TDG – Unit 7

Accident Reporting

Part 8 of the regulations sets out the requirements for what you need to do in the event of an accidental release of dangerous goods. Understanding the importance of when to report, as well as the proper reporting procedures, cannot be under estimated. The Clear Language regulations contain two new definitions (replacing “dangerous occurrences”) which are important for you to know.

Accidental Release

An “accidental release” is defined as an unplanned or accidental discharge, emission, explosion, outgassing or other escape of any dangerous good. This also includes an unplanned or accidental emission of ionizing radiation that exceeds a level established by the “Nuclear Safety and Control Act”.

Imminent Accidental Release

An “imminent accidental release” of dangerous goods in transport involves an incident where there is “likely” a need to remove or transfer dangerous goods to another means of containment, or there has been damage to the means of containment which could result in an accidental release.

Accidental Release - Notification

In the event of an imminent or accidental release of dangerous goods, the person who has possession of the dangerous goods must immediately report. An immediate report of an imminent accidental release is considered to be an immediate report for any subsequent accidental release.
While each person who has possession of the dangerous goods at the time of an accidental release, a “dangerous goods accident” or a “dangerous goods incident” must make an immediate report, if one person makes the immediate report, the other persons are not required to make additional immediate reports.

Accidental Release - Notification

An immediate report notifies the appropriate parties and provides them with the information they will need to know to provide an appropriate response. In the event of an imminent or accidental release, a person who has possession of the dangerous goods must make an “immediate report” to the persons listed below:

  • the local police and appropriate provincial authority;
  • the person's employer;
  • the consignor of the dangerous goods;
  • road - the owner, lessee or charterer of the vehicle;
  • rail - CANUTEC at (613) 996-6666;
  • for a ship, CANUTEC, a Vessel Traffic Services Centre or a Canadian Coast Guard radio station;
  • Air - for an aircraft, an aerodrome or an air cargo facility, CANUTEC must be notified. Also, the nearest Regional Civil Aviation Office of the Department of Transport and, if the aerodrome is an airport, the operator of the airport;
  • for Class 6.2, Infectious Substances - CANUTEC;
  • for an accidental release from a cylinder that has suffered a catastrophic failure - CANUTEC .

Immediate Reporting - Provincial Authority
The regulations require immediate reporting to local police and the appropriate provincial authority. When a report is made directly to the local police, it is expected that they will inform the local fire department. Depending on the province, the following must be notified:

A copy of this table is available in the regulations or in the “links” section of this program accessible on the home page.

Immediate Reporting Information

The “immediate report” must include as much of the following information as is known at the time of the report:

  • the shipping name or UN number of the dangerous goods;
  • the quantity of dangerous goods before the accidental release;
  • the quantity of dangerous goods that is known or suspected to have been released;
  • the condition of the means of containment including details as to whether the conditions of transport were normal when the means of containment failed;
  • for an accidental release involving a cylinder, a description of the failure;
  • location of the accidental release;
  • for a ship, the position of the ship and the next location at which the ship will be at anchor or alongside a fixed facility;
  • the number of deaths and injuries resulting from the accidental release
  • an estimate of the number of people evacuated from private residences, public areas or public buildings.

30-Day Follow-up Report

The Regulations also require the development of a 30 day follow-up report. A 30 Day follow up report is required whenever an immediate report was necessary. This report must be made by the employer of the person who had possession of the dangerous goods at the time of the release, or by a self-employed person. The old regulations contained a specific form that was to be filled out for a 30 day follow-up report. This form has been dropped in the Clear Language Regulations and replaced with a list of the information required.

30-Day Follow-up Report

The follow-up report must be made, in writing, to the Director General within 30 days after the release and must include the following information:

  • name, address, telephone number and place of business of the person providing the information;
  • date, time and location of the release;
  • name and address of the place of business of the consignor;
  • the classification of the dangerous goods;
  • the estimated quantity of dangerous goods released and the total quantity of dangerous goods in the means of containment before the release;
  • a description of the means of containment involved and a description of the failure or damage including how it occurred;
  • for an accidental release from a cylinder that has suffered a catastrophic failure, the certification safety marks and a description of the failure;
  • the number of resulting deaths and injuries;
  • an estimate of the number of people evacuated from private residences, public areas or public buildings;
  • if an emergency response assistance plan was activated, the name of the person who responded to the emergency in accordance with the emergency response assistance plan.

Quantities Used for Determining a “Release”
A “release” consists of a quantity of dangerous goods, or an emission of radiation, dependant on specific quantities. The quantities that require reporting have changed for some of these minimums in the Clear Language Regulations. Reporting is required when the amount of a release is greater than the quantity or emission level set out below:

EMERGENCY RESPONSE ASSISTANCE PLANS (ERAP)

The Emergency Response Assistance Plan (ERAP) is a major component of the TDG system. When an ERAP is required, everyone involved in the transportation of these goods must have an understanding of their role with respect to these plans. Whether your responsibility is writing the plans, emergency activation/notification, emergency response, or you are entrusted with the care of these goods, you must have a thorough understanding of your role in the event of an emergency or potential emergency.

ERAP - Responsibilities

Part 7 of the Transportation of Dangerous Goods Regulations, requires that a person (consignor) who offers for transport or imports certain dangerous goods must have, when required by the regulations, an approved Emergency Response Assistance Plan (ERAP) in place.
As a result of the introduction of the Clear Language TDG Regulations, the number of dangerous goods requiring an ERAP has increased significantly and they are also now listed in Column 7 of Schedule 1 of the regulations. Section 7.15 to section 7.19 of the regulations, along with Column 7 of Schedule 1, stipulate the dangerous goods and the concentration or quantity for which an ERAP is required. Clear notification of the availability of this plan, as well as a means of activating this plan, must accompany these dangerous goods at all points in their journey.
Dangerous goods requiring an ERAP are generally considered more harmful than others and may present serious hazards in the event of an accident. Response to this type of an accident often requires special equipment or specially trained and qualified personnel.

EMERGENCY RESPONSE ASSISTANCE PLANS (ERAP)

An ERAP is designed to provide on-site assistance to local authorities in the event of an accident. The “assistance” provided includes the provision of 24 hour emergency response advice.
The persons who are required to file an ERAP (with Transport Canada) are required to take many factors into account. These factors are outlined in part 7 of the regulations and include:

  • the nature of the dangerous goods,
  • specialized training, equipment, analysis of hazards,
  • mode(s) of transportation,
  • geographic area to cover and means of containment.

Applying for Approval of an ERAP
A person must apply, in writing, to the Minister of Transport, or a designated person, for the approval of an ERAP. The application for an ERAP approval must be signed by the person submitting it and must include the following information:

  • the name, business address, telephone number, e-mail, and facsimile of the applicant
  • the classification of the dangerous goods to which the ERAP relates;
  • information relating to the means of containment used to transport the dangerous goods;
  • the geographical area covered by the ERAP;
  • the telephone number to call to have the ERAP activated immediately;
  • a description of the emergency response capabilities available to the person offering for transport or importing dangerous goods
  • the number of persons qualified to give, by telephone, technical advice about the dangerous goods, as well as the number of persons qualified and available to give advice and assistance at the site of an emergency,
  • a list of the specialized equipment that can be transported to and used at the site of an emergency,
  • a general description of the response actions capable of being taken at the site of an emergency,
  • a description of the transportation arrangements to bring specialized emergency response personnel and equipment to the site of an emergency, and
  • a description of the communications systems that can be made available at the site of an emergency;

Additional Information Required on a Shipping Document

The shipping document for dangerous goods requiring an emergency response assistance plan must include:

  • the reference number of the emergency response assistance plan issued by Transport Canada preceded or followed by the letters “ERP” or “ERAP” or “PIU” (French);
  • the telephone number to call to have the emergency response assistance plan activated immediately.

Consignor Responsibilities

The consignor who is required to file an ERAP is responsible for all aspects of the development of an ERAP. When resources are required from a contractor, the person is required to demonstrate a contractual arrangement with the selected contractors before an ERAP is approved. It is also the responsibility of the consignor requiring an ERAP to verify and ensure that any contractor is capable of providing the required response.
Transport Canada has an active program to register, inspect and approve ERAPs. All ERAPs are subject to review and investigation by regional Remedial Measures Specialists (RMS). An RMS may request changes where required and if these changes are refused or not implemented, an ERAP registration may be revoked.

External Alerting

The TDG Regulations discuss situations where notification of authorities is required when a shipment is interrupted. The ERAP should include how fire and police departments, emergency measures organizations, federal and provincial authorities, news media, volunteer or off-duty workers will be contacted. The plan should also identify the agency that will lead in responding to an emergency.

Emergency Action / Containment / Cleanup

Methods to minimize danger should be provided for each material handled as well as the location, capability and limitations of equipment to be used.
A plan should describe methods for containment, storing, transferring and disposal of dangerous goods and should include any scenario likely to be encountered.

Emergency Response Assistance Planning

Alerting - An ERAP should describe how emergency calls are processed and the emergency action initiated. Twenty-four hour emergency telephone numbers must be prominently displayed in the text. The plan should contain an accurate, up-to-date telephone roster which may include individuals within the organization, regulatory contacts, CANUTEC, containment and cleanup equipment contractors, technical specialists, public health and environmental authorities, aircraft charter operators and the news media. For telephones of individuals involved in the plan that are not staffed 24 hours a day, the times they will be answered should be included.

Your Responsibility

When your work responsibilities involve the transportation of dangerous goods requiring an ERAP, always be certain that the proper documentation accompanies the goods, and that you familiarize yourself with all aspects of notification and activation of an ERAP.

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