The consignor prepares the document, the carrier refuses the load without it, and the driver keeps it where an officer can reach it.
Key takeaways
Under the federal Transportation of Dangerous Goods Regulations, the consignor must prepare and give the carrier a shipping document, or an electronic copy if the carrier agrees, before allowing the carrier to take possession (section 3.1). The carrier side is the mirror image: a carrier must not take possession of dangerous goods for transport unless the carrier has the shipping document (section 3.2(1)), and a carrier who accepts an electronic copy must produce a paper document from it before taking possession.
Placarding is governed by Part 4. The primary class placard for each of the dangerous goods in a large means of containment must be displayed on each side and on each end (section 4.15), subject to a general exemption where the gross mass on the vehicle is 500 kg or less and a list of goods that exemption never covers.
Section 3.5(1) sets out the required information. It begins with the name and address of the consignor’s place of business in Canada and the date the document was prepared or first given to a carrier.
Then comes the description, and the order is not stylistic. The regulations require the elements in the following order, without any additional information interspersed unless otherwise provided: the UN number; the shipping name, with “WASTE” before it if the goods are waste, “HOT” where the goods travel at or above 100°C liquid or 240°C solid, and “NON-ODOURIZED” for an unodorised liquefied petroleum gas; the primary class number after or under the word “Class” or “Division”; the compatibility group letter for Class 1; any subsidiary class numbers in parentheses; and the packing group in Roman numerals after or under “PG” or “Packing Group”.
After the description: the quantity and unit of measure for each shipping name, in SI units for a document prepared in Canada (net explosives quantity for Class 1); the number of small means of containment for each shipping name where labels are required; flash point and marine pollutant wording for vessel transport; control and emergency temperatures for temperature-controlled goods; nuclear substance information for Class 7; the ERAP reference number and ERAP telephone number where an emergency response assistance plan is required; and finally the words “24-Hour Number” followed by a telephone number at which the consignor can be reached immediately for technical information without breaking the connection made by the caller.
That last requirement is more demanding than it looks. It is not a voicemail and not an office line at 3 a.m. The regulations allow the number to belong to an organisation such as CANUTEC instead, but only with CANUTEC’s written permission, or to another agency if the consignor ensures it holds current and accurate information about the goods.
The information must be easy to identify, legible, in indelible print and in English or French (section 3.4(1)). Where dangerous goods appear on the same document as ordinary freight — the normal case for an LTL carrier — the dangerous goods information must be shown before the non-dangerous goods under a “Dangerous Goods” heading, or printed or highlighted in a contrasting colour, or marked with an “X” opposite the UN number in a column headed “DG”.
The consignor also certifies. Section 3.6.1 requires the document to carry, after the section 3.5 information, a declaration that the contents are fully and accurately described by the proper shipping name, properly classified and packaged, with dangerous goods marks properly affixed, and in proper condition for transport — made by an individual who is or acts for the consignor, and setting out that individual’s name.
Section 3.7 is specific and is exactly what an inspector checks first. The driver of the power unit must ensure a copy of the shipping document is kept in a pocket mounted on the driver’s door or within the driver’s reach if the driver is in the power unit; or, if the driver is out of the power unit, in a door pocket, on the driver’s seat, or in a location clearly visible to anyone entering through the driver’s door.
While the goods are in the carrier’s possession the carrier must keep the document in that location (section 3.2(4)), must hand it or a copy to the next carrier at or before transfer, and must give a document identifying the goods to any other person taking possession. Where a trailer is dropped in an unsupervised area, the shipping document must be placed in a waterproof receptacle securely attached to or near the means of containment at a readily identifiable and accessible location.
A placard must be square, displayed in the same orientation as in the appendix so that the square sits on point, with each side at least 250 mm in length and a line running approximately 12.5 mm inside the edge (5 mm for a Class 7 placard). Where the shape or size of the containment would make it invisible from the same viewpoint as the other marks, each side may be reduced to not less than 100 mm, with every element reduced proportionally.
Where a large means of containment holds two or more dangerous goods requiring different placards, all of them in two or more small means of containment, a DANGER placard may be displayed instead of the individual placards. But it must not be used where one consignor offers goods of the same class with a gross mass greater than 1,000 kg, nor for goods requiring an ERAP, Class 1 explosives, Class 2.3 toxic gases, Class 4.3 water-reactive substances, temperature-controlled Class 5.2 type B organic peroxides, Class 6.1 goods subject to special provision 23, or Class 7 goods requiring a Category III — Yellow label.
UN numbers are a separate mark. Where required, the number is written without the “UN” prefix in black characters at least 65 mm high, on an orange panel next to the primary class placard or within a white rectangle on the placard that does not obscure any symbol or text.
Section 4.16.1 provides that a placard is not required on a road vehicle if the dangerous goods in or on it have a gross mass less than or equal to 500 kg. This is the provision most mixed-freight carriers rely on, and the exceptions list is the part to memorise.
Separately, section 1.15 exempts small consumer-quantity movements from Parts 3 to 6 and 8 entirely, but only on tight conditions: each means of containment at 30 kg or less, total gross mass of all dangerous goods at 150 kg or less on a road vehicle, in a quantity or concentration available to the general public, and transported by a user or purchaser or by a retailer to or from one. A commercial LTL carrier moving a customer’s freight is not inside that exemption.
Worked example: a mixed LTL trailer out of Cambridge
The trailer carries general freight plus three dangerous goods consignments: 180 kg of a Class 3 flammable liquid in drums, 60 kg of a Class 8 corrosive in pails, and one skid of Class 9 goods at 210 kg. Nothing requires an ERAP.
Documents first. Each consignor provides its own shipping document with the section 3.5 elements in order, the SI quantity, the count of small means of containment, the certification and a working 24-hour number. Because the dangerous goods appear alongside ordinary freight, the dangerous goods lines are shown first under a “Dangerous Goods” heading, or highlighted, or marked with an X in a DG column. The driver keeps the documents in the door pocket.
Placards next. Total gross mass of dangerous goods is 450 kg, which is at or below the 500 kg threshold, and none of the goods fall into the excepted categories, so no placard is required on this configuration. Add one more drum of the Class 3 product and the total crosses 500 kg — at which point placards are required on each side and each end, and the DANGER placard option becomes relevant because there are multiple classes in small means of containment. The moment the load plan changes at the dock, the placard decision changes with it.
Two follow-through duties get missed. If the quantity or the number of small means of containment changes during transport, the carrier must write those changes on the shipping document or on a document attached to it. And when the danger is no longer present, the person who unloads, cleans or purges the means of containment must cover or remove the dangerous goods mark, using durable, weather-resistant material that withstands the conditions without detaching.
A document checker is a legitimate and useful piece of automation. The section 3.5 requirements are structural: a defined element order, mandatory fields, a certification, a 24-hour number. A rules engine can compare a scanned or transmitted shipping document against that structure and flag a missing packing group, a description with information interspersed in the wrong place, or an ERAP number with no accompanying ERAP telephone number, before the trailer moves.
What must not be automated is the determination. Classification, packing group assignment, choice of means of containment and the consignor’s certification are judgements made by a trained person who takes responsibility for them. Transport Canada’s dangerous goods pages are the starting point for classification, ERAP and CANUTEC questions, and the regulations themselves are the authority. A tool that drafts and flags is an asset; a tool presented as deciding is a liability.
The consignor may give an electronic copy if the carrier agrees, but the carrier must produce a paper shipping document from the electronic copy before taking possession.
The consignor prepares and certifies it. The carrier, however, must not take possession without it, must keep it in the prescribed location, and must record quantity changes in transit — so a carrier who accepts an obviously deficient document is not a bystander.
Generally on each side and each end, but for a trailer unit the placard may be displayed on the front of the vehicle attached to the trailer rather than on the leading end.
English or French, in indelible print, easy to identify and legible.
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