Clearing up the language and introducing uniformity

by Blair Gough

There are some significant (albeit technical) changes proposed for federal dangerous goods legislation that will soon have a significant impact on a segment of our industry.

Known as the Clear Language Proposals, they were published in the Canada Gazette on Aug. 7, after five formal drafts of the regulatory changes.

While the comment period is usually three months from the publication date, the rules probably won’t take effect until the fall of 2000 or early 2001, at the earliest.

Here is a synopsis of the changes:

1. Consumer Commodities and Limited Quantities will be removed from the regulations and replaced with Low Threat Consignment (LTC). In Schedule 1 Explosives, and Schedule 2, Classes 2 through 9, a column has been added for the LTC items, indicating the amounts.

Section 1.5 (1) of the LTC section explains how to verify whether a dangerous good to be transported meets the LTC criteria. Subsections 2 and 3 explain additional requirements for transporting LTC in consignments under and over 30 kilograms and transporting quantities greater than 500 kg from one consignor to one destination. Some items that are now classed as dangerous goods will not be regulated at all.

2. The classification of dangerous goods under the Clear Language Proposals is now located in Part 2 of the regulations. Some classifications that are present in the existing regulations will be removed. Dangerous goods that were in these classes will now appear in other classes. (For example, ammonia, anhydrous UN 1005, formerly in Class 2.4, will now be in Class 2.2 (8). Although some classifications will change, the goods will still be regulated.

3. The section concerning documentation will now be Part 3 in the Clear Language Proposals. The information required on the shipping document and the location where it has to be kept during transportation has changed very little. But the requirements for completing a shipping document have been made far easier to understand, and are therefore easier to meet.

4. The greatest number of proposed changes will occur in Part 4, which is associated with dangerous goods safety marks.

The consignor will be required to label both the primary and the first subsidiary class for shipments of dangerous goods in small means of containment. That is to say, consignors will be required to use more labels to identify dangerous goods than are presently required.

5. With respect to training, the major change will involve the information that has to be shown on training certificates. There will also be a requirement for employers to provide inspectors with a copy of the record of training and a description of the training materials that were used.

Carriers should start preparing for the changes by familiarizing themselves with the proposals. They are available on the Internet.

It’s dry material – boring stuff, really – but it is important.

In the same vein, let’s flip to a new Ontario Ministry of Transportation (MTO) policy issued to holders of the ministry’s Enforcement Procedures Manual which, itself, can serve as an effective remedy for insomnia.

The particular policy in question pertains to “Pushrod Marking Devices” and is dated Nov. 29, 1999. It serves as Item EP-9-37 of the Manual, and reads as follows: “Issue: To establish a uniform method of marking pushrods for accurate and professional-looking brake measurement.

“Background: Officers in some cases are not using a straight sharp marking tool when scribing pushrods for brake measurement. These marking tools can consist of soap, stone, chalk, lumber crayon or any other type of marker that is legible. In some cases, the mark is a considerable distance from the chamber face. In other cases, the mark is not straight. There is also a misconception that we are measuring from the wrong side of a thick mark, putting the operator at a disadvantage.

“Direction: To ensure the integrity and accuracy of our inspections, each officer will sharpen their marking device to a fine point which will produce a thin line on the pushrod, parallel and flush with the chamber face … This will allow for a more uniform and accurate inspection.”

The policy brings to mind a few comments. I am befuddled by the point about the industry’s “misconception”. Might I suggest that, if some officers have been using their tool in an unacceptable fashion, there might be reasonable grounds for such misconception?

And what the hell is a lumber crayon? I’ve hung around trucks and hardware stores for a good chunk of my life, and have bought a whack of lumber, but I am not familiar with the term. Are officers’ tools issued by the MTO? Are they compliant with federal weights and measures regulations ?

I mean, after all, we are talking about a commercial measurement.

I guess that, in reading the policy, you have to ask yourself an important question: does the officer have a thin or thick tool? It appears to be important.

– Blair Gough is a consultant to the trucking industry and can be reached at 905-689-2727.

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