Transport Canada requires shippers to account for all quantities of propane product in required shipping documents, even if it means estimating the amount of product left in empty cylinders that have been picked up.  

As outlined in the Transportation of Dangerous Goods Regulations, Part 3, shippers must carry and update diminishing balance documents during multiple deliveries. The information must include the amount of product AND the number of containers present in the vehicle. The regulations state: 

3.5 (1)(d)  for each shipping name, the quantity of dangerous goods and the unit of measure used to express the quantity which, on a shipping document prepared in Canada, must be a unit of measure included in the International System of Units (SI) or a unit of measure acceptable for use under the SI system” 

(5) If the quantity of dangerous goods required on a shipping document under paragraph (1)(d) or the number of small means of containment required under paragraph (1)(e) changes during transport, the carrier must show those changes on the shipping document or on a document attached to the shipping document. 

Issues can arise when a shipper is delivering filled cylinders and picking up empties. As a cylinder is a sealed container, it is difficult to ascertain how much product is left. A shipper has two choices to meet the requirement of recording the quantity of dangerous goods when transporting multiple containers: estimate the quantity remaining in an “empty container” or mark the container as empty but record the product quantity as if the container is full.  While it is understood that recording an empty container as full on the balance sheet is misrepresenting the amount of product on board, TC would rather have the product amount overestimated than not accounted for at all. 

To conduct repairs to any tank, the facility must be an authorized repair facility registered with Transport Canada. Understand what constitutes a repair on highway and portable tanks, TC reporting requirements, and the length of time required to keep a copy of your report.

As per Clause 3.2, CS B620:20, “a repair constitutes returning a tank to its original design by welding on the tank wall or pipeline, on protective devices, on structural components, and on any part that contains lading”. 

Repairs do not include:  

• changes to vehicle equipment, such as lights, steering and brake systems, and suspension;  
• changes to fender attachments, lighting brackets, and ladder brackets; 
• replacement of components, such as valves, vents, or fittings; 
• replacement of an attachment by welding to a mounting pad; and 
• repairs to a nurse tank chassis.  

Repair reports have different requirements than inspection/test reports. The repair report includes information on the repair facility, details about the repair facility, details about the repair and it identified the welding procedure that was used. The repair facility must keep a copy for 20 years (Clause 7.5.10, CSA B620:20). 

Note that procedures and welders must be qualified for the weld in accordance with ASME PBVC Section (Clause 4.4, CSA B620:20).   

For more information, take the TC quiz. 

A CPA member was recently flagged for non-compliance on their shipping documents due to the ‘ES’ missing from “Liquified Petroleum GasES”  

 As per the inspector’s comments: 

On the pre-printed forms, the dangerous goods information is in the upper right corner. The proper shipping name, per Schedule 1 of the TDG Regulations, is “Liquefied Petroleum GasES”, (capitals emphasizing what is missing). This is very minor, but the regulations require the shipping name to exactly match Schedule 1. Please ensure future documents are compliant with the TDGR (ie. correct them manually or if you prefer, use new documents or pre-print a sticker with compliant information to cover the error).   

To ensure you are compliant, please confirm all your shipping labels include the proper wording.  

Following an evaluation of the Contraventions Act Program in 2021 assessing activities undertaken by Justice Canada between 2016-2017 and 2019-2020, it was recommended that federal departments and agencies be engaged in a systemic review of fine levels to ensure that the Contraventions Act is achieving its intended impact on those who commit offences designated as contraventions. 

Justice Canada agreed with the recommendation and advised that Transport Canada and all departments that have offences designated as contraventions, increase their existing fine amounts. Therefore, in 2023, the Department of Justice and the Transportation of Dangerous Goods Directorate worked in close collaboration to review existing fine amounts under Schedule XV of the Contraventions Regulations. As existing fine amounts had not been updated since the offences were first included in the Contraventions Regulations in 2007, it was recommended to update the fines to a more appropriate level to maintain their deterrent effect. This work led to the publication of the Regulations Amending the Contraventions Regulations (Transportation of Dangerous Goods Act, 1992) in the Canada Gazette, Part II (CGII) on December 20, 2023. 

These amendments come into force on the day upon which they are published in the CGII. 

You are encouraged to read the Regulatory Impact Analysis Statement (RIAS) that follows the regulatory text. The RIAS provides a plain language explanation of why the changes were needed and a description of the main changes that were made. It provides Justice Canada’s rationale for making the changes and the expected costs and benefits that will result from the proposal.  

The updated fee schedules for the 2024-2025 term at Technical Safety BC are now operational and can be viewed on the TSBC website.  

The fees are intended to recover costs related to safety oversight, including educational programs; public safety campaigns such as recalls, hazard awareness, and safety alerts; investigating incidents; assessing equipment and systems; and finding ways to innovate and improve programs and products for our safety partners and clients.  

As of January 1, 2024, clients are also required to use cheque or EFT to pay for invoices valued above $5,000. If you have any questions about the fee schedule or require further information, please contact the TSBC engagement team.