TDG training, the eternal problem that has been going on for so many years. I began my career in 1999 and even then the regulations did not really help to define training requirements regarding the Transportation of Dangerous Goods Regulations (TDGR). It is fair to say that we are no further ahead today.
It is important to understand the training requirements for your company, including:
- Who? Which employees require training?
- What? What training do they need?
- When? How often do they need to be trained?
- How long? Do they need a 4-hour course, 1 day, 2 days?
- Regulations? What parts of the Transportation of Dangerous Goods Regulations should be addressed?
This blog is one in a series that I hope will help you establish the training requirements for your employees.
We will start by asking questions and we will find the answers in regulatory articles. I will interpret them to guide you as best as I can.
Before I begin, I would like to clarify the term ”Transportation”. When Transport Canada uses the term transportation includes any activity that relates to the request for transportation by all modes of transport (contacting a carrier for a shipment either by ground, air, or sea), transportation (e.g. truck driver), handling (employees who prepare shipments and/or receive dangerous goods (DG), and also includes the import of DG by all modes of transport (air, sea, or transborder).
One of the problems with this term has always been that companies tend to believe that because they do not carry DG, this does not apply to them but that is wrong given what the term means.
Furthermore, we must ask ourselves the following question:
Who needs TDG training?
a. Yes, if you are a driver/carrier: meaning a person who, whether or not for hire or reward, has possession of dangerous goods while they are in transport.
b. Yes, if you are handling: meaning loading, unloading, packing, or unpacking dangerous goods in a means of containment for the purposes of, in the course of, or following transportation and includes storing them during transportation.
c. Yes, if you make arrangements for transport or are the consignor: meaning, for dangerous goods not in transport, to select a carrier to transport the dangerous goods, to prepare, or allow the preparation of the dangerous goods so that a carrier can take possession of them for transport or to allow a carrier to take possession of the dangerous goods for transport.
Subsequently, a company must understand that they still represent a consignor because of the definition in TDG is as follows:
Consignor: The person in Canada who:
a. is named in a shipping document as the consignor; (that is, the physical address from which the DG is being shipped from)
b. imports or who will import dangerous goods into Canada; (that is, the DG enters Canada by air, sea, or transborder) or
c. if paragraphs (a) and (b) do not apply, has possession of dangerous goods immediately before they are in transport. (that is, a warehouse company that provides storage services and subsequently prepares DG shipments for its customers)
So that’s it for now. See you soon for more … in my next blog, we will further determine how to establish your training needs.
Of course, you can contact us anytime so that we can help you in determining your training needs.
See you next time!