Canada's Clear Language Rule Takes Effect in 2002

Aug. 23, 2001
Canada's Transport Minister David Collenette has announced the implementation of new "clear language" regulations governing the transportation of hazardous

Canada's Transport Minister David Collenette has announced the implementation of new "clear language" regulations governing the transportation of hazardous materials in Canada. The regulations include requirements for testing, classification, labeling, containment, and documentation.

They are scheduled to take effect August 15, 2002, according to information from Transport Canada.

"This new version of the regulations is presented in clear language and in a more user-friendly format, making them easier to understand," says Collenette. "The amendments also reflect advances in technology, and the increasingly global nature of the transportation industry, by enhancing harmonization and addressing the greater number of trans-border shipments."

The new regulations will replace the previous version, which was enacted in 1985. The new regulations are designed to streamline the process for shipments involving several forms of transport, including trucks, ships, and trains.

Certification of tanks to the B620-87 specification will no longer be permitted, and facilities registered under B620-98 will be authorized to manufacture only TC400-series tanks.

The new regulation introduces a number of changes from the 1987 edition that is currently in force, and closely mirrors US Department of Transportation requirements, according to Kevin Green, Transport Canada senior specialist, tanks engineering services.

Changes include new TC400-series tank specifications, more frequent periodic inspections and tests, revised quality control requirements for registered facilities, and design reviews for pressure and non-pressure highway tanks.

The new TC400-series tank specifications feature improvements in structural integrity, venting devices, and welding control. The non-pressure-vessel highway tanks include tank specifications TC406, TC406 Crude, TC407 with design pressures less than or equal to 15 pounds per square inch (psig), and all TC406, TC407, and TC412 tanks manufactured of fiber reinforced plastics.

The improved structural integrity of these non-pressure highway tanks is achieved in part through adoption of selected portions of the American Society of Mechanical Engineers (ASME) code. Welders, for example, and the procedures they follow must be qualified in accordance with Section IX of the ASME code by a Transport Canada registered facility. Manufacturers must have and adhere to a quality control manual that is very similar to that required by the ASME code, but they are not required to have ASME U-stamp authorization.

The regulation will introduce Design Reviews and the Manufacturer’s Design Identification Number (MDIN). The MDIN is a number issued by a highway tank manufacturer to identify a particular tank design, and to indicate that it has been reviewed for compliance. For non-pressure highway tanks, design reviews are performed by a design engineer registered with Transport Canada. When the design is approved, the manufacturer or final assembler of the tank marks the MDIN on the name plate and certificate of compliance of every tank manufactured to that design.

Here are five steps for manufacturers to follow before constructing non-pressure TC400 highway tanks under B620-98.

1. A manufacturer must register with the TDG Directorate in accordance with B629-98. This could be a new registration, or an upgrade of a currently valid B620-87 registration.

An upgrade from a B620-87 to a B620-98 registration often requires improvements to the facility’s B620 quality control manual to include more complete procedures, documentation samples, and revised inspection and test procedures and reports. Clause Nine and Appendix B of B620-98 describe the registration and quality control requirements. Manufacturers should begin preparation of their B620-98 quality control manual now to avoid the registration rush in 2002.

2. A manufacturer must document and qualify all weld procedures to be used in the construction of the highway tank in accordance with Section IX of the ASME Code. Each welder must then be qualified to the procedures he will perform. Registered facilities may perform their own welder qualification tests, but records will be subject to an audit by Transport Canada.

3. A manufacturer must then prepare a complete design package for the highway tank design and its accessories. The design should include all drawings, calculations, and accessory specifications for the highway tank vehicle as prescribed in CSA B620, including vents, relief devices, bumpers, accident damage protection, piping, etc. The manufacturer must also assign a unique MDIN to the design package. Each document in the package must be marked with this MDIN, or listed on a separate record that is marked with the MDIN.

4. The design package should then be forwarded to a design engineer registered with Transport Canada. The calculations and drawings relating to the design must be reviewed and approved by the design engineer, who will mark them with his or her name, signature, and Transport Canada registration number. The design engineer may be a member of the manufacturer’s staff, or retained specifically for the design preparation review and approval. The requirements for design engineer registration can be found in Clause Nine of B620-98. The TDC Directorate may be contacted at (613) 998-5270 for a list of registered design engineers.

5. When the design engineer has approved the design as complying with B620-98, the manufacturer or final assembler of the tank will mark the MDIN for the design on the name plate and certificate of compliance of every tank manufactured to that design.

A copy of the standard may be obtained by contacting the Canadian Standards Association at (800) 463-6727. Other questions may be addressed to the Transport Dangerous Goods office in each region or by contacting the TDG directorate in Ottawa, Ontario, Canada, at (613) 998-5270.