Rules for transporting Covid-19 test samples extended

Transport Canada has issued a temporary certificate that governs the handling and transporting of Covid-19 test samples heading to laboratories for analysis.

The certificate, issued May 30, has been introduced because since testing is still ongoing at non-traditional screening sites it can be “challenging to ensure that everyone in the transportation chain has received the related training required under the Transportation of Dangerous Goods Act, 1992.

The temporary certificate expires on May 31, 2023, unless its canceled by Transport Canada, and is essentially a reincarnation of the same temporary certificate that was issued Dec. 14, 2020, and had indicated it would not be renewed past Dec. 31, 2021.

Interested stakeholders are once again able to avail themselves of the special measures when handling and transporting Covid-19 test samples in a way that does not comply with TDG Act rules relating to documentation, dangerous goods safety marks, means of containment, training, reporting requirements, and air.

The Covid-19 test samples must be placed in P650 packaging or an alternative that meets a number of detailed conditions outlined in the certificate known as TU 0764 (Ren. 2). The outer packaging of the test samples must also be marked as indicated by the certificate.

One exception to these marking requirements allows the names of the consignor and consignee to be identified on a transport document rather than the outer packaging itself. But in such a case, the transportation document must include some additional information.

Finally, when test samples are being transported by air, air carrier employees who are involved in handling or transportation must be trained as indicated, and must not transport test samples in carry-on baggage, checked baggage or on their person.

All other requirements of the TDG Act and the TDG Regulations continue to apply to test samples.

Handling and transporting dangerous goods is still fraught with peril, not only because of the inherent dangerous nature of the goods themselves, but also due to the extremely complex regulatory regime that with which stakeholders must always comply.

Anyone needing help interpreting TU 0764 (Ren. 2), the TDG Act, or the TDG Regulations whether they respect Covid-19 test samples or other dangerous goods — would be well-advised to consult a qualified transportation lawyer for advice.

James Manson is associate counsel in Miller Thomson’s Transportation & Logistics Group. He can be reached at jmanson@millerthomson.com. This article is provided for information purposes only and does not constitute a solicitor-client relationship or legal advice.


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