Introduction to Transport of Dangerous Goods (TDG) Regulations for workers in the Department of Biological Sciences

Executive Summary:
  1. TDG Regulations apply to persons involved in shipping & receiving and transport of hazardous materials via road, rail ship and air.
  2. People in Biological sciences who transport small amounts of hazardous materials to/from field sites may be exempt from many of the requirements IF they qualify for some of the exemptions such as the "Limited Quantity Exemption".
  3. The Limited Quantity Exemption specifies the maximum container size that can be used for a material but you can pack several containers together in a box and you can transport several boxes of containers at once.

Nota Bene: although the limited quantity amount for some material may be 1 litre, this is not the maximum amount that can be in a shipment, rather it is the maximum container size to hold the material. You can pack several containers in a box (total mass <=30 kg) and you can transport several of these boxes at once.

About TDG Regulations:

The amended Transport of Dangerous Goods Act, 1992 (enacted June 2009) is federal legislation designed to regulate the movement of dangerous goods via roads, rail, air, and ship. It aims is to ensure that any shipping is done in a manner that enhances the safety of the person involved in the transport as well as the general public and the environment. In case of accident, emergency officials can quickly identify the hazard based on the warning placards displayed on the vehicle.

The Transport of Dangerous Goods Regulations are the guidelines used to promote the aims of the Act and Alberta Transportation enforces these regulations here. While much of the legislation is aimed at controlling large volume shipments via transport trucks or rail cars, these regulations may impact smaller quantities that an individual might be transporting, perhaps to a field research site. Unfortunately, these regulations are very detailed and difficult to interpret for someone who hasn't studied them extensively.

Read a short Primer on TDG from Transport Canada. Some plain language summaries of the regulations appear in Safety Bulletins published by Alberta Ministry of Transportation. These pages give you an overview of the requirements but may not go into the details for small quantities or exemptions.

Requirements for transporting items that are dangerous goods: Dangerous products are considered hazardous if they have certain properties related to pressure, flammability, toxicity, biohazard, corrosiveness or radioactivity. If you are transporting items that are considered to be dangerous goods, then you need to meet certain criteria in terms of: training, packaging, documentation and use of warning labels. Specifications may differ for transport via road, rail, ship and air.

The nine hazard classes in TDG are:

Class 1 explosives
Class 2 gases
Class 3 flammable liquids
Class 4 flammable solids (spontaneously combustibles and substances that emit flammable gases on contact with water)
Class 5 oxidizing substances and organic peroxides
Class 6 poisonous (toxic) and infectious substances
Class 7 radioactive materials
Class 8 corrosives
Class 9 miscellaneous products or substances (e.g. wastes or materials considered dangerous to the environment)

Note: these classes are similar to ones listed under WHMIS legislation but WHMIS involves training of workers to avoid personal injury from contact with hazardous materials and is different from TDG legislation. WHMIS training is not the same as TDG certification.

Here is a web page with the TDG diamond shaped placards that appear on containers and trucks.

The specific requirements under TDG include:

  • identifying and classifying the material
  • proper packaging
  • shipping documents
  • container labels and marks
  • operator training & certification
  • Emergency Response Plan
  • Accidental Release Reporting

A TDG training course would cover all these topics and is required for people involved in the shipping, transport and receiving of dangerous goods. Rectification is required every 3 years (for road, rail or ship transport). The training can be obtained on campus offered online by the Office of Environment, Health and Safety. It is free to University members; register here.

Relevance to workers in the Department of Biological Sciences:

There are two situations/areas that might involve require TDG training for people in our Department:

  1. if you are involved in shipping and receiving of hazardous materials
  2. if you actually transport hazardous materials

Most all shipping and receiving is done through the Biostores so the staff there maintain their TDG certification to be able to ensure that packaging is correct and to fill out the complex shipping documents required (especially for air transport).

We also have people who transport dangerous products such as: alcohol, lead-acid batteries, propane or microbial cultures on public roadways to/from field sites both inside and beyond Alberta and they too should be aware of the requirements for complying with the TDG Regulations or be subject to financial penalties ( i.e. fines). However, if you are carrying small quantities of hazardous materials, you may be exempt from all the requirements normally associated with TDG. It is up to the individual and their supervisor to review the regulations to see what they need to do to comply with the legislation.

I have reviewed the TDG regulations and tried to identify the exemptions that might apply to different situations for people in our department. Part 1 section 1.17 of the Regulations describes the Limited Quantity Exemption and this may be the most important part for us. Although the requirements are less stringent for limited quantities, you must still package items properly, lable them and may need some documentation accompanying the shipment.

Further information on the Limited Quantity Exemption and some examples of materials that might be transported in our department under exemptions.

Links: Transport Canada Transport of Dangerous Goods Directorate TDG Act and Regulations Alberta Ministry of Transportation Dangerous Goods Handling

Alberta Ministry of Transportation Dangerous Goods Safety Bulletins
there are a variety of topics including: propane tanks, liquid nitrogen, batteries, limited quantities, waste chemicals, refrigerant gases, etc. These bulletins are based on the Federal Government Regulations but may be easier to read and understand.

Contact Environment, Health and Safety (Ask EHS) if you have any questions regarding TDG.