Explosive risk

Incident: July 2013 – Lac-Mégantic in Quebec’s Eastern Townships was the site of one of Canada’s worst rail disasters, when an unattended freight train rolled down a hill and derailed downtown, resulting in the fire and explosion of multiple tank cars loaded with six million liters of light crude. Forty-seven people died in the explosion and fire, and more than 30 buildings in the town’s centre were destroyed in the one-kilometer blast radius.

The size and frequency of such events show that compared to other freight, shipments of explosives, gases, flammable liquids, flammable solids, oxidizing substances, poisonous and infectious substances, nuclear materials, corrosives and other products can pose significant public safety and environmental risks. The consequences of accidents or spills can be severe, particularly if shipments travel through populated centres or fragile ecosystems. That fact has sparked governments at all levels in Canada to enact stricter rules and regulations on the handling, storage and transportation of dangerous goods.

Transport Canada’s Transportation of Dangerous Goods (TDG) Act, stipulates that federal inspectors (and their designates) can inspect virtually anything to do with transportation of goods in Canada. “The Act is updated regularly to keep in line with the ever-changing society we live in and the newly created dangerous goods are being transported on our highways, railways, waterways and airways,” says Kerri Wirachowsky, who leads the Carrier Enforcement Program with the Ontario Ministry of Transportation (MTO). “But it’s also very difficult to put the Dangerous Goods Act in simple terms, once you get into all the requirements.” Essentially, if commercial vehicle drivers carry more than five cylinder propane or flammable substances cylinders gas, they should contact the MTO or Transport Canada with their specifics to determine their requirements. And once they start carrying mixed loads, all the situations change.

Sgt. Hank Dubee, an enforcement officer with the Ontario Ministry of Transportation, agrees that working with dangerous goods is an increasingly complex business. “There was a time when there were no regulations in place,” he says from his office in Thornton, Ont., north of Toronto. “But a train derailment which caused a mass explosion and an evacuation of over 200,000 people in Mississauga back in 1979 of styrene, toluene, propane, caustic soda and chlorine called for the creation of the TDG regulations. First responders at the time had no idea how to deal with an incident of dangerous goods. Thanks to the regulation, they now stagger railway cars transporting dangerous goods, carry shipping documents, have training and safety marks.”

Regulations on the movement of dangerous goods can vary by jurisdiction across the country but generally require accurate classification, appropriate means of containment, and correct marking, labeling and documentation. In Canada, federal legislation currently prohibits the transportation of certain high-risk dangerous goods unless an Emergency Response Assistance Plan (ERAP) has been submitted and approved. The plan outlines how specialized emergency response personnel will react to an accident and their overall capacity to respond. As dangerous goods are likely to remain a significant portion of the overall freight moved across the country, there is a recognized need to further enhance the monitoring of these shipments. For instance, in June of 2014 Transport Canada amended the TDG regulations to clarify the criteria for displaying safety marks: now safety marks are required to be displayed on trucks, rail cars and bulk containers used to transport dangerous goods, identifying the type of goods and the nature of the
risk posed.

What does all this mean to rental operators? “First, it’s a myth that dangerous goods are exempt when empty,” cautions Dubee. “Dangerous goods are just as dangerous empty as when full. The only time they are exempt (from TDG regulations) is if they have been cleaned and purged so there is no evidence of dangerous goods present or they are new tanks never filled.” In Ontario, the penalties for breaking the rules range from zero to $50,000 for a first offence and up to $100,000 for a second offence or six months in prison. MTO constables who stop and find violations may summon the offender to court for a justice of the peace to apply the suitable fine or they may issue a ticket which is usually $490 each with three commercial vehicle operators’ registration (CVOR) points attached (licence suspensions are issued upon receiving four, six, nine or 15 demerit points depending upon the class of licence). Usually, both the driver and carrier owner/operator are ticketed.

Asked what red flags prompt MTO inspections and police traffic stops, Dubee replies that, “We typically do random checks, however the main triggers are faded or poor condition placards, and insecure loads. It’s also common that most charges written to a company and drivers are those who haven’t taken adequate dangerous goods training.” He urges taking a course from a qualified instructor who can answer questions specific to the dangerous goods you are transporting. “I believe training is the most important part so that you know about how to transport the goods safely and in compliance.”

One of Canada`s top providers of in-depth, hands-on education in the proper handling of propane is the Propane Training Institute PTI), a division of the Canadian Propane Association (CPA), offering programs available in English and French to assist the liquid propane gas industry and customers in meeting their LPG technical training needs. “We`re not just trainers, we’re also stakeholders in the propane industry,” states Gerald Thompson, PTI’s Calgary-based senior director of learning and development. “Compliance is of paramount importance when it comes to
propane safety.”

According to Thompson, who enjoys the growing relationship his organization is nurturing with its rental company members and customers, PTI’s Transportation of Dangerous Goods – Propane /LPG Specific course has been newly updated with input from propane industry members as well as Transport Canada. “If you make the grade,” he notes, “you will receive a wallet certificate good for three years.” PTI courses are designed to provide basic instruction on the safe handling of propane and propane-powered equipment and satisfy federal and provincial training requirements. Most PTI courses are designed to be delivered in one day or less.  Some courses are also available with self-study materials to reduce the amount of in-class time for the student. The final written exam take less than one hour to complete.

Although there is no set check list for rental operators to follow when transporting dangerous goods on Ontario highways, Dubee suggests that a good general rule of thumb includes: ensuring load security, using only trained employees to handle dangerous goods, making certain shipments are correctly documented, and that safety marks (labels and placards) are clearly visible. “These are necessary because everyone wants to protect the environment and persons on the highway,” he says.

With over 400 members, the Canadian Propane Association (CPA) is the national voice of the Canadian propane industry, a multi-billion dollar industry that impacts the livelihood of tens of thousands of Canadians.

The Propane Training Institute (PTI) is the training division of the Canadian Propane Association, and is dedicated to offering state of the art training programs to assist the LP gas industry and customers in meeting their LP gas technical training needs. PTI courses are designed to provide basic instruction on the safe handling of propane and propane-powered equipment and satisfy federal and provincial training requirements.

The Propane Training Institute (PTI) currently has over 30 propane related course offerings, covering over 150 learning objectives.  PTI courses are designed to address specific job-related topics so that employees can take the propane training that is appropriate for them.  Most PTI courses are designed to be delivered in one day or less. Some courses are also available with self-study materials to reduce the amount of in-class time for the student reducing time away from work.  

PTI’s recently updated its 100-03 course. Transportation of Dangerous Goods – Propane/LPG Specific is designed for individuals who offer propane for transport, who transport propane or direct others to either transport or offer for transport propane and other LPG’s that fall under the UN Dangerous Goods number 1075 or 1978. The student may attend an instructor-led training course or, upon the direction of a PTI certified trainer, study the course manual and attend a specialized review session and demonstration of correct procedures by a PTI certified trainer. In either case, the certification requirements must be achieved in order to successfully complete the course.

Regulatory authorities recognize PTI courses across Canada and PTI certifies over 30,000 students annually on the safe handling of propane. A full list of PTI training courses can be found on the Canadian Propane Association website. 

Read the label
The following information is now required on a shipping document for the transportation of propane/Liquified Petroleum Gas (LPG), also referred to as simply propane or butane.

• The name and address of the place of business in Canada of the consignor
• The date the shipping document or an electronic copy of it was prepared or was first given to a carrier
• The description of each of the dangerous goods, in the following order: the UN number, the shipping name and the description of the substance immediately after the shipping name unless it is already part of it
• For dangerous goods that are subject to special provision 16, the dangerous substance that predominantly contributes to the hazard or hazards posed by the dangerous goods
• For a liquefied petroleum gas that has not been odorized, the words “not odorized” or “not odorized” or the equivalent in French
• The primary class, which may be shown as a number only or “class”  
• The quantity of propane/LPG and the unit of measure used to express the quantity
• For propane/LPG in one or more small means of containment that require a label to be displayed on them in accordance with Part 4 of the TDG Regulations, the number of small means of containment for each shipping name
• The words “24-hour number” or “Numéro 24 heures,” or an abbreviation of these words, followed by a telephone number, including the area code, at which the consignor can be reached immediately for technical information about the propane/LPG in transport, without breaking the telephone connection made by the caller.