CIAC to Transport Canada – Terminology will play a key role in efforts to amend Part 7 of the TDG Regulations
June 08, 2017
The Chemistry Industry Association of Canada (CIAC) has submitted recommendations to Transport Canada regarding proposed amendments to Emergency Response Assistance Plans (ERAPs) for the transportation of dangerous goods. “Throughout the regulatory updates and anticipated drafting of guidance materials, terminology will play a key role in clarifying expectations,” said Kara Edwards, CIAC Director, Transportation.
Overall, CIAC is supportive of the efforts to amend Part 7 of the Transportation of Dangerous Goods (TDG) Regulations to clarify its expectations for stakeholders and agrees that the ERAP program plays a key role in protecting the safety of the public and first responders.
As explained by Andy Ash, Director, Dangerous Goods for the Railway Association of Canada, ERAPs are important for industry because in the event of a dangerous goods incident on their property, they can trust that it’s going to be taken care of by qualified, trained and properly equipped teams.
Despite their importance, a lot of first responders are not aware of the ERAP program. “Part of the messaging during the consultation process has been the need to establish first responder’s outreach and education on what ERAPs are and how they can benefit public safety and environmental protection,” said Ash.
In the submission, CIAC recommended several language considerations and changes to Transport Canada’s proposal to clarifying expectations for stakeholders. Topics on which CIAC commented related to: the ERAP telephone number, ERAP activation criteria and process, availability of a technical advisor, tiered service levels, ERAPs for shipments of residual amounts of dangerous goods, and termination of an ERAP.
“In the final drafting of the regulations, we support a flexible versus prescriptive approach,” said Edwards. “It is also important to stress that any timelines being proposed are clearly understood as guidelines with the recognition that many factors can influence their ability to be met.”
To view all of CIAC’s recommendations, the full submission is available here.