How Globally Harmonized System (GHS) Affects Transportation of Dangerous Goods (TDG)

On February 11, 2015 the Government of Canada published in the Canada Gazette, Part II the Hazardous Products Regulations (HPR), which, in addition to the amendments made to the Hazardous Products Act under the Economic Action Plan 2014 Act, No.1, modified the Workplace Hazardous Materials Information System (WHMIS) 1988 to incorporate the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) for workplace chemicals. This modified WHMIS is referred to as WHMIS 2015.  What does this mean for the Transportation of Dangerous Goods?

In the US, the DOT says that both OSHA HazCom labeling requirements and DOT’s labelling requirements are in effect.  So if you are in Canada shipping to the US you need to be aware of the labelling requirements.  However, there are some special cases:

• When small containers are put in a larger container for shipping, the inside containers will contain the GHS compliant label and the larger outer container will be marked with the DOT label.
• When a large means of containment is shipped, ie: a drum or a tote, should have both labels on it.  (there is a provision that the GHS label should not contain the picture, but this is up for revision).

In Canada, since GHS is brand new as of this recent change, there is nothing official from Transport Canada.  However, the general practice is for Transport Canada to mirror what the US does for convenience of transportation between our two countries.  Transport Canada just released a TDG Bulletin on Dangerous Goods Safety Marks in January 2015 which can be found at:

https://www.tc.gc.ca/media/documents/tdg-eng/Bulletin_-_Safety_Marks.pdf

Here are some important dates you should remember: