Transportation of Hazardous Materials Between the US and Canada

HazMat Employee Training, PHMSA HazMat Transportation Regulations

Transportation of Hazardous Materials Between the US and Canada

Daniel Stoehr
November 17, 2012

Persons responsible for the safe transportation of hazardous materials within the U.S., known as HazMat Employees, must receive the training required by the US DOT at 49 CFR 172, Subpart H.  If you only ship hazardous materials domestically, by highway or rail, then this is the only training necessary.

The transportation of HazMat in Canada – known there as dangerous goods – is subject to the regulations of Transport Canada:  The Canadian Transportation of Dangerous Goods Regulations.  Transport Canada has similar training requirements to those of the US DOT for all persons involved in the handling, offering for transport and/or transporting of dangerous goods.  With a few exceptions for differences between the two country’s regulations (see below); both the US DOT @ 171.12 and Transport Canada generally accept compliance with the other’s regulations for transport by highway or rail between the two countries.

This acceptance extends to the allowance of training completed per the regulations of one country (either the US or Canada) to meet the training requirements of the other for the transportation of HazMat/dangerous goods by highway or rail.  In other words, HazMat Employees trained and tested per the requirements of the US DOT may handle, offer for transport, or transport a HazMat/dangerous good into, from, and/or through Canada by highway or rail.  Conversely, a person trained according to the requirements of Transport Canada’s regulations may handle, offer for transport, or transport a HazMat/dangerous good into, from, and/or through the US by highway or rail.  This guidance document from Transport Canada explains their side of this agreement (RDIMS #5907129, June 2010).

Regardless of the understanding between the two countries (limited only to shipments by highway or rail), as the shipper of a hazardous material/dangerous good, it is your responsibility to ensure your compliance with the regulations of the respective national agency.  Below are a few situations where compliance with one nation’s regulations will not suffice for the requirements of the other:

  • A hazardous material/dangerous good forbidden by one country but not by the other.
  • A hazardous material/dangerous good regulated by one country but not by the other.
  • The hazardous material/dangerous good is transported under an exception to the regulations recognized by one country but not the other.
  • Other differences in the regulations.  Example:  The Class 9 placard is required to be used in Canada if applicable, but is not required to be used in the US under any circumstances.

Also please note that an agreement of accepting compliance with another country’s regulations for transportation within another does not exist between the US and Mexico.

Determination of compliance with the regulations, both domestic and international, is your responsibility as the shipper of a hazardous material/dangerous good.  As a HazMat Employer you must also ensure your HazMat Employees are properly trained.  My training will not only meet the regulatory requirements, but it will give you the tools you need to ensure compliance with the regulations, no matter the destination of your hazardous materials.