Clarification on Use of New Limited Quantity Markings in Canada

Clarification on Use of New Limited Quantity Markings in Canada
Dec. 17, 2010 - PRLog -- Clarification on Use of New Limited Quantity Markings in Canada

Figure 1As the start of 2011 approaches, those who transport dangerous goods under the ICAO Technical Instruction, the IATA Dangerous Goods Regulations and the International Maritime Dangerous Goods (IMDG) Code have started to prepare for the new limited quantity marking these regulations have adopted (see Figure 1).

This marking was originally included in the UN Recommendations on the Transport of Dangerous Goods as an easily-recognizable, yet easy to apply, symbol for dangerous goods in limited quantities. It replaces the previous UN solution, which was the identification number within a diamond-shaped outline. This marking, it was argued, was difficult for shippers of many different products to use, since the number had to be changed for each different product. The new marking eliminates the UN number, and therefore can be used for multiple materials.

Unfortunately, while this marking has been accepted internationally, Canada's Transportation of Dangerous Goods (TDG) Regulations has not yet been updated to refer to this new marking. The section on limited quantities, section 1.17, gives four options – the words "Limited Quantity", the abbreviation "Ltd. Qty.", the words "Consumer Commodity" or the old marking of the UN number in a diamond-shaped outline. This leaves shippers who want to use one set of marks for all modes in a dilemma.

Transport Canada intends to address this situation by in proposed Amendment [A]. This amendment would replace section 1.17(4), which currently authorizes the use of the UN number in the diamond-shaped outline, with text that would refer instead to the new marking without the UN number. The proposed text of this amendment can be found on Transport Canada's website. However, many limited quantity shippers have wondered whether they can start using this mark immediately for ground transport, since it is used already in the international regulations.

Transport Canada recently gave the following clarification of the current situation for limited quantities: "As it stands right now there is no mechanism in the Transportation of Dangerous Goods Regulations that would permit the use of this new Limited Quantity marking for road transportation prior to the provisions of the amendment coming into force.  An Equivalency Certificate could be applied for through our Headquarters in Ottawa but it would require some review and examination." So, until Amendment [A] has been finalized, this marking is not suitable when preparing shipments for ground transport only. If used, it should be supplemented with one of the other four markings currently authorized by section 1.17. For companies where this presents a serious issue, obtaining an equivalency certificate (previously known as a permit for equivalent level of safety) may be the best temporary solution.


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ICC The Compliance Center (ICC) is a provider of solutions for regulatory compliance in transportation and workplace safety, specializing in labeling, packaging, training, consulting, Dot Placards, Un packaging, GHS labeling, GHS, Iata publications, MSDS.
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