An email query on October 20, 2017:
Hello,
Just read your article “US DOT Exception for Combustible Liquid Hazardous Materials” and it was very helpful to my company.
One question… can this combustible exemption be used when shipping to Canada?
My reply:
I will be able to assist you with this issue. A few questions:
- What is the mode of transport? Air, vessel, highway, or rail?
- What is the flash point? <100 degrees F? 100 – 140 degrees F? >140 degrees F?
- Will the packaging be bulk: cargo tank, portable tank, IBC? Or, non-bulk: 55-gallon drum or smaller?
Thank you and please advise.
Looks like I didn’t move fast enough!:
Daniel,
Thank you so much for your quick response.
In the past half hour, I was able to speak with someone in Canadian “DOT” who was able to help answer all of my questions.
Thanks again for your response but they were able to straighten me out,
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But I’m a curious guy, always wanting to learn more:
Your welcome.
If you don’t mind taking the time, could you please confirm my initial determination (more research was planned) that a form of the U.S. combustible liquid exception is available in Canada if transport is by highway or rail?
Hello Daniel,
This is the response that I received from Transport Canada.
Makes sense to me!
Thanks again,
TEXT OF LETTER FROM TRANSPORT DANGEROUS GOODS (TDG) CANADA FOLLOWS:
Mr. <<>>
Flammable liquids in PG III are not regulated in Canada as a dangerous good if the flash point is above 37.8 C (~100 °F), they are exempt from shipping papers, labels, packaging, training, emergency response planning, by road under 1.33 as follows:
1.33 Class 3, Flammable Liquids: General Exemption
SOR/2008-34
Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks), Part 5 (Means of Containment), Part 6 (Training), Part 7 (Emergency Response Assistance Plan), Part 9 (Road) and Part 10 (Rail) do not apply to the handling, offering for transport or transporting of dangerous goods included in Class 3, Flammable Liquids, on a road vehicle, a railway vehicle or a ship on a domestic voyage if the dangerous goods
(a) have no subsidiary class;
(b) are included in Packing Group III and have a flash point greater than 37.8°C; and
(c) are in one or more small means of containment designed, constructed, filled, closed, secured and maintained so that under normal conditions of transport, including handling, there will be no accidental release of the dangerous goods that could endanger public safety.
In addition Part 9 of the regulations allows for reciprocity with US DOT requirements under 49 CFR to destination from USA to Canada IAW 49 CFR.
So, in short, yes you may ship as stated to destination in Canada.
Regards
D.W. (Dave) Greyeyes
Transport Dangerous Goods Inspector
Prairie and Northern Region – Surface
Transport Canada / Government of Canada
Room 305 101-22nd Street East, Saskatoon, SK., S7K 2L2
David.greyeyes@tc.gc.ca / Tel : 306 975 6246 / Fax: 306 975 4555 / TTY: 1.888.675.6863
TEXT OF LETTER TO TRANSPORT DANGEROUS GOODS (TDG) CANADA FOLLOWS:
Good Morning Sir/Madame,
I have a question about shipping combustible paint to Canada. Our company is located in USA.
The paint that we are shipping to Canada has a flash point of 108 degree F (42 degrees C). From what I understand, this classifies it as a combustible material in Canada.
Here in the US, combustible materials do not need any classification or labelling as they are exempt under US DOT laws.
Can I ship into Canada without labelling/hazardous documentation (same laws as in the US)?
Thanks very much for your time in this matter,
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Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |
Conclusion:
So there you have it, right from our neighbors to the north! The combustible liquid exception found in USDOT/PHMSA regulations is valid in Canada as well.