Advisory Note Regarding recent amendments to the Transportation of Dangerous Goods Regulations (TGDR) and their impact on Permits Issued under the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR) and the Interprovincial Movement of Hazardous Waste Regulations (IMHWR) (December 9, 2015)

Movement Documents

Two regulatory amendments affecting the shipping document under the Transportation of Dangerous Goods Regulations (TDGR) administered by Transport Canada were adopted.

The first was published in July 2014, and came into force on July 15th, 2015. It requires that a shipping document includes a consignor certification that complies with Section 3.6.1 of the TDGR. This Section lists five acceptable consignor certifications, including the consignor certification set out in Section 5.4.1.6 of the United Nations Recommendations, which is precisely the one chosen to be include in the current movement document required under the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR) and the Interprovincial Movement of Hazardous Waste Regulations (IMHWR) for its compliance with the TDGR. Therefore, no changes are needed to the current movement document to be consistent with the July 15, 2015 requirements under the TDGR.

However, the second regulatory amendment to the TDGR may result in the need to prepare additional documents. It was published in December 2014 and came into force on July 1st, 2015. It requires that the UN number be shown before the shipping name in the description of the dangerous goods (Section 3.5 of the TDGR) on the shipping document. If you are moving a hazardous waste or a hazardous recyclable material which is also a dangerous good, you will still need to provide EC’s movement document and you will also have to provide the shipping document for the TDGR. This means that it is no longer possible to use only the movement document in order to comply with both the TDGR and the EIHWHRMR/IMHWR requirements. The format and required information set out in the EIHWHRMR/IMHWR cannot be modified. Please contact Transport Canada for more information on how to comply with the TDGR.

UN3077 and UN3082

The publication of the 18th edition of the United Nations Recommendations has occurred and affects two product identification numbers (PIN): UN3077 for Environmentally Hazardous Substance, Solid, N.O.S. and UN3082 for Environmentally Hazardous Substances, Liquids, N.O.S. These two product identification numbers (Class 9 dangerous goods as per the classification requirements of the TDGR) can now be used again to describe hazardous waste or hazardous recyclable material under the EIHWHRMR and the IMHWR. According to Chapter 2.9 of the UN Recommendations, these UN numbers can be used for wastes covered under the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal. Furthermore, Subsection 2.2(4) of the TDGR provides that a consignor may use the appropriate classification in the UN Recommendations to describe the dangerous goods. As a result, Environment Canada withdraws its previous Advisory Note of July 28, 2008.

Existing valid permits issued under EIHWHRMR containing N/A (Not applicable) as the PIN will continue to be valid until their expiry date. Until the expiry of such existing permits, the associated movement documents should contain N/A for the purpose of complying with the EIHWHRMR and ensuring permits and movement documents match.

When crossing the border, it is recommended that a copy of the present Advisory Note accompany the movement document and permit.

The use of these UN numbers for the purpose of complying with TDGR remains the responsibility of the permit holder. Please contact Transport Canada for more information on how to comply with their Regulations.

Contact information

For information on the TDGR, visit Transport Canada’s web site.

Any question regarding the TDGR may be directed to Transport Canada.

For information on the EIHWHRMR and IMHWR, visit Environment Canada’s web site.

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