November 8, 2023 | Circular No. 11599

Dear Member,

Transport Canada has announced the launch of new site registration requirements and a new Client Identification Database to reduce risks associated with the transportation of dangerous goods, as per a series of recent amendments to the TDG Regulations.

The database is essentially a new online platform for registering and identifying persons and companies which import, offer for transport, handle or transport dangerous goods in Canada.  Specific information that must be provided in the database includes:

  1. The company’s name, address and province(s) of operation;
  2. The sites (physical addresses) where dangerous goods are imported, offered for transport, handled or transported;
  3. Details regarding the type of dangerous goods involved and the mode by which they are being transported.

With respect to item 2 above, the new regulations define a “site” as a permanent location where dangerous goods are imported, offered for transport, handled or transported and are in the direct possession of a person conducting these activities.  According to the guidance provided by Transport Canada, a site in the marine mode would include locations where dangerous goods are being loaded and unloaded (such as terminals), but not an office, warehouse or vessel.

We are now seeking additional clarification from Transport Canada on the applicability of these new requirements to marine carriers, given that marine carriers don’t handle dangerous goods at their sites/offices (which would appear to exempt them from point 2 above), but they do nevertheless “offer” containers with dangerous goods to railways and trucking companies for inland transport.

Although the new regulations came into effect on October 25, applicable companies will have until next year –  October 25, 2024 – to register in the new database, with enforcement only beginning thereafter.

We  will revert with additional information on the extent to which the new requirements are applicable to Federation members as soon as possible.  In the meantime, the Minister’s press release and supporting documentation related to this issue can be found at this LINK.


Karen Kancens
Vice President