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Important Notice regarding amendments to Transportation of Dangerous Goods Regulations

Ottawa, Ontario
K1A 0H3

July 28, 2008

To: Canadian Hazardous Waste Export / Import /Transit Permit Holders

Re: Advisory Note Regarding Impacts on Waste Permits Issued under the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR) Resulting from Transport Canada’s Amendment 6 of the Transportation of Dangerous Goods (TDG) Regulations

This is to inform you that Amendment 6 to the Transportation of Dangerous Goods Regulations, which came into force on February 7th, 2008 removed the Class 9 hazardous class criteria for leachate toxicity and environmentally hazardous substances. These Class 9 criteria were specific to substances intended for disposal, ie. wastes. As a result, Environment Canada (EC) assumes responsibility for the control of these hazardous wastes as they no longer meet the definition of dangerous goods under the TDG Regulations.  

Under the Canadian Environmental Protection Act, 1999 (CEPA 1999) and the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR) export, import and transit permits are normally issued with a validity period for up to one year. In the case of hazardous waste that was classified as leachate toxic or environmentally hazardous at the time of notification, the TDG Regulations product identification number (PIN) UN3082 for liquids and UN3077 for solids will appear in the permit issued by the Minister of the Environment.

Movements under existing permits issued for environmentally hazardous and leachate toxic waste still require the use of the movement document in the usual fashion. Under the EIHWHRMR, the description of the hazardous waste in the permit is required to match the information that is set out in the movement document which has meant using the PIN UN3082 and UN3077.

All existing valid permits will remain in effect until they expire, no new export, import or transit permits will be issued under CEPA 1999 to account for these changes. Therefore, in order to remain compliant with the Amendment to the TDG Regulations, you are advised to no longer use the PIN UN3082 and UN3077 on the movement document for environmentally hazardous and leachate toxic waste until further notice. When completing the boxes on the movement document for the hazard class, PIN number and the packing group number, it is suggested that N/A (not applicable) be entered instead.

With respect to the appropriate shipping name to be entered on the movement document, a description such as “environmentally hazardous waste” or “environmentally hazardous waste subject to EIHWHRMR” would be appropriate.

In order to remain compliant with EIHWHRMR and CEPA 1999 when crossing the border, it is also recommended that a copy of this advisory note accompany the movement document and permit to be deposited at the Customs Office at which the hazardous waste is to be reported under section 12 of the Customs Act.

Please be advised that EC has informed Transport Canada and the Customs offices of this action. Should you require any further information concerning this issue, please contact Mr. Joe Wittwer at (819) 953-2171 or by fax at (819) 997-3068.

Carolyne Blain
Director
Waste Reduction & Management
Public and Resources Sectors
Environment Canada