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The Clear Language TDG Regulations: How do they impact Class 7 shipments?
Trevor Beniston, B.Sc.
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On August 15, 2003 Transport Canada will be implementing the new "Clear Language" Transport of Dangerous Goods Regulations. These regulations represent several years worth of work aimed at updating Canadian dangerous goods regulations to bring them in line with many international standards. In addition, the Canadian Nuclear Safety Commission intends to implement IAEA Safety Standards Series No. T-SR-1 (formerly known as ST-1) in the "Packaging and Transport of Nuclear Substances Regulations". As a result, there is some impact on the way radioactive materials are transported. Luckily, most of the changes are very minor and simply update the regulations currently used without significantly changing how radioactive materials are shipped.
The following paragraphs outline the changes to be found in the new TDG regulations with regards to radioactive material shipments. For further information on these changes, please visit the Transport Canada website or the CNSC website.
1. Permit of Equivalent Level of Safety (part 1.14)
A permit for equivalent level of safety that was issued under section 31 of the original Act before the coming into force of these Regulations is valid until two years after the date on which these Regulations are published in Part II of the Canada Gazette or until the expiry date on the permit, whichever occurs first.
In other words, your current permit is valid until August 15, 2005 or the expiry date on the permit, whichever occurs first.
2. Samples for Laboratory Analysis (part 1.19)
Samples sent for analysis that are reasonably considered dangerous goods are excepted from the regulations if the sample is believed not to contain radioactive material, has a gross mass (sample plus container) of less than 10 kg, and is accompanied with a shipping document that includes the words "Test Sample".
With regards to sealed source leak test kits, nothing changes on how they are shipped since they are not considered dangerous goods. However, shipping samples for NORM analysis must now follow the "Packaging and Transport of Nuclear Substances Regulations".
3. Class 7 Radioactive Materials (part 1.43, 2.37 & 2.39)
These Regulations do not apply to Class 7, Radioactive Materials if the radioactive materials satisfy the conditions for an excepted package as specified by the "Packaging and Transport of Nuclear Substances Regulations" and they are accompanied by a shipping document that includes the Shipping Name and UN number of the radioactive materials.
(Note: There is a direct contradiction in the "Clear Language Regulations" and the "Packaging and Transport of Nuclear Substances Regulations" with regards to shipping documents and excepted packages. The Clear Language Regulations (Part 1.43) specifically requires that a shipping document be included with an excepted package. However, 17(2) of the "Packaging and Transport of Nuclear Substances Regulations" explicitly states that a shipping document is not needed for an excepted package. We suggest that until a clear ruling is made on this contradiction, follow the requirements of the Clear Language Regulations as Transportation Officials from Transport Canada will be using this set of regulations.)
If your shipment meets the requirements for an excepted package, the TDG regulations defer to the CNSC "Packaging and Transportation of Nuclear Substances Regulations".
Materials with a specific activity greater than 70 Bq/g are still considered radioactive as before. However, there are now NO packing groups for Class 7 shipments.
4. Responsibility of Classification (part 2.1)
Before allowing a carrier to take possession of a dangerous good for transport, the consignor must determine the classification of the dangerous good in accordance with this Part. You are allowed to use the classification determined by a previous consignor or by the manufacturer.
5. Shipping Names and UN Numbers (Schedule 1)
The following shipping names and UN numbers replace those that are currently in use under IAEA Safety Series No. 6. The following list is not complete but covers those shipping names most frequently used when transporting radioactive materials. If you are transporting nuclear fuel or Type B quantities of radioactive material or larger, please refer to Table VIII in IAEA Safety Standard Series "ST-1 Regulations for the Safe Transport of Radioactive Material 1996 Edition".
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UN Number
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Proper Shipping Name & Description |
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2910
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RADIOACTIVE MATERIAL, EXCEPTED PACKAGE - LIMITED QUANTITY OF MATERIAL |
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2911
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RADIOACTIVE MATERIAL, EXCEPTED PACKAGE - INSTRUMENTS or ARTICLES |
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2909
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RADIOACTIVE MATERIAL, EXCEPTED PACKAGE - ARTICLES MANUFACTURED FROM NATURAL URANIUM or DEPLETED URANIUM or NATURAL THORIUM |
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2908
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RADIOACTIVE MATERIAL, EXCEPTED PACKAGE - EMPTY PACKAGING |
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2912
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RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-I) non-fissile or fissile excepted |
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3321
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RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-II) non-fissile or fissile excepted |
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3322
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RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-III) non-fissile or fissile excepted |
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2913
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RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECTS (SCO-I or SCO-II) non-fissile or fissile excepted |
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2915
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RADIOACTIVE MATERIAL, TYPE A PACKAGE, non-special form, non-fissile or fissile excepted |
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3332
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RADIOACTIVE MATERIAL, TYPE A PACKAGE, SPECIAL FORM, non-fissile or fissile excepted |
6. Activity Limits
With the adoption of new shipping names also comes the update of the activity limits for packages containing radioactive material. The following list picks the more common isotopes used in Canada and their associated A1 and A2 values. Remember, A1 refers to special form material while A2 refers to normal form material.
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A1 (GBq)
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A2 (GBq)
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| Americium-241 |
10,000 |
1
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Carbon-14
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40,000
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3,000
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| Cadmium-109 |
30,000
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2,000
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| Californium-252 |
50
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3
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| Curium-244 |
20,000
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2,000
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| Cobalt-57 |
10,000
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10,000
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| Cobalt-60 |
400
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400
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| Cesium-137 |
2,000
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600
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| Iron-55 |
40,000
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40,000
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| Iodine-125 |
20,000
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3,000
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Iodine-129
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Unlimited
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Unlimited
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| Iodine-131 |
3,000
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700
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| Iridium-192 |
1,000
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600
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| Lead-210 |
1,000
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50
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| Nickel-63 |
40,000
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30,000
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| Phosphorus-32 |
500
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500
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| Radium-226 |
200
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3
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| Strontium-90 |
300
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300
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| Technetium-99 |
40,000
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900
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| Tritium |
40,000
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40,000
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7. Placards
Part 4.15 of the Clear Language Regulations implies that placards for Class 7 shipments are only needed if the shipment has a YELLOW III label. White I and Yellow II categories would now be exempt from placarding requirements.
(Note: We are awaiting clarification on this point as it is in direct opposition with the "Packaging and Transport of Nuclear Substances Regulations".)
This summarises the changes that will be encountered under the new TDG regulations that come into effect on August 15, 2002. Please visit the TDG website at http://www.tc.gc.ca/tdg/menu.htm for further information.
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Trevor Beniston is the Manager of Laboratory and Training Services at Stuart Hunt & Associates Ltd. For more information on our training service, please visit out Training Services page. |
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