Transportation of Dangerous Goods (TDG): What Canadian Employers Need to Know
The Transportation of Dangerous Goods (TDG) program is Canada's federal regulatory framework - governed by the Transportation of Dangerous Goods Act (1992) and its regulations - that controls how dangerous goods are classified, documented, marked, labeled, placarded and handled during transport by road, rail, air, or marine. Every Canadian employer who offers for transport, handles, or transports dangerous goods is legally required to comply. Violations carry fines up to $50,000 for individuals and $100,000 for corporations per offence, plus potential imprisonment for serious contraventions.
If your organization ships chemicals, compressed gases, flammable liquids, corrosives, oxidizers, or any of the nine TDG classes, this is your regulatory reality. And unlike some safety regulations where enforcement is sporadic, Transport Canada actively inspects, audits and prosecutes. The consequences of non-compliance go beyond fines - a misclassified or improperly documented shipment that leads to a spill or exposure during a highway accident can result in criminal liability, environmental remediation costs and catastrophic reputational damage.
This guide breaks down what employers need to know, what they need to do and where the most common compliance gaps occur.
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Get Free SWPsWho Does TDG Apply To?
The TDG Act applies to anyone who is involved in the handling, offering for transport, or transporting of dangerous goods. Specifically:
- Consignors (shippers): The person or company that prepares dangerous goods for transport, creates shipping documents and offers the goods to a carrier. This is typically the employer whose facility the goods originate from.
- Carriers: The person or company that physically transports the goods - trucking companies, rail operators, marine vessels, or air carriers.
- Handlers: Anyone who loads, unloads, packs, or unpacks dangerous goods during the transport chain.
- Importers: Those who bring dangerous goods into Canada.
A common misconception is that TDG only applies to trucking companies. In reality, if your manufacturing plant ships drums of solvent, your oil field sends cylinders of compressed gas, or your warehouse distributes pool chemicals - you are a consignor and the full weight of TDG classification, documentation and training requirements falls on you.
The 9 TDG Classes of Dangerous Goods
TDG classifies dangerous goods into nine primary classes, several with subdivisions. Correct classification is the foundation of everything else - documentation, labeling, placarding and emergency response all depend on it.
| Class | Description | Common Examples |
|---|---|---|
| 1 | Explosives (6 divisions) | Dynamite, detonators, fireworks, ammunition |
| 2.1 | Flammable Gases | Propane, acetylene, hydrogen, methane |
| 2.2 | Non-Flammable/Non-Toxic Gases | Nitrogen, carbon dioxide, argon, helium |
| 2.3 | Toxic Gases | Chlorine, ammonia (anhydrous), hydrogen sulfide |
| 3 | Flammable Liquids | Gasoline, diesel, acetone, paint thinners, ethanol |
| 4 | Flammable Solids / Spontaneously Combustible / Dangerous When Wet | Matches, sodium, magnesium, calcium carbide |
| 5.1 | Oxidizing Substances | Ammonium nitrate, hydrogen peroxide (>8%), sodium hypochlorite |
| 5.2 | Organic Peroxides | Methyl ethyl ketone peroxide, benzoyl peroxide |
| 6.1 | Toxic Substances | Pesticides, cyanides, arsenic compounds |
| 6.2 | Infectious Substances | Medical waste, diagnostic specimens, biological cultures |
| 7 | Radioactive Materials | Medical isotopes, industrial radiography sources |
| 8 | Corrosives | Sulfuric acid, hydrochloric acid, sodium hydroxide, batteries |
| 9 | Miscellaneous Dangerous Goods | Lithium batteries, dry ice, environmentally hazardous substances, magnetized material |
Each dangerous good has a UN Number (a four-digit identifier assigned by the United Nations) and a Shipping Name that must appear on documentation and labels exactly as specified. You can't paraphrase. "Battery acid" is not the correct shipping name - "Sulfuric acid" or "Battery fluid, acid" with the appropriate UN number is.
Classification: Getting It Right
Classification is the consignor's responsibility. Not the carrier's. Not the receiver's. Yours. And getting it wrong cascades into every other compliance element.
To classify a dangerous good, you need to determine:
- The primary class based on the most significant hazard (e.g., Class 3 for a flammable liquid)
- Any subsidiary hazards (e.g., a flammable liquid that is also toxic would have Class 3 primary and Class 6.1 subsidiary)
- The Packing Group (I, II, or III) which indicates the degree of danger - PG I is the most dangerous, PG III the least
- The UN Number and proper Shipping Name from Schedule 1 of the TDG Regulations or the IMDG/ICAO codes for marine/air transport
For pure substances, classification is usually straightforward - look up the product in the regulations. For mixtures, solutions and waste streams, classification becomes more complex and may require testing or the application of precedence-of-hazard tables. When in doubt, consult your Safety Data Sheet (SDS) Section 14 for transport information, but verify against the TDG Regulations - SDSs can be outdated or incorrect.
TDG Training Requirements
This is where many employers fail compliance audits. The TDG Regulations require that every person who handles, offers for transport, or transports dangerous goods must be adequately trained before performing those duties.
Who Needs Training?
- Shipping and receiving clerks who prepare or accept dangerous goods shipments
- Warehouse workers who load, unload, pack, or unpack dangerous goods
- Drivers who transport dangerous goods (in addition to their provincial driver training)
- Supervisors who oversee dangerous goods operations
- Emergency response personnel who may respond to dangerous goods incidents
What Must Training Cover?
Training must be specific to the duties the person performs and the dangerous goods they handle. General awareness training is not sufficient. A worker who classifies and documents shipments needs different training than a forklift operator who loads sealed containers.
At minimum, training must address:
- Classification of the dangerous goods the worker will encounter
- Proper use of shipping documents, labels, placards and markings
- Safety procedures and emergency response actions
- Means of containment selection and inspection
- Reporting requirements for releases, anticipated releases and incidents
Training Certificate Requirements
Every trained worker must hold a TDG Training Certificate that includes:
- The worker's name
- The date training was completed
- The expiry date (training is valid for a maximum of 3 years)
- The specific aspects of handling, offering for transport, or transporting covered by the training
- The name and address of the employer
Certificates must be kept by the employer and be available for inspection by Transport Canada inspectors. Using a centralized document management system to track training certificates, expiry dates and retraining schedules prevents the common scenario where a Transport Canada audit reveals that half your shipping staff has expired certifications.
The Supervised Worker Exception
A person who has not yet completed TDG training may handle or transport dangerous goods only if they are under the direct supervision of a trained and certified person. "Direct supervision" means the trained person is present and able to intervene immediately. A trained supervisor in another building or available by phone does not meet this requirement.
This exception is meant for transitional periods - new hires awaiting training - not as a permanent alternative to training.
Shipping Documents
Every shipment of dangerous goods must be accompanied by a shipping document (also called a dangerous goods document or bill of lading) that includes specific information in a prescribed format.
Required information on the shipping document includes:
- UN Number - preceded by "UN" (e.g., UN1203)
- Shipping Name - exactly as listed in the regulations (e.g., GASOLINE)
- Primary Class and any subsidiary classes (e.g., 3)
- Packing Group in Roman numerals (e.g., II)
- Quantity - expressed in mass or volume units
- Number and type of means of containment (e.g., 4 drums)
- Consignor's name and address
- Consignee's name and address (if known)
- 24-hour emergency telephone number - this must reach a person or service (like CANUTEC) that can provide immediate technical information about the goods in an emergency
The dangerous goods description must appear in a specific order and be clearly distinguishable from other information on the document. Many employers use a red-bordered box or dedicated section to separate dangerous goods information from general shipping data.
Shipping documents must be kept by the consignor for a minimum of 2 years from the date of the shipment. The carrier must also retain copies.
Labels, Placards and Markings
Visual communication is a critical safety layer in TDG. Labels go on individual packages. Placards go on vehicles and large containers. Markings provide additional specific information.
Labels
Each package containing dangerous goods must display the appropriate TDG hazard class label(s) - diamond-shaped, color-coded, with the class number and hazard symbol. Labels must be durable, legible and visible. If a product has subsidiary hazards, labels for both the primary and subsidiary classes are required.
Placards
Vehicles (trucks, railcars, portable tanks over 450 L) must display placards when carrying dangerous goods above specified quantities. Placards must be:
- At least 250 mm × 250 mm (approximately 10" × 10")
- Displayed on all four sides of the vehicle or container
- Visible and not obscured by ladders, doors, or tarps
- Removed or covered when the vehicle no longer contains dangerous goods (displaying incorrect placards is also a violation)
UN Number Display
For large means of containment (e.g., tank trucks, ISO tanks), the four-digit UN number must be displayed on orange panels or within the placard on all four sides.
Emergency Response: ERAP and CANUTEC
Certain high-risk dangerous goods require an Emergency Response Assistance Plan (ERAP) approved by Transport Canada before they can be transported. ERAPs are required for specific products listed in the regulations - typically toxic-by-inhalation gases, certain explosives and other high-consequence dangerous goods.
CANUTEC (Canadian Transport Emergency Centre) is Transport Canada's 24/7 emergency response advisory service. In the event of a dangerous goods incident during transport, CANUTEC can be reached at 613-996-6666 (or *666 on a cellular phone in Canada). This number should be referenced on shipping documents when an ERAP is not required and the consignor does not have a dedicated 24-hour emergency line.
Common TDG Compliance Failures
Transport Canada inspection data consistently reveals the same violations across industries. Knowing these patterns helps you focus your compliance efforts.
- Expired or missing training certificates - the single most common finding. Workers transfer, new hires start and nobody updates the training tracking system.
- Incorrect or incomplete shipping documents - wrong UN number, missing emergency phone number, packing group omitted, quantity not specified.
- Improper means of containment - using containers not rated for the product, expired cylinders, or damaged packaging that doesn't meet performance standards.
- Missing or incorrect labels and placards - subsidiary hazard labels omitted, placards not on all four sides, old placards left on vehicles after the load changes.
- Failure to report releases - any accidental release of dangerous goods during transport must be reported immediately to the local authority and, if it meets threshold quantities, to CANUTEC and Transport Canada within 14 days.
- Inadequate means of containment inspections - cylinders past hydrostatic test dates, drums with damaged closures, IBCs with expired UN markings.
TDG vs. WHMIS: Understanding the Boundary
A frequent source of confusion: TDG and WHMIS (Workplace Hazardous Materials Information System) are different regulatory systems with different requirements, even though they sometimes apply to the same product.
- TDG applies during transport - from the moment goods are offered for transport until they reach their destination.
- WHMIS applies in the workplace - while products are being stored, handled and used at a fixed facility.
The same drum of solvent needs a TDG shipping document, labels and placards while on a truck and a WHMIS label and Safety Data Sheet once it arrives at your facility. The classification systems are related but not identical. Workers who handle both the transport and workplace use of dangerous goods need training under both systems.
Building a TDG Compliance System
Sustainable TDG compliance isn't about cramming before an audit. It requires embedded systems that make compliance the default, not the exception.
- Inventory your dangerous goods. Know exactly what you ship, receive and transport. Maintain a current list of products with their UN numbers, shipping names and classifications.
- Assign clear responsibilities. Designate who is responsible for classification, documentation, labeling and training. Don't assume - document it.
- Implement training tracking. Use your document management system to track every TDG certificate with automated expiry alerts. A 3-year renewal cycle means roughly one-third of your workforce needs retraining every year.
- Standardize shipping documents. Create templates that prompt for every required field. A well-designed form prevents most documentation errors.
- Audit regularly. Conduct internal TDG audits at least annually - check shipping documents, inspect means of containment, verify labels and placards and review training records.
- Use toolbox talks. Regular TDG-focused toolbox talks keep requirements fresh between formal training cycles. Cover specific topics like proper label placement, shipping document completion, or spill response procedures.
Keep Your TDG Program Audit-Ready
Transport Canada doesn't announce inspections. When an inspector arrives at your shipping dock, you need every training certificate current, every shipping document complete and every container properly labeled - not next week, but right now.
Make Safety Easy gives you the tools to stay compliant without the administrative burden. Track TDG training certificates with automated renewal reminders through our document management system. Deliver ongoing TDG education through structured toolbox talks. Request a demo to see how it works, or view pricing to get started.