Updates to Part 6 of the Transportation of Dangerous Goods Regulations (TDGR)
March 3, 2022
Transport Canada will be updating Part 6 of the Transportation of Dangerous Goods Regulations (TDGR) in October 2022 to drive improvement in training on Transportation of Dangerous Goods Regulations (TDGR) Gaps have been observed by TDG Inspectors across Canada regarding lack of skill and knowledge of regulations and inconsistent or insufficient training when handling dangerous goods in transit. To address these inadequacies Transport Canada is looking to remove the term ‘adequately trained’ for individuals and require proof that persons are competent in the application of TDG knowledge on-the-job. General awareness and function-specific training and assessment based on competency are proposed as a new national training standard.
The current Chemscape TDG course will keep you compliant for the next 3 years and will be updated in the Fall to meet the awareness training requirement of the Part 6 update. Chemscape is exploring ways to help our clients meet the function-specific competency training requirements which are still in draft from by Transport Canada.
Watch the Updates to Part 6 of the Transportation of Dangerous Goods Regulations Webinar
Angela: I'm getting ahead of myself, but we started getting messages from you saying there was some urgency. And I've been on the calls with some of the Transport Canada representatives provincially saying, "Oh, yeah. Everything's changing." I felt there was a sense of...what do you call it? Fear mongering? And I don't like that. I've been on these meetings going for years now and things go slowly. And there is a chance to provide input to the government, and I completely recommend that.
I'm not gonna go into that today. I wanna assure our clients that you have tools at your hands, at your fingertips, and that our course will stand strong through the transition and really to encourage you to develop a TDG program, just like we have hygiene programs, safety programs, things like that, just something. And I'll say it again, something you can point to when the regulator comes and say, "Look, we figured this out. If you can find something wrong with it, tell us and we'll update that." That's your due diligence, that's your bulletproof vest. So, that's what I wanted to say. Yes. So, I'm a CIH, CRSP, registered author, and TD trainer. I try not to talk about it a lot, but these are just things that I used to bring to bear for compliance purposes for you guys and whomever I work with. So, feel free to get in touch when you've got questions, and we can help.
Like I said, I've been part of the general advisory group, Transport Canada since the...on funnel liquids classifications since Lac-Megantic. And that was 2014, sadly. Anyway, my goal today is, yeah, less about when and what Transport Canada wants you to do differently. Ultimately, the employer is responsible to train and deem their employees competent. And that hasn't changed, and it mirrors our OHS responsibilities through that legislation, and we know those really well. And remember that if a worker is not certified in TDG, they need to be supervised by someone who is, that's never changed. So, I think we're really just...they're using some new terminology to put a bow on it and just encouraging people to get better at dangerous goods transportation.
So, I'm here to make it simple. The update's simple, in particular, and showcase how to...look at that. I just seem to know this. Chemscape can be an effective part of your TDG program. And I only have 20 slides, so that should give us enough time at the end for questions. Otherwise, I type them in and Maureen and Moriah will be there, answer them all at the end. So, I'll ask you to take notes a few times, some of the points. But if you email us, we'll send you the slides out too so that you can share that.
Objectives of TDG Training Update
Here we go. So, after Lac-Megantic, it was transport safety audit to ensure that the root causes were found. I don't know if you ever saw that poster, but there were like 18 root causes, a safety person's dream, right? Not so much. But just underlines the fact that it wasn't one thing.
Here, we're big on training, but training was part of that, the whole findings. And then Canada didn't wanna see another town wiped off the track. So, remember, that is the driving force on some of these things. Yeah. We're so many years out, but like I said, things take time to change and there has been a lot of changes in between. We live in some amazing times with regard to regulation change. Transport regulations haven't changed in 20 years. So, now we're just catching up. So, there were many audit findings, of course. And that runaway train incident is...this training is one of the stock gap measures.
So, in fact, annual statistics show that training is a factor in many incident investigations and roadside inspections. But my personal slant is that, is it really the training or is it complacency? So, I believe dangerous goods can be taken too lightly and case in point, lithium batteries. So, systems need to be put in place for it to be done properly. We tell them, industry tells Transport Canada that it's not the big guys, and we have programs in place. It's small people that...again, that's the complacency, is it really dangerous goods? Uh-huh. It's in the table, so you need to treat it appropriately. So, if you've got a good program, that's one of your checkboxes marked. Okay? Next.
Proposal: a Competency-Based Approach to Training & Assessment
So, their proposal, the changes update is a competency-based approach to training and assessment. This isn't new, guys. This has always been the case. And in the U.S., the competency has also been there. They even put it on their driver's license. You know, it's that important. And so, Canada went to great labor to create a CGSB standard around the training and assessment. And so, it just means a lot more people were involved and they've got something to point to that can be updated like an ASTM standard, yeah. Things like that. So, that's to know.
Timeline: Prepare to Update Your Training Materials This Fall
There we go. Timeline. And so, I don't want this to be confusing, but old and new are acceptable from now...oh, sorry, October 22. So, if you hear things changing in the fall, yes and no. You can jump on the new expectations, or you've got a whole year to come into compliance. So, come October, prepare to update your training materials and develop a task list, performance criteria, and assessment tools. And I'm gonna go into that a bit later. So, the new Part 6 will actually come into play October 2023. And that, again, this is not set in stone yet, the guidance documents are still in draft. We're still petitioning the government for a practical deadline. So, this could be shifting. And the whole COVID thing just showed us how much things can shift, and who knows war could push things out too? It's government and they get different direction all the time.
So, after 2023, so until 2025, we've got the new Part 6. So, you'll need to change those training certificates. They need to say competency certificates. So, again, like I say, relabeling and an acknowledgment a few of the changes, but I don't want people thinking it's a completely different system. New part after 2025. So, you can see the progress just like Remis took many years to implement. This will take some time as well. And the trick here, some of my colleagues will say is timing it. So, which employees are fully...you know, that certificate is three years for road and rail. And if you can get everybody pretty much trained before this fall, then you've got a three-year window for that. And then as you can imagine, new hires and things like that, then you just slot them in with the new training and assessments and it's less of a burden. So, just managing that means if you don't have. That's one of the things we clarified. Everybody starting October 2023 does not need this training. It goes to expiration of your tickets.
Amended Training Requirements
So, a bit more diving into that requirement. So, TDGR for dangerous good regulations requires currently people are adequately trained. So, the adequately has changed to competent and for their tasks. Again, it's going to be an exercise in categorizing what your workers are doing for TDG tasks. Certificates to perform tasks, training certificate required, then it becomes a certificate of competency. Just changing the words, certificate format, aspects of training indicator.
So, on the back of your ticket, you said... And here, we're gonna have more... And this is another contentious part. It's like, "How do we get all these codes? And how do we summarize all this function-specific training onto the back of a car?" So, that is left to be determined. We'll see how that goes. Because what is it really benefit, right? Are the workers gonna understand the codes? It's mostly inspectors that need to be able to reconcile codes with what they're inspecting, the performance criteria. Foreign carriers certificates, that's American truckers, right? They are equivalent. Of course, they gotta do that. It's a cross-border trade. Record of training, requirement to have a record of training for each employee, and clarity on what the record of training must contain. They wanna see what they wanna see. So, I'm gonna help you with that. And they do have guidance documents that are gonna help us with that too.
Enforcement of the TDGR
Enforcement, we always say, "So, what are they gonna ask us?" What can they really ask you? They wanna see your certificate. Right? So, pull it out. That was one of the big things on truck stops is certificates on hand. They may go electronic, wait for that, or don't wait for that, but you'll see that. Yeah. Something to have in your back pocket. If guys can have some...if they carry their cell phones and things like that, truckers do, but rail workers, not necessarily, right? So, again, we're lobbying with Transport Canada say, "Hey, if you can pull up their files from the office and you have access, why do they need them on their person at all times?" They're working in a facility, they're not on the road. So, that was just understanding where the regulations come from, allows you to push back and explain industry. Being on these boards, that's one thing I realized is people in Ottawa don't understand...I've heard it before. Don't understand how work gets done. So, the more we can share with them, the closer we would come to our expectations. So, is your certificate current? Is all the required information present? So, is it a valid certificate? If you're getting it from a provider, they should have done all that homework for you. And is it signed? Oh, gosh. How many times do we hear it's not signed? And so, if there's a way that you can have your certificates pre-signed, you know, when we pass, it says your company acknowledges this, that's the best. Yeah.
Gone are the days of us being able to walk up to our supervisor and say, "Here, sign my ticket." Systems take away that human error or, you know, it doesn't seem like much when you get your certificate, but it's huge for Transport Canada, and they mark it on their results. So, review training records. Inspector will say, "Are the TDG program documents present? And is there a competency component to the program?" That's where I'm going, is document what you've trained your people in in TDG. When I was in charge of this, that's what I did. You know, you'll often have TDG components of all the jobs that they do. Working in the warehouse, working in the receiving, wherever. All these things, and you've trained them in that. But if you need to outline for Transport Canada, just pull it all together. Yes, they got their ticket for forklift training in the warehouse, and there's a TDG component for that. Just having that pulled together in a document that you can flash the inspectors, that just takes all the...it just gives you that check mark again. So, verify the TDG task being performed. So, again, they're just gonna say, "Oh, look at that. That's on the list, and that's what they're doing." Identify if employees receive training and assessment, or are supervised by someone who has. That's, again, record keeping.
TDG To Do List
So, here's your to-do list according to...I just pulled this out of Transport Canada expectations. All right. So, update, oh, we saw it before. There's timeline. This is the highlight I wanted. So, our Chemscape TDG course offers compliance now, and will meet the requirements for the general awareness component. So, that's the half part. And your tasks are like the field assessments and training.
General Awareness Training
So, there it is, general awareness training. If you look at these expectations, they haven't changed much from the TDG course as it is now. And, yeah. I've gone through them and we've got updates in the pipe for our course.
This is the function-specific training. And, yeah. This is a lot of words on here, but this comes from the guidance documents. Draft again, guidance documents. You can see that watermark in there. There's maybe changes to it. But you can see they've just broken down some of the roles into exact competencies. So, if you can check the box on these competencies and show it in your program that you've addressed each of these, mapped it towards their JSA, then you're golden.
Chemscape’s Resource Training
There we go. So, now I'm going to part where these are the Chemscape resources that we have. I'll go through these fast. I don't expect you to understand it all or take it all away. If you're interested, just contact one of us, and, yeah, we'll take the time to make sure it's something you can do for your organization.
This is under our training courses. You'll find that training course, something that Maureen or Moriah needs to add. So, again, just call out and we can add it in there. This is mine, prepaid. Oh, look at that in progress. Maybe it's not mine. Mine would have been completed. Okay. So, many of you have those. And again, my pledge to you, that will be updated by October. Little side note. Because of...and Maureen and I'll work it out, but you can say that you're training general awareness to the new standard come October, or you can say it's the old standard. It'll be compliant either way. And the old standard just means you don't have that expectation for the function-specific yet. You can ride the wave until you're ready to implement. But either way, got your back.
TDG SmartChart for Shipped Products
Smart chart, I don't know many... I don't know if all of you have got to know our smart chart. I spent a lot of time with this over the years and shifted out to many of you. I love this for many reasons, but, in particular, for loadout boxes and haulers. So, how often do we give SDSs to our haulers? And they, "Oh, thank you for the binder." Maybe they don't say thank you, but you know what I mean. And they throw it in the back of the truck. And yeah. When they get stopped, they'll go through it looking for your product SDS, and it may or may not be updated. But it's in there with everybody else's product that they haul. Well, with this one, it's...and they don't need that SDSs. That's not a Transport Canada thing. And they do, from an employer standpoint, they have to have an SDS in their workspace, worksite, which is their truck. But for the purposes of Transport Canada, they want a shipping document. And this to me is a...this smart chart really helps with that shipping document. It's not a shipping document, it just relays what...and you'll have that too. But sometimes as a producer, you don't have a shipping document, the carrier uses his or it's a remote location. You don't have a lot of control over what gets put on that shipping document. I think you should, and you should send it to them electronically so that you have it on file saying you told them what the packing group was, what the class number, and what placard you want it on. But this will also tell it. Comes right from your SDS. And yeah, like I said, it matches that placard so that they know highly visual, tells them the UN number that they need.
This is written exactly how it should go on a shipping document, UN number first, shipping name, to no condensate or diluent. It's a proper shipping name right out of the schedule one. The class, the packing group, they don't have to write it in, oh, whatever. I guess they would have to write it in, but they can match between their shipping document and your document. The beauty here, special provisions are lined out. I'll go into that because I haven't done this stuff. People don't appreciate the special provisions and Transport Canada does because it's all part of schedule 1, schedule 2, schedule 3.
So, shipping comments, look at this. Loadout box is located northeast corner of the site. Check in the gate for authorized access. Notes that you want them to know. The emergency response guide that's linked to your product and the reporting quantity, which is, again, reporting. Oh, we're gonna have to do a webinar on reporting because, yeah, it's changed over since Lac-Megantic as well. And they're scrutinizing that. So, Alberta has done some great job in reporting. We've heard back east and almost more reporting than any other province. But yeah. Just because...well, we're better. Sorry. Reporting. Anyway. So, routine uses, again, you guys understand our smart charts. We're putting in the hazard controls in there. There's the GHS that comes right off the SDS, there's the name of the SDS associated so they could find it, and there's the ERAP numbers if you have one and CANUTEC Emergency. So, you can see how laminating that and putting out the load box just ensures that the important information for that shipping document gets transferred to those truckers or whomever is...you can have them in the low warehouse as well as guidance for people shipping stuff.
I talked about the special provisions. The second page of the smart chart gives provisions that it's all automated, right? So, you don't have to look these things up. These come off through the SDS, the transport section. The accepted quantities, we don't see that much. But if you're sending samples and things like that, that's where those lie. And then immediate reporting. So, within Canada, it gives all those reporting numbers for transport if there's an emergency. Oh, and I already talked about that date and CANUTEC.
Transportation SmartChart for Shipping Documents
So, next one is this is transportation smart chart, not to be confused with the TDG one. And there'll be a DOT one coming out as well soon.
So, the transportation smart chart is for shipping documents. And I like this one because I would put all my products on the list here. And so, whatever's hauling out, they have all the products, the manufacturers, and then this stuff goes exactly into the shipping documents. So, again, there's always room for transcription error, but at least the guys aren't having to look it up. It's a cheat sheet, and I've been there in the doghouse, or they need cheat sheets. And a lot of times the guys will...you know, you have it already in your system electronically. This is a great audit tool for auditing as well. You come in there. Okay, okay. Let's see. When you're looking through old shipping document papers, again, you keep them for two years, right? No longer. You don't want them to find any dirty laundry. So, after two years, get rid of those things. So, that's another audit tool. But I've done trucker audits and this is a brilliant thing. You can go through hundreds of tickets very quickly to make sure they're putting in what you need them to put in. And then you give them feedback. I've changed up so many truckers' shipping documents just because, yeah, I had a cheat sheet. And they're willing to do it, right? You're hiring them, so...
SDS By TDG Report
So, here we go, SDS by TDG report. Now, the resource in your subscription, you can search your entire system for the TDG within it. So, here I have gone to the SDS by TDG report under the reports tab. You can choose some of the times, you know, if I'm just looking for all my flammable liquids, I'll click that. But here, I've just done all of the TDG chemicals products in my gas plant six binder, gas plant nine. And yeah, you can see, 16 products. And I see all the TDGs. So, I can manage them that way. Why would I use this one? Again, it's an audit tool from me from a health and safety side and from product stewardship side. Well, and receiving just to see what I'm dealing with if I'm missing any, and, yeah, to look in on the different types. So, we always see flammables, right?
Who: Determine Who Needs to Do TDG Training
Here we go. Okay. Now, back to my to-do list for you is the TDG program. Who needs to do it? So, decide who needs TDG training. Back in the day, everyone got TDG training. It was just one of those things, women's TDG, H2S awareness, you know it. Now, we're pulling that back, right? We have to rationalize who goes out, how long, and how much it's gonna cost. So, we really need to...I mean, we've been pushed to reduce that. And so, the redundancy isn't there. Many people don't understand TDG and the ones that do, need to know it well. So, there's not a lot of crossover, you know, back in the sites. And so had been there 20 years, and he was always looking over his shoulder. Well, they aren't there anymore. And yeah, some of these guys have never been trained.
So, again, figure out who needs your TDG training. That means anyone's handling offering for transport and transporting. So, yeah, even our guys with the different things, fuel trucks, any sort of thing over a certain amount of dangerous school goods need that training. So, there's also the guidance document, new, again still in draft, but the government will have this who to train on transportation of dangerous goods, a guide for employers. So, all of those people require that general awareness training. So, check those boxes as soon as you can.
What: Determine What Jobs Require Function Specific Training
Then what is...determine which job. This is the function-specific side, the tasks that require function-specific training, and then confirm that with supervisors, HR, your hazard analysis job, hazard analysis, anything you've got in that regard and document. Whenever I say determine, you wanna document as well.
Again, Transport Canada has a guide on that, but you know your processes and then provide function-specific training. Huh, just one line there. Anyway, you do this. You know you do this. Just round up where you do it and how you do it and make sure you go through the checklist that they provide. This is part of that CGSB work. And did I...Oh, there you go. This is what it looks like. So, look at this. Consignor offers for transfer. Okay. Now, you're a consignor, your company's consignor. Don't forget your marketing personnel, don't forget your sales personnel. If they're selling these commodities and they're dangerous goods, they need TDG training and they're gonna push back because mine did. And I don't care. Transport Canada requires them to have training. And yeah. Just because they work in the office at corporate, they need to know that it's a flammable liquid that they're selling to West Texas Intermediate.
So, yeah. Definitely, a consignor offers for transport that includes sales personnel. And then do they classify dangerous goods and do they evaluate substance articles against classification? This is their task, identifying if it is dangerous goods. So, that comes down to the application of the schedules on TDGR. So, check the box, yes, no, not applicable. There should be boxes on each of these lines. Do they use the part two of the TDGR? And are they using radioactive materials? Not. So, you've gone this far, you've figured out who needs a TDG training, who needs task-specific. And so, just keep going and mark off and keep on file the things that they...the competencies. Yeah. And then make sure it's mapped to each person. Next.
Why: If It Isn’t Documented, It Didn’t Happen
Why? So, if it isn't documented, it didn't happen. And so, confirm with supervisor... I just took that from the last one, but yeah, you need to keep records of the training that they had in transport of dangerous goods. And annual review is my last checkbox because it's a program and you need to find out where it's working, where it's not working. It's different from the certification of each individual TDG worker, which is three years road and rail, two years air, and anytime it's necessary. So, you need to...like anything at work, right? If they're having trouble, if there's something wrong with the work they're doing, they need to be retrained, just increasing that competency. That's it. I encourage you to give us an email, sign up for our newsletter. Stuff like this comes through anytime there's updates that we think that you guys need to know about. And yeah, give us an email if you want the slides. And remember to use our system over the web or a mobile device. I don't see one chat. Oh, there we go. Any questions? Thanks, Henry. Glad you're here.
Maureen: Hey, Angela. I had to miss just a couple of minutes there. Someone popped in. Are these slides gonna be available?
Angela: You bet.
Maureen: Okay. Thanks so much.
Angela: And I'll send it. Maureen, Moriah, anything you'd like to add? Now is my time.
Maureen: Nothing for me to add, Angela. Thank you very much.
Moriah: Yeah. The presentation's gonna be sent out to everybody.
Maureen: So, I do have a question about...so if we're using like a provider and just simply doing online training for our staff...I mean, our staff don't really handle dangerous goods like a trucking company would, but we're an oil company, so we have that side of it. I mean,
Could we count on the providers to update their training?
And if it's online training, we're gonna have to add a practical component to that or kind of wait and see what they come up with.
Angela: Yes. So, tell me, are you hands-off? Because many producers are consignors, right? So, you know, gas companies and things like that, it goes into a pipeline and they pretty much, you know, taking it away from the site by the carrier. But when it comes to oil and gas, I mean, you still...you're a consignor, right? You're selling it.
Maureen: Exactly. We're still a consignor, for sure.
Angela: Yeah. Well, and then contracts. I've been part of contracts as well. You need to look over that contract with the hauler that says they will meet and make sure you have it in writing because that's where any litigation comes back. You can stop that with your contracts and say...in your contracts, it need to say, "We will only hire TDG certified haulers." When you bring a containment to us, you put it in your contract. It needs to be appropriate for...because often, you know, in our industry, we've been giving it all to the haulers, all that responsibility. So, put that in writing. Make sure your contracts with them say that. You are responsible for meeting all...I've put the wording in myself because procurement doesn't understand. And you need to put that in there. Say you are responsible for upholding the TDG regulations, bringing the right vessel to the site, and we will check on that. And make sure you've got audit findings that show that you made sure that they were bringing the right means of containment to your site. You may not know what that is, but give us a call, we can discuss it. And that's our due diligence to protect the producer from haulers that aren't certified. And yeah.
Maureen: I like that actually, only having the TDG certified drivers, I guess, right?
Angela: Yeah. Yeah. And when I was at the truck stop, they asked him for the tickets. They only had to ask. We did this blitz, and Henry can talk about it too. He does blitzes all the time. And every trucker that came in, they asked him for their certification. Okay. And they wrote it down, and he only had to do it twice. And then every time they came to the site because they either had their training or they don't. We were given TDG training to haulers that were contracted to us, just dependent on the contract. But if they're hauling for Gibson's, they need Gibson's TDG training.
Angela: In D.C., there's a whole group of them that get together. I can't remember who's on that group, but there's a pool. And to get onto their sites, Chevron, all these sites, they actually have to have all this training. Yeah.
So, the guidance document that you talked about for employers, when would we have access to that, or do we have access now?
Angela: No, it's draft. Henry, just because we're in the advisory council, we're still beating that out. It will come out publicly, close to the fall, I imagine just because the...
Henry: I think it'll be May, June, and July. The guidance materials are released, but I think there's still some opportunity for tweaking it, and I think they need to tweak it in some areas.
Henry: But I think you can share it though, Angela, if you have access. Like, I know I downloaded and I did ask the TDG secretariat if I was allowed to share that with our learning management people so that I can start kind of mirroring up what we have in place today versus what tomorrow will look like. And they said, "Yes. Feel free to share it to start mapping out what your program..." So, it's pretty close. You know, there may be tweaks, but I think what they have out is pretty close to what will stay in place.
Angela: Yep. And I do like it. Well, I mean, like Henry says, there's a few things we're pushing back on, but it's just checkboxes. You can audit your program and make sure. So, yep.
Maureen: Would you mind sending that too then?
Angela: Yep. I can send that.
Maureen: Thank you.
Henry: Yeah. I'd love to. To Brendan's question here, I think the timelines...he was asking the timelines for the transition from draft changes. I think that's all part and parcel that will stay in alignment with October. I think by October, everything will be released. I don't think we're gonna see much pushback. Maybe some consultation is already in Gazette 1. Through the consultation, we'll hear the feedback at GPAC in May, but I think the October deadline is pretty much.
Angela: Okay. Good to know. Yeah. And yeah. What did we have, 12 months on that?
Henry: Yeah. It's from October '22 to October '23. That will be the transitional provision where you...between partial compliance and where they'll actually start enforcing the new training standards and requirements.
Angela: Yeah. Good.
Henry: Going back to a piece that you said, Angela, on due diligence, the one thing I didn't hear you note that's kind of crucial for everybody to be aware of is the validation of third-party trucking companies coming onto the site. The employer has to do the training. So, Gibson's, let's say, as an example would have to do the training, but they can't do all the training because Gibson isn't familiar with our onsite equipment, our loading and that. So, that part of it, you have to make sure is well covered under your orientation to either share with or provide to the trucking companies on-site and to provide to yourself that that worker, you know, if an incident happened on-site that they actually were confident to... You know, most of our loading is self-loading, anyways. We don't have people that load their trucks. We kind of orientated for the site. So, that's a due diligence process, the same as hiring third-party training companies is you have the ownership to make sure that they're compliant.
Angela: Good work. Yeah. Good add. And that's what that conglomerate NBC did. Chevron, Exxon. Yeah. They couldn't actually access the sites until they had all the training, and that included competency on each site. Because like you say, sometimes they're accessing the site middle of the night. You don't have people to watch them or remote sites. Yeah. Definitely record that and check that competency and training. And plug for check-in there means a containment as well. Some of that has changed in the past few years. Many of the trucking companies have upgraded their trucks, but imagine Northern BC, Northern Alberta, who knows?
Maureen: So, I will say, Angela, I love the smart chart. I actually remember in the beginning it's grown quite a bit. So, that's really awesome to see it's got kind of all the necessary information that you need.
Angela: I'm glad to hear that because Mike thinks I shouldn't talk about a form. He's had feedback that it's too cluttered. I'm like, "If it's on SDS, you know, and that's why people don't read long-winded SDSs." Yeah. There's a lot of information to display.
Maureen: There is, but I mean it's everything that they ask for, that the drivers ask for, right? And I like the idea of putting it in the load box. You know, we've toyed around with making stickers. So, this is actually probably a more inexpensive way to do that.
Angela: Yeah. Yeah. Yeah.
Maureen: So, that's awesome.
Angela: Good. Thanks. And we were just presenting to American company last week and I brought it up and it was all TDG and I'm like, "Oh, I guess I need to create a DOT version for them." But yeah. And that's what they were asking. "Do you have those numbers, that emergency numbers on hand?" I'm like, "Yeah. Certainly." And like I said, the special provisions, right Henry? Most people don't even go to that part. That's schedule 2. And it's so sad because we get hung up on those provisions. The ERAP was one of the special provisions and things like that, reporting different quantities.
Henry: Yeah. I guess the regulatory piece is that's the hardest piece for companies to anybody that's doing in-house training, like doing their own in-house training for general awareness. That regulatory piece is probably the hardest piece of upkeep for any company because of the constant change in regulations. Whereas you're better off to have like your Chemscape program or any...you know, if you're using any other off-the-shelf type, what used to be just the TDG online type courses will offer you that comfort that those are usually being maintained by Chemscape and the other organizations putting it out there because that can become quite administrative from most companies perspectives. Good job, Angela. You can take over my position at Cap and Gcap soon.
Angela: No, no. We're different. Henry and I are different. Henry brings a whole other skill set to the table.
Henry: I just remind them in Ottawa which province I come from so that they don't think I belong on that side of the country.
Angela: Yeah. Yeah. I tried, didn't fit me either. Yeah. No. These are our products, you email me because there's no way you should be putting 3494 if you don't have to, if you're not Shell.
Henry: Well, hopefully, Angela. Hopefully, I don't think it'll happen this year. But, you know, 3494 SP. Well, SP 106 is already coming out of the...is being repealed. And then we're working hard to take 3494 out, but it seems to be the U.S. uses it a fair bit, so...
Angela: Fair bit, what do you mean?
Henry: That's what Transport Canada's telling us, and that's one of their...
Angela: They just say that.
Henry: I know, I know. I always say, "Show me the data, show me the proof." They're waiting for it.
Angela: Yeah, no. So many. We have a laundry list of things we've asked for that they're like, "Hmm, government."
Henry: We're getting there, slowly but surely.
Angela: Yeah. They're just...yeah. We've watched the change of guard so many times. We keep educating them, the next layer of government officials. But good. They seem to be distracted lately. Good. Good. I'll let you guys go. Thanks for tuning in. We're happy to get the word out.
Objectives for the new national training standard include:
- Clarify the requirements for TDG training
- Provide clear and consistent guidelines for training in the TDGR: General awareness and function-specific training and assessment
- Won’t replace current training that is compliant
- Better align with international codes
- Focused more on outcome-based education to help develop skills to augment knowledge
What Can you Expect in the New Amended Training Requirements of Part 6?
Current Part 6
Amended Part 6
Persons must be adequately trained for their TDG tasks
Persons must be competent for their TDG tasks (requirements for competency outlined in the standard)
Certificates to perform tasks
Training certificate required for TDG tasks or under the supervision of someone who is adequately trained and holds a certificate
Certificate of competency required for TDG tasks or under the supervision of someone who is adequately trained and holds a certificate
Aspects of training indicated on certificate of training
Both types of training (general and function-specific) indicated on certificate of competency
Foreign carriers’ certificates are equivalent to training certificate
Foreign carriers’ certificates are equivalent to certificate of competency
Record of training
Requirement to have a record of training for each employee
Clarity on what the record of training must contain (outlined in the standard)
What is the Timeline for Implementation of the New Part 6 Standards?
Beginning in Fall 2022 there will be a transition phase where the old and new part 6 will be accepted; this means companies have 12 months to start developing a new Competency Certificate. To get ready for this change organizations should begin reviewing their training materials, developing task lists, performance criteria, and assessment tools. Competency Certificates can be issued starting in Fall 2023. By Fall 2025, only Competency Certificates will be accepted as proof of TDG training.
October 2022-October 2023
- Old + New Part 6
- Training + Competency
- Certificate Update training material
- Develop task lists, performance criteria, assessment tools.
- New Part 6
- Competency Certificate
- New Competency Certificates issued
- New Part 6
- Competency Certificate
- Valid training certificates or competency certificates accepted
- New Part 6
- Competency Certificate
- Only certificates of competency accepted
How will enforcement of TDGR Part 6 change?
Enforcement of TDGR Part 6 will be done by TDG Inspectors who will:
- Review a person’s certificate of competency to ensure that all the information required in the amended regulations is present.
- Review training records to ensure that all necessary documents are present in accordance with the standard.
- Verify that tasks being performed by the employee are contained in the employee's tasks description and that the employee has received training corresponding to those tasks.
- Identify if the employee who received training and an assessment was supervised by someone who is qualified to provide training and assessment.
What do I need to do now about my TDG Training?
- Current TDG certificates are good until their expiration date.
- Get your TDG certificates updated before October 2022 for 3 years of compliance
- Chemscape will have their TDG course updated for the competency-based General Awareness in Fall 2022
- You’ll will have a year from October 2022 to plan for the function-specific training and assessment component; Chemscape will provide more details on how we can help you with that too.
Learn more about Chemscape’s chemical management solutions for TDG Act Compliance today.