June 12, 2023 | Circular No. 11533

Dear Member,

The Federation recently participated in several forums with Transport Canada related to the movement of dangerous goods; including National CMAC (Canada Marine Advisory Council), TDG (Transportation of Dangerous Good) General Policy Advisory Council, and the Federation’s Annual Cargo and Ship Inspection meeting. Below are updates related to the transportation of dangerous goods in the marine sector.

Changes to Hazardous Goods Training Requirements – Transport Canada is changing the regulatory training requirements to include a competency-based approach to training under new regulations currently in Canada Gazette Part I. The Federation raised an issue with the linkage between the IMDG (International Maritime Dangerous Goods) Training Requirements and the new Canadian requirements, where the international requirements were not included into the Canadian regulations. While the obligation for members to train staff in accordance with the IMDG Code does not change, it does mean that other stakeholders in Canada involved in international marine shipments may not be adequately trained in IMDG requirements. Transport Canada is currently reviewing all comments with a view to publishing in Canada Gazette Part II in the Fall 2023 and will be allowing for a 12-month transition period.

Registration Database (CID) – Several reports from the Auditor General of Canada dating back to 2011 emphasized that Transport Canada is unable to identify the dangerous goods regulated community. Thus, the TDG directorate is implementing a DG registry in which any entity involved in handling, offering for transport, transporting or importing dangerous goods in Canada will have to register under this new registration database program. The goal of this registration database is for TDG regulated entities, and their sites involved in dangerous goods activity across Canada to register their DG activities in a common database. The Federation is seeking clarification if marine carriers need to register under this program as no hazardous goods are physically handled at their sites/offices, however, marine carriers do “offer” containers with hazardous goods to railways and trucking companies for inland transport.  The registration requirement is included in Bill C-33, and expected to be in Canada Gazette Part II by the Fall 2023 and expect Royal Assent by Spring 2024.

Marine Container Inspection Program – In collaboration between the TDG and MSS departments, export DG container inspection program continues in Montreal, Halifax and Vancouver.  As part of Canada’s international commitment, TC inspected 711 containers across the country in 2022, where 225 were noted with deficiencies or a 31% failure rate (25% failure rate in 2021).  Transport Canada have recently advised they will be increasing the number of export DG containers being inspected to about 400 for each port (Montreal, Halifax and Vancouver) and monitoring other container ports.  As a reference, in 2022 the inspections per port were; Halifax (513), Montreal (110) and Vancouver (88).

Enforcement of Non-Compliance for Undeclared/Mis-declared Dangerous Goods – The Federation raised the issue of stricter enforcement for non-compliance with DG requirements. Noting that in the absence of Transport Canada issuing AMPS for non-compliance, marine carriers have implemented their own surcharges/fines. Transport Canada should not be transferring the burden of enforcement to marine carriers and as such, the Federation has requested Transport Canada to review their enforcement and compliance policies.

Dangerous Goods Training Program – The Federation’s Dangerous Goods Training Program continues as a service well used by members. In 2022, we issued 64 training certificates to both members and non-members. In May, we offered the course for the second time this year with 23 participants (total 46 certificates issued in 2023).  We plan to offer the virtual training course again early in the fall for members that have a demand for IMDG.

Ammonium Nitrate Best Practices – Following the 2020 explosion in Beirut, Transport Canada conducted a regulatory review both nationally and internationally to ensure that Canada had the appropriate regulatory framework in place to prevent such an incident. The final report confirmed  that the regulatory framework in Canada is a shared responsibility between Federal, provincial and municipal levels of government and concluded the framework as being robust and supported by industry’s comprehensive best practices. Transport Canada will next look to enhance the regulatory clarity and maintain international harmonization while continuing to raise awareness.

Please do not hesitate to contact the undersigned for any questions or comments.


Chad Allen
Director, Marine Operations