Transport Canada Publishes White Paper on TDG Training

Transport-Canada-Logo2Over the past several years, Transport Canada has held a number of consultations to determine to improve the quality and consistency of course ware used to train individuals on the requirements related to the Transportation of Dangerous Goods.  In 2016, Transport Canada published a White Paper to summarize the findings of their consultation and to develop a framework for moving forward.

To view or download a copy of this White Paper, click on the “Read More” button below.

Read More

TDG Training Requirements

This article, related to TDG Training Requirements, first appeared in the 2016 Mar/Apr edition of Propane Canada Magazine.

1075 PlacardThis article addresses some of the questions posed to us at Fuels Learning Centre with respect to the Transportation of Dangerous Goods (TDG) training requirements.  While the TDG training requirements have been in place for many years it does not hurt to occasionally review and discuss the TDG training needs of the propane industry.

TDG Training Basics

Part 6 of the Transportation of Dangerous Goods Regulations provides the regulatory requirements for training for persons who, handles, offers for transport or transports propane must be trained in those functions.  Transport Canada (TC) has published guidelines that are intend-ed to help employers determine which employees should be trained and what should be included in the training.

How to train employees is not mentioned in the regulations.  Training may be done through a combination of formal “in-class” training, on-the-job training, and extensive work experience. It is up to the employer to decide.

Training Certificate

The employer must provide an employee with a Training Certificate as proof of training indicating the specific training an individual has received.  Self-employed individuals must also determine if they are adequately trained and issue them-selves a training certificate.

I would encourage employers and those who are self-employed to visit the TC website to ensure that you are complying with all of the training requirements.

No Requirement for Training if Under Direct Supervision

The TDG Regulations do not require a person to be trained to handle, offer for transport, and transport propane as long as they are doing so under the direct supervision of a trained person.

The key to understanding this requirement is the words “direct supervision”.  Neither the TDG Act nor Regulations define “direct supervision”.  In cases as this where the regulatory requirements do not define a term we look for other published definitions.

For example, Ontario Regulation 215/01 Fuel Industry Certificates defines “Direct Supervision” to mean “the supervision provided by a supervising certificate holder who is on site in close proximity to a trainee and is available to assist and supervise the trainee”.

Another definition is provided by a Legal Definitions website, which states; “Direct Supervision generally means to be physically present, or within an immediate distance, such as on the same floor, and available to respond to the needs of something or someone”.

As you can see the industry best practice, in this case, is to ensure that the person providing the direct supervision is present or in close proximity to the person under supervision.

One thing to remember is that if you are providing “Direct Supervision” to a person, you are responsible and accountable for that person’s actions.  If there is an incident and it is shown that the person under your direct supervision was not properly supervised, you were away from the transfer facility or not in the cab of the truck, you can and will be the one held responsible.  It is therefore in the supervisors and the employee’s best interest that the employee is properly trained and is the holder of a Training Certificate.

Training Organizations

While the TDG Directorate maintains a listing of organizations which provide dangerous goods training, the Directorate does not examine or certify any of the courses offered and the listing of organizations does not imply endorsement or approval of the training offered by Transport Canada.

Focused Training

Some employees may only need training in the aspects of the regulations that are directly related to their work.  If a tank truck, cargo liner or cylinder delivery vehicle is loaded by a plant person, then that plant person may only need specific training in relation to the offering for transport and handling of propane.  Conversely, a driver who drives the truck will require training in transporting and for unloading, handling.  In this situation, it is the employers’ responsibility to deter-mine what constitutes adequate training for their employees.

To make it simpler for employers to determine what TDG training an employee requires, Fuels Learning Centre embeds the necessary TDG training requirement in our cylinder/automobile filling, tank truck, cargo liner and cylinder delivery training modules so there is no need for persons performing those functions to take an additional TDG training program and no guess work on the part of the employer on whether the employee received the correct training.

An employer can feel comfortable that the employee has received the correct TDG training and issue a TDG Training Certificate to each student who successfully passes the training module.  Also by embedding the necessary TDG training within the training modules saves time and money.

Handlers, Offerers, and Transporters of Propane

Regulations stipulate that no person shall import, offer for transport, handle or transport propane unless the person complies with all safety and security requirements, the propane is accompanied by the required documentation, and that the means of containment and transport vehicle used comply with all safety standards and display all safety marks required by regulation.

The responsibility for compliance falls on multiple parties, although there are three primary categories of people who work with propane depending on their specific job functions.

Handlers of Propane
Handling refers to loading and unloading propane into a means of containment for the purpose of transporting it or storing the propane in the course of transportation.  Therefore, handlers of propane are individuals who transfer propane from one container to another, handle pro-pane containers and operate bulk delivery vehicles.  This would include, but is not limited to:

  • workers who fill propane cylinders and auto propane tanks at refilling centres;
  • bulk truck drivers who fill their bulk trucks from the refinery or storage and deliver propane to end-use customers; and
  • refinery workers who load propane into rail cars for shipment.


Offerer of Propane for Transport
The person who offers for transport is the person who, for propane not in transport, selects or allows the selection of a carrier to transport the propane, to prepare or allow the preparation of the propane so that a carrier can take possession of the propane for transport or to allow a carrier to take possession of the propane in transport.  The offerer of propane is also referred to as the consignor.
The offerer of propane is generally a corporate entity.  Outside of handling and transporting propane shipments, the offerer carries primary responsibilities for the classification of propane, appro-priate documentation and emergency and security planning.  Some of the individuals who are responsible for these primary responsibilities include:

  • Individuals who classify propane and provide proof of classification;
  • Individuals who obtain or prepare Safety Data Sheets for distribution to carriers and receivers of propane shipments;
  • Individuals who select a carrier of propane shipments; and
  • Individuals who bill customers for the shipment of propane.

Transporters (Carriers)
This refers to individuals who are in possession of propane while it is in transport.  This would include, but is not limited to:

  • Road transport companies;
  • Rail transport companies
  • Propane retailers;
  • Bulk truck drivers; and
  • Operators of other vehicles carrying propane such as cylinder trucks and crane trucks.

Cargo Liner

Some individuals may fall into more than one of the above three categories and the level of training they require to meet the regulatory requirements depends on the scope of their individual jobs.

Specific TDG Training Requirements

Base Content for All TDG Training
The following items must be included in TDG training and serve as the “base” for TDG training:

  1. Definition of the nine classes of dangerous goods and their associated hazards;
  2. Shipping names, classes, UN numbers and packing groups for the dangerous goods that are normally encountered on the job;
  3. Safety marks such as labels and placards that are used to identify the different classes of dangerous goods that are normally encountered on the job;
  4. Knowledge of the information that must be on a shipping document;
  5. The requirements regarding mixed loads and the need for segregation of incompatible dangerous goods;
  6. The proper selection and use of means of containment for the dangerous goods;
  7. What to do if the shipping documents, placards, labels, other safety marks or means of containment seem inadequate or incorrect;
  8. What constitutes an accidental re-lease and the reporting requirements if an accident happens;
  9. Proper use of all equipment that is used in the handling, offering for transport and/or transportation of dangerous goods; and
  10. Emergency Response Assistance Plans (ERAP) requirements if a plan is required.

Training for Handlers of Propane
In addition to the standard items required in all TDG training, handlers of propane must also receive training in the following areas:

  1. Types of placards, labels, signs, num-bers and other safety marks, what they mean, and when and where to display them;
  2. A thorough knowledge of the control and emergency features for all handling equipment used in the day-to-day activities of the job;
  3. Safe practices on the loading and stowage of propane;
  4. When to remove placards, UN numbers, and other safety marks;
  5. The proper selection and use of means of containment for propane.

TDG Cylinder Label

Training for Offerers of Propane
In addition to the standard items required in all TDG training, offerers (con-signors) of propane must also receive training in the following areas:

  1. All of the requirements required for documentation except for the location and the rail consist;
  2. How to communicate the special instructions and precautions for the handling and/or transporting of propane while on the job;
  3. Types of placards, labels, signs, numbers and other safety marks, what they mean, and when and where to display them;
  4. The proper selection and use of means of containment for propane;
  5. The Emergency Response Assistance Plan requirements (ERAP) if a plan is required.

Office Worker on Computer

Training for Transporters of Propane
In addition to the standard items required in all TDG training, transporters of propane must also receive training in the following items:

  1. Types of placards, labels, signs, numbers and other safety marks, what they mean, and when and where to display them;
  2. The location of the shipping documents and the importance of keeping them accurate;
  3. Requirements for parking, loading and vehicle inspection which may apply.

Vehicle Parking

Training Required to Fill Cylinders Larger than 46 Litres in Capacity

We have been asked many times about the requirement for TDG training for individuals who fill cylinders at retail filling centres. The 150 kg and 500 kg exemptions in the regulations remove the training requirement, however, the exemption is limited to cylinders up to 46 L in capacity.  The Small Means of Containment exemption does allow for larger cylinders, however, the exemptions only apply to the transport of the propane and not the handling.  Therefore, if your employees are going to be filling cylinders larger than 40 pounds in capacity, they must have TDG training specific to the handling of propane.

Embedding of Specific Training into Training Courses

At Fuels Learning Centre we not only embed the required TDG training but also, dependent on the training module, we embed other specific training requirements a person needs to complete the tasks required for their job.

Trained Individuals Danger Sign


For example, a version of our tank truck driver training course includes inspection of propane tanks and pressure relief valves, truck-to-truck transfer requirements specific to each province and directions for how to safely light appliances for fuel outages.

View PDF

Keeping Regulatory Training Current

Most records of training for compliance training are valid for three years. A lot can happen in terms of regulatory requirements in three years. This article, summarizes information from two articles which first appeared in the Sep/Oct and Nov/Dec 2014 editions of Propane Canada Magazine. This article discusses the importance of ensuring you are keeping regulatory training current so that your employees remain properly trained.


As detailed in previous articles earlier this year the B149.1 – Natural Gas and Propane Installation Code and the B149.2 – Propane Storage and Handling Code have been extensively amended for publication by the Canadian Standards Association in 2015.

Also, the B149.3 – Code for the Field Approval of Fuel Related Components on Appliances and Equipment and the B149.5 – Installation Code for Propane Fuel Systems and Tanks on Highway Vehicles will have new Codes published by the Canadian Standards Association in 2015.

The provincial adoption of the 2015 codes will start to take place sometime after January 2015.  Some provinces adopt the codes as soon as they are published, while other provinces adopt several months later.  It is, therefore, important that, as users of the Codes, you are aware of when your particular province will adopt the Codes that regulate the work you perform.

Ontario Adoption of Codes

Ontario - TSSA Logo 01Ontario has issued an Ontario Code Adoption Document (CAD) for both 2010 editions of B149.1 and B149.2 codes which become effective October 1, 2014. The CAD adopts many of the changes that will appear in the 2015 editions of the B149.1 and B149.2 codes.  The CADs are available on the TSSA website for download.  Significant changes made by the Gaseous Fuels amendment include:

  1. Permitting press-connect fittings;
  2. Re-classifying clothes dryers in accordance with the certification standard;
  3. Adding a new section regulating unvented heaters installed in livestock or poultry facilities;
  4. Incorporating Director’s Order FS-051-04 (re B-Vents not certified for exterior applications installed outdoors) into the code, for ease of reference; and
  5. Adoption of TSSA-MFSE-2014 for field approval of mobile food service equipment.

The Propane Storage & Handling Code Adoption Document adopts the 2010 edition of the Code and new requirements approved by the B149.2 and B149.5 Code Committees for the 2015 Code which are considered important to be implemented in Ontario now and addresses gaps in the current codes to enhance safety.

Major changes in this version include the following:

  1. New definitions added for “construction site” and “cylinder exchange”;
  2. New requirements for cylinder storage, including storage at construction sites and rooftops;
  3. New requirements for cylinder exchanges;
  4. Reiterating the need for compliance with Branch Standard #9 or a full risk and safety management plan for facilities in heavily populated or congested areas; and
  5. New certification requirements for valves, components, and accessories for propane vehicle conversion; replacing IGAC Protocol 01-97.

Code Updates Referred to in TDG Regulations

At the same time there is a new, 2014 edition of the B620 – Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods and B622 – Selection and Use of Highway Tanks, Multiunit Tank Car Tanks, and Portable Tanks for the Transportation of Dangerous Goods, Class 2.

While Transport Canada recently adopted the 2009 editions of the CSA/B620 and CSA/B622, the 2014 editions are completed and ready for adoption. It is important for one to keep abreast of the latest Codes and Standards as you know eventually any new requirements will become law.

Training Requires Updating

Once the Codes and Standards are adopted there will be an immediate training need for persons who perform work that is regulated by these documents.  In Ontario, this is October 1, 2014, which means that training programs that are used by the propane industry to train people must reflect the latest regulatory requirements as of October 1, 2014, for Ontario and in other provinces early next year.

This does create some issues as the current Record of Training (ROT) retraining requirements are once every 3 years, which means that people can actually be working in the field for up to 3 years before they are trained on the new regulatory requirements.


Given that 2015 is the year for the issuance of new codes it may be advisable for employers in certain segments of the industry such as gas technicians, propane cylinder, cargo liner and bulk delivery and propane construction heating, to have their employees trained on the new requirements rather than wait until such time that the person’s ROT is up for renewal.

One of the largest impacts is going to be in the construction industry where the requirements for the storage and use of cylinders have been extensively amended. If your cylinder delivery driver is not aware of the new requirements he could inadvertently create a non-compliance situation which could result in fines and disruption of service to your customer.

For example, Ontario Director’s Order FS-095-06, issued November 2013, states that “when distributors provide fuel to tanks or cylinders not connected to the premises, the distributor shall ensure that the fuel storage is compliant with Ontario Regulation 211/01”.

If not aware of the new requirements, the contractor who uses the propane cylinders and construction heaters can also inadvertently create a non-compliant situation which could result in fines and impact the ongoing construction of the building. The contractor could also be at a disadvantage from an efficiency perspective if he does not know the new requirements with respect to the use and storage of propane cylinders on rooftops.

Another example is the increased size of cylinders which may be stored in cylinder exchange cabinets. Due to demand from the RV industry, the maximum was changed from 20 lb. 30 lb. cylinder sizes. The cabinet maximum capacity of 500 lb. (25 x 20 lb., or 16 x 30 lb., or a combination thereof) has been maintained. If you were not aware of these new requirements you could be missing out on an opportunity to serve the recreational market with the larger propane cylinders.

The CSA-B620-14 has new requirements for “off truck emergency shutdown system” to include tanks in non-metered propane delivery as well as engine shutdown when the engine air intake senses flammable vapors. When adopted, drivers of unmetered deliveries need to be trained in the inspection and use of these new requirements

It does not make economical or practical sense to train people with outdated training programs. As indicated by the examples above it is crucial to one’s business that employees are trained in understanding the latest regulatory requirements.

Status of publication of the 2015 series of CSA Codes and Standards

2015 B149.1 – Natural Gas & Propane Installation Code
The committee last met on June 12, 2014. Public Review took place from March 12 to May 12, 2014; and all comments were dispositioned and resolved. There was a general consensus on the draft and it proceeded to the editing stage. The ballot for the approval of the Code has been issued for committee review. A meeting of the Technical Committee (TC) will take place in February 2015 if needed for the disposition of ballot comments. Publication in both English and French is scheduled for August 2015. The next Technical Committee meeting is planned for the week of June 8, 2015, in Niagara Falls, ON.

2015 B149.2 – Propane Storage & Handling Code
The committee last met on June 11, 2014. Public Review took place from March 12 to May 12, 2014, and all comments were dispositioned and resolved. There was a general consensus on the draft and it proceeded to the editing stage. The ballot for the approval of the Code has been issued for committee review. A meeting will take place in February 2015 if needed, for the disposition of ballot comments. Publication in both English and French is scheduled for August 2015. The next Technical Committee meeting is planned for the week of June 8, 2015, in Niagara Falls, ON.

2015 B139 – Installation Code for Oil Burning Equipment
The Technical Committee last met on June 24-26, 2014 to disposition Public Review comments and finalize the technical content in the Draft. The ballot for the approval of the Code took place from Sept. 3 to Oct. 3, 2014. The scope has been changed to include fuel oil storage tanks of all sizes including underground tanks. The Code is now divided into two major parts, B139.1 – Large Installations and B139.2 – Residential and Small Commercial Installations. Publication is scheduled for April 1, 2015, in both English and French.

Gas Appliances and Related Accessories
The CSA Gas Technical Committee held a joint meeting with the U.S. Z21/83 Technical Committee on Sept. 30. 2014. The following new standards were approved:

  • CSA 3.8, Gas-fired Equipment for Drying Crops;
  • Z21.10.1/CSA 4.1, Water Heaters Volume 1; Z21.10.3/CSA 4.3, Water Heaters Volume Ill;
  • Z21.54/CSA 8.4, Gas Hose
  • Connectors;
  • Z21.19/CSA 1.4, Refrigerators Using Gas Fuel;
  • Z21.56/CSA 4.7, Pool Heaters; and
  • Z21.58/CSA 1.6, Outdoor Cooking Appliances.

Oil Burning Appliance Standards (B140 Series, B211 & B212)
The B 140 series of Standards have been reaffirmed; however, they are in need of review and updating. The last Technical Committee meeting was held on May 2, 2012. CSA will be looking at reconstituting the TC to begin work on these documents.

Carbon Monoxide Detectors Standard
The Technical Committee has been reinstituted for a new edition of the CSA 6.19 standard. The TC’s first meeting was Sept. 25, 2014, with the publication date projected for September 2016.

Introduction of the Fuels Learning Centre

Recent events provided a business opportunity for me to partner with Bill Egbert in the creation of a new training provider for the fuels industry.  The company is called Fuels Learning Center Limited (FLC) which will not only provide training modules to the propane industry but also the fuel oil and natural gas industries.

Fuels Learning Centre

As most of you are aware Bill was for many years, the General Manager of the Propane Training Institute. I was under contract to the Canadian Propane Association to write new training programs and update existing programs with the latest technical and regulatory requirements.

The Fuels Learning Centre currently has nine provincially approved training courses which reference the latest regulatory requirements of the Codes and the Standards to be adopted:

These programs, when successfully completed, will provide the provincially acceptable ROT and where required the TDG qualifications for persons who need to be trained in the handling and use of propane.  We have been able to streamline these programs to focus more on what a person needs to know and less of what is not required to know to safely perform their tasks.


View PDF