class 7

Section 1.17(5) Limited Quantities -        List of classes of dangerous goods when accumulation exceeds 500 kgs..

Section 1.19 Samples.
Section 1.44 Residue of dangerous goods in a drum(s).  List by class and number of packages.

Documents between consignors, carriers and receivers can be transferred and stored
electronically (on computer) but a paper copy must always accompany the load and a person
is in possession of the dangerous goods.

7   Accidental Release and Imminent Accidental Release
   
Simplification of reporting requirements

- elimination of ‘lost, stolen, or misplaced’ (explosives and radioactives)
- elimination of ‘any damage’ to bulk containers or pressurized containers (Some requirements may be found in a safety standard
- some changes to reporting quantities
- required to report any quantity of Class 2.1 and 2.2
- required to report over 25 kg or litres of Class 9
- simplified 30 Day Report

• Schedules 1, 2, and 3.

New Schedule 1 lists the dangerous goods by UN Number and contains many new shipping names.  The columns headings in this schedule have changed.

New Schedule 3 lists the dangerous goods in alphabetical order and is cross-referred to Schedule 1 by UN Number.

Schedule 2 contains new Special Provisions.

9 Special Cases (replaces Part 2 Application [Exemptions)

Exemptions for Personal Use requirements (current retail sales - Sec 1.15).

500kgs exemption. Each means of containment has a gross mass of 30kgs or less and
is accompanied by an abbreviated document, property safety marked and proper
training requirements are met. (Sec. 1.16).

Limited quantities with new requirements. (Sec 1.17 and column 6 of Schedule 1 - amount limits). 

Samples taken in the field to be sent for testing

Totally exempt if:
  
- reasonably believed to contain Dangerous Goods
- Less than 10 kgs or liters
- Package marked with ‘Test Sample” and document shows name and address of the consignor
  and marked with ‘Test Sample” (Sec 1.19).

Agricultural exemptions for:

• less than 1,500 kgs. on licensed farm truck.
• Less than 3,000 kgs. From a retail outlet to place of use and less than 100 kms.
• Pesticides solutions.  Some classes not included and ERAP requirements.

Dangerous Goods / Hazardous Materials Training

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