Shipping Hazmat & Dangerous Goods Between Canada and the U.S.: TDG vs 49 CFR

1What counts as dangerous goods

Canada calls them dangerous goods; the United States calls them hazardous materials, or hazmat. Both countries build on the UN Recommendations on the Transport of Dangerous Goods, so they share the same nine classes, the same packing groups (I for great danger, II for medium, III for minor) and the same four-digit UN numbers. In Canada the rules are the Transportation of Dangerous Goods (TDG) Regulations; in the U.S. they are the Hazardous Materials Regulations in Title 49 of the Code of Federal Regulations (49 CFR, Parts 171 to 180).

The quickest way to know whether a product is regulated is section 14 of its Safety Data Sheet, which gives the UN number, shipping name, class and packing group. If those are there, the product needs a shipping document, the right packaging, labels and, above the thresholds below, placards on the truck.

2TDG vs 49 CFR at a glance

For most freight the two systems ask for the same things in a slightly different form. The differences that change how a truck is loaded, placarded or documented are these:

3When a truck needs placards

Canada: the 500 kg rule and its exclusions

A placard is not required on a road vehicle carrying 500 kg gross mass or less of dangerous goods (TDG s. 4.16.1(1)). Above that, each class on board is placarded on both sides and both ends. Some goods need placards at any quantity because they are excluded from the 500 kg exemption (s. 4.16.1(2)):

• Dangerous goods that require an ERAP.
• Goods that need a subsidiary class placard (s. 4.15.1).
• Class 1 explosives, except those listed in s. 4.17(1) (such as 1.4S) and small quantities of Class 1.1, 1.2, 1.3 or 1.5.
• Class 2.1 flammable gases, when the vehicle is to be carried on a ship.
• Class 2.3 toxic gases and Class 4.3 water-reactive substances.
• Class 5.2 Type B organic peroxides that need temperature control.
• Class 6.1 toxic substances subject to special provision 23 (toxic by inhalation).
• Class 7 radioactive material that needs a Category III-Yellow label.

UN numbers must also be shown on the large means of containment, except for Class 1, when the goods need an ERAP or are a liquid or gas in direct contact with the container, such as a tank (s. 4.15.2).

United States: Table 1 and Table 2

Table 1 materials need placards at any quantity: Divisions 1.1, 1.2 and 1.3, Division 2.3, Division 4.3, temperature-controlled Type B organic peroxides (5.2), materials poisonous by inhalation (6.1), and Class 7 packages with Radioactive Yellow-III labels. Everything else is Table 2, which can travel without placards by highway when the total is less than 454 kg (1,001 lb) aggregate gross weight and none of it is in bulk (49 CFR 172.504(c)). Division 6.2 has no placard, and the Class 9 placard is not required within the U.S.

A load that crosses the border has to meet the placarding rule of the country it is in. Check the placards and the shipping document against both countries’ rules before the load leaves.

4Shipping documents and emergency numbers

Both countries require a document that travels with the load, prepared by the shipper before the carrier takes the freight, and kept within the driver’s reach in the cab.

Canada’s 24-hour number can be the shipper’s own or another organization’s; CANUTEC’s number can be used only with CANUTEC’s written permission (s. 3.5(2)). CANUTEC, Transport Canada’s emergency centre, answers 24 hours a day at 1-888-CAN-UTEC (226-8832), 613-996-6666 or *666 on a cellphone in Canada. The U.S. number has to be answered by a person who knows the material; callback services do not qualify (§ 172.604).

Canada accepts the U.S. shipper’s certification wording as an alternative to its own (s. 3.6.1), which lets one document serve both legs when it carries everything both countries need.

5ERAP: Canada’s emergency response plan

An Emergency Response Assistance Plan is a plan, approved by Transport Canada, to respond to an accident involving certain high-risk dangerous goods. It is required when the quantity is more than the ERAP index in column 7 of Schedule 1, with separate triggers for Class 1, for interconnected gas containers over 225 L, and for Risk Group 4 infectious substances in any quantity (TDG s. 7.2). The ERAP number and the ERAP telephone number go on the shipping document.

There is no ERAP in the U.S. rules. For goods coming from the U.S. into Canada, the ERAP is still required when the goods would need one under Canadian classification (s. 7.2(2)). Anhydrous ammonia is one example; the UN number lookup shows the ERAP index for each entry that has one.

6Crossing the border: whose rules apply

Neither country makes you reclassify and repackage at the border. Each accepts the other’s rules for road shipments, with conditions.

U.S. to Canada: TDG s. 9.1

• A road shipment from the U.S. into or through Canada can follow 49 CFR for classification, documentation and safety marks instead of TDG Parts 2 to 4.
• The shipping document must be legible and in English or French, and show the consignor’s name and Canadian place of business (for goods in transit, each consignor’s name and address).
• Goods with a “D” (U.S. domestic only) entry in the U.S. table must also carry the Canadian classification.
• The ERAP information goes on the document when an ERAP applies, and the carrier rules on document location and storage in transit still apply.
• Goods forbidden in Canada, goods regulated in Canada but not in the U.S., and U.S. exceptions that Canada does not allow are not covered.

Canada to the U.S.: 49 CFR 171.12

• Hazmat moving from Canada into the U.S., from the U.S. to Canada, or through the U.S. may travel by truck or rail under the TDG Regulations, with conditions on packaging and cylinders.
• U.S. requirements still apply for hazardous substances (the RQ notation), hazardous waste, marine pollutants in bulk and materials poisonous by inhalation (49 CFR 171.23(b)).

Drivers licensed in Canada or Mexico who haul placarded hazmat into or within the U.S. need a background check equivalent to the U.S. hazmat endorsement check; a current FAST card or TWIC meets it (49 CFR 1572.201). Canada accepts U.S.-licensed drivers trained under 49 CFR 172.704 while that training is valid (TDG s. 6.4(1)).

7Training and driver credentials

8U.S.-only rules shippers miss

• Hazardous substances. A material listed in Appendix A to § 172.101, in one package at or above its reportable quantity, is a hazardous substance: “RQ” goes on the shipping paper and the package.
• Marine pollutants. Listed in Appendix B to § 172.101; in bulk they need shipping-paper entries and markings even on a highway move.
• Combustible liquids. A flash point above 60 °C (140 °F) and below 93 °C (200 °F) makes a liquid “combustible” in the U.S. In non-bulk packages it is not subject to the rules unless it is also a hazardous substance, waste or marine pollutant; in bulk it is regulated. Canada has no combustible class.
• Registration. PHMSA registration is required for offerors and carriers of, among others, any placarded quantity of hazmat (farmers excepted), bulk packagings of 13,248 L (3,500 gal) or more, and non-bulk shipments of 2,268 kg (5,000 lb) or more of one placarded class (§ 107.601). A foreign shipper offering solely from outside the U.S. may be excepted (§ 107.606).
• Safety permits. Carriers of certain materials, such as more than 25 kg of Division 1.1, 1.2 or 1.3 explosives or zone A inhalation hazards, need an FMCSA hazmat safety permit (§ 385.403).

9Common goods, two rulebooks

10What to send us for a hazmat quote

Stryke arranges dangerous goods freight in all nine classes, domestic and cross-border, through qualified carriers. To quote and plan a load we need the facts the shipping document will carry:

• The Safety Data Sheet, or at least section 14.
• UN number, shipping name, class and packing group, as you have classified them.
• Quantity and packaging: number of packages, net and gross weight, bulk or non-bulk, limited quantity or not.
• Your ERAP number if the goods need one in Canada, and the 24-hour emergency number for the shipping document.
• Pickup and delivery, dates, and whether the load crosses the border, with your customs broker’s details.

We check that the paperwork, placards and route fit both countries’ rules before pickup. The classification and the shipping document remain the shipper’s.