TDG Part 2.2.1 states that a Consignor who allows a carrier to transport dangerous goods or imports dangerous goods is responsible for proof of classification for the dangerous goods information used on the shipping document. This proof must be maintained for five (5) years and must be in a document that explains classification (i.e. test report, lab report, explanatory document) and include the following information:
Date on which dangerous goods were classified;
If applicable, the technical name of the dangerous goods;
The classification of the dangerous goods; and
If applicable, the classification method used under this Part or under Chapter 2 of the UN Recommendations.
For UN1267 (Petroleum Crude Oil) and UN1268 (Petroleum Distillates N.O.S.), special provision 92 states that proof of classification must be done on the basis of sampling and analysis. The document used to explain the sampling method must include the following information:
- The scope of the method;
- The sampling apparatus;
- The sampling procedures;
- The frequency and conditions of sampling; and
- A description of the quality control management system in place.
It is important to understand that the above applies not only to products but also waste. Any material shipped as a dangerous good, including waste, needs to have proof of classification of the determination of the UN number. If the waste stream is UN1267 or UN1268 then the waste stream must have been sampled and analysed in order to determine the appropriate classification.
For more information, please contact Mark Roehler.