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LEHDER News

LEHDER Training Updates & Mark Roehler Obtains Certified Online Training Professional Designation

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Mark Roehler Receives Certified Online Training Professional (COTP) DesignationLEHDER is pleased to announce Principal Mark Roehler has obtained the Certified Online Training Professional designation from the International Council for Certified Online Training Professionals.  Congratulations, Mark!

LEHDER's O. Reg. 347 Subject Waste Webinar Series is currently underway with only 3 sessions left.  To participate in any of the remaining sessions, links to the registration module are provided below.  Please note, if you are interested in registering for the entire series yet have missed a module, recordings of the missed sessions and applicable resource materials will be provided upon registration.  The remaining sessions are provided below:

200-WB-05 Movement Documents for Subject Waste Shipments - February 28, 2017

200-WB-06 Subject Waste Full Webinar Series

The full listing of LEHDER webinars currently available can be found on the LEHDER Webinar page.

LEHDER Spring Classroom Sessions

The Ontario and Alberta spring classroom sessions are approaching - the Ontario sessions occur during March and early April; the Alberta sessions are taking place in Edmonton, AB, between April 18 and 21.  Please note - register early!  Courses can be cancelled two weeks in advance of course date if there is insufficient registration volumes.

To view the upcoming courses available, please select the appropriate location below:

Point Edward, Ontario

Edmonton, Alberta

For more information in regards to LEHDER's training capabilities, please contact Mark Roehler.

LEHDER 2017 Regulatory Reporting and Traning Calendars Available

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LEHDER 2016 CalendarsLEHDER is pleased to provide our clients with a Regulatory Reporting Calendar for important dates to remember for Ontario Reporting requirements.

Also available are LEHDER's 2017 in-class training calendars for both Alberta and Ontario. Additional information in regards to LEHDER's regulatory training capabilities are provided on the Regulatory Training page.

 Please feel free to download the documents from the links below.

LEHDER's regulatory training sessions occur in the spring and fall.  Additionally, LEHDER hosts webinars to provide updates to regulatory changes and updates.  To view the courses available in your region, please select the applicable category below.

For more information on LEHDER's regulatory training services, please contact Mark Roehler.

When Federal & Provincial Rules Conflict - The Case of Waste Manifests Vs. TDG

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ON Waste Manifest Requirements Vs. the TDGRThe recent amendments to the federal Transportation of Dangerous Goods Regulation (TDGR) have created challenges for waste managers/shippers due to inconsistencies between the federal/provincial waste manifest form.

In order for a waste manifest to qualify as a TDG shipping document, the information must be provided in the order prescribed in TDGR s.3.5 - UN No., Shipping Name, Class, Packing Group.  However, the current waste manifest requires the information be entered as Prov. Code, Shipping Name, Class, UN No., Packing Group, Quantity Shipped, Units, Packaging (No./Code), Physical State. 

Earlier this year, the Canadian standard Movement Document/Manifest (adopted by Canadian provinces and territories for use in waste shipments across Canada) was modified to include the required consignor certification statement and signature which was required by TDGR s. 3.6.1 as of July 15, 2015.  For more information, please refer to the June 17, 2015 post - Documentation Requirements for Dangerous Goods Including Wastes.

The provincial regulatory bodies must wait on Environment Canada to modify the Movement Document/Manifest.  Completion of the manifest must meet provincial waste requirements as well as Federal TDG regulations.

In Ontario, the MOECC does not have any plans currently to revise the manifest document to account for these discrepancies.  Dr. Dianne Saxe, one of Canada's leading environmental lawyers, has written a blog post in relation to some of the steps you can take to handle these issues at your facility.  To view that post, please click here.

Note:  While Dr. Saxe's post provides a general guide to this subject matter, it is recommended you seek specific advice in regards to your facility requirements.

In Alberta, Alberta Environment and Parks (AEP) is allowing the manifest form to be completed by proceeding the UN Number before the shipping name in the shipping name column of the manifest.  AEP has also updated their manifest attachment sheet to be in compliance with TDGR.  For more information on this, please refer to the AEP's Hazardous Waste Manifest System.

For more information about waste manifests and the TDGR, please contact Mark Roehler.

Documentation Requirements for Dangerous Goods Including Wastes

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The Canada Gazette Part II amendment (SOR/2014-306), published December 31, 2014 which included a 6 month transition period, called for modification of TDG Part 3.5(1)(c) which requires that dangerous goods descriptions must be in the order of Columns 1, 2, 3 and 4 of TDG Regulations, Schedule 1 or UN number, Shipping Name, Class (Subsidiary Class) and Packing Group.

TDG Part 3.6.1 states that as of July 15, 2015, a Consignor must state their name and make a Consignor’s Certification on any shipping document containing dangerous goods.  This certification can be authorized by 49 CFR, ICAO Technical Instructions, IMDG Code, or UN Recommendations.  Alternatively, you would use the TDG certification language which is as follows:

“I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, are properly classified and packaged, have dangerous goods safety marks properly applied or displayed on them, and are in all respects in proper condition for transport according to the Transportation of Dangerous Goods Regulations.”

Documentation Requirements for Dangerous Goods Including WastesThe Canadian standard Movement Document/Manifest adopted by Canadian provinces and territories for use in waste shipments across Canada has been recently updated to include the new certification requirements of a Consignor.  You will note that this certification requirement states that the correct classification under TDG is used (note Part 2.2.1 above).  However, the manifest description for dangerous goods is not in compliance with Part 3.5(1)(c) of TDG as the description is still shown as Shipping Name, Class, UN No. and Packing Group.
 
If the Movement Document/Manifest is not modified and adopted by provincial/territorial authorities by June 30, 2015, with the correct TDG description order, which is not likely to occur, then all dangerous goods waste shipped on a Movement Document/Manifest must be accompanied by a bill of lading with the correct TDG description.

For more detailed information in regards to waste handling, please contact Mark Roehler.


Classification of Dangerous Goods Including Waste Streams

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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.