Transportation of Dangerous Goods (TDG) - Emergency Response

The Transportation of Dangerous Goods (TDG) Regulations define “emergency” as “immediate danger to public safety that requires the use of dangerous goods to avert or mitigate the danger; or arises directly or indirectly from the dangerous goods.”

A TDG emergency may include incidents such as:

• a traffic incident that may cause the dangerous good to catch fire, explode, or spill
• vehicle problems that may cause the dangerous good to catch fire or explode (e.g., damage to cooling system)
• failure of the means of containment (MOC) which results in a release of the dangerous good into the environment

Note: The information below is provided as guidance only. Always check with Transport Canada and the TDG Act and Regulations to ensure compliance.

Please also see the following documents in this series:

• TDG - Overview
• TDG - Training
• TDG - Classification
• TDG – Nine Classes
• TDG – "Special Case” and “Special Provision” Exemptions
• TDG - Reporting Requirements

Yes.  Part 7 of the TDG Regulations outline requirements that are specific for dangerous goods that are a high risk to public safety. When high risk dangerous goods are being transported at or above a certain threshold, Part 7 requires the consignor to prepare an Emergency Response Assistance Plan (ERAP).

Note that for dangerous goods that are not covered in Part 7, the TDG Act also specifies a “duty to take reasonable emergency measures” which reads:

Every person required to make a report shall, as soon as possible in the circumstances, take all reasonable emergency measures to reduce or eliminate any danger to public safety that results or may reasonably be expected to result from the release.[TDG Act, S. 18(2)]

In practice, yes. These plans relate to:

• Dangerous goods that MUST have an Emergency Response Assistance Plan (ERAP) when they are transported above a certain threshold. These dangerous goods are specified in Part 7 and Schedule 1 of the TDG Regulations. They will be referred to as “ERAP dangerous goods” in this document.
• Dangerous goods that do NOT require a formal Transport Canada approved ERAP. It is good practice develop a response plan to follow in the event of a spill, fire, release, etc.

An emergency response assistance plan (ERAP) describes how the consignor of higher risk dangerous goods will respond to support first responders in the event of a transportation incident. Generally speaking, the ERAP will:

• list the mode of transport used, the frequency of transport, means of containment, and geographical area where the dangerous goods are shipped.
• describe the equipment and procedures the shipper has available to support a response to incidents involving the high-risk dangerous goods.
• outline the information about the ERAP response personnel (such as technical advisors, team leaders, response teams)
• describe the specialized response capabilities (e.g., measures that can be taken, persons responsible for taking those measures, etc.)
• estimate the time required to respond (e.g., reach the location of the release, steps required to deploy personnel and equipment, etc.)
• include information on emergency preparedness for specific scenarios (i.e., release, release of less than 1% of the dangerous good in a means of containment, more than 50% of the dangerous good in a means of containment, and exposure to fire)

The ERAP may be used along with emergency plans from other organizations (such as local or provincial authorities).  Always confirm with these authorities or other agencies that they have the capacity to assist or respond appropriately to the hazards of the specific dangerous good being shipped in their area.  Creating and implementing an incident management system will help to coordinate these plans.

The dangerous goods that must have an ERAP are identified in Column 7 of Schedule 1 and in Part 7 of the TDG Regulations.

Transport Canada has published guides about ERAPs, including a “Guide to find out if you need an emergency response assistance plan”.

Column 7 of Schedule 1 lists the specific threshold (ERAP Index) when an ERAP is required. This threshold varies for different dangerous goods.  For example, the ERAP Index for “UN1076, Phosgene, Class 2.3(8)” is 25 L while that for “UN1075, Liquefied Petroleum Gases, Class 2.1” is 3000L. See the Table below for these examples (the ERAP Index values are highlighted in green). If a shipment contains a quantity of a dangerous good below its ERAP Index, a formal ERAP is not required.

Schedule 1: Requirements for UN1075 & UN1076

ERAPs should be prepared by a competent person who has knowledge about that dangerous good as well as safety and emergency response. They can be created by producers, manufacturers, or distributors of dangerous goods. If the organization does not have the expertise to prepare an ERAP, industry associations, consulting firms (with expertise in TDG), or similar organizations should be contacted for assistance.

Transport Canada has prepared a “Guide to help you prepare your emergency response assistance plan”.  Part of an ERAP is to document a potential incident analysis.  See Transport Canada’s “Potential incident analysis format example”.

For guidance on the preparation, application, and approval process of an ERAP, please see the guides listed in this document or contact Transport Canada:

Transportation of Dangerous Goods
Transport Canada
330 Sparks St.
Ottawa, ON K1A 0N5
Help with your ERAP application
Email: ERAPapplications@tc.gc.ca
Tel: 613-220-8749
TTY: 1-888-675-6863

Yes. Once the ERAP is prepared, it must be submitted to Transport Canada for approval by using the ERAP online services (EOS).

Follow the steps as outlined in Transport Canada's Guide to apply for approval of an emergency response assistance plan.

Transport Canada will review the application and return a decision (i.e., interim approval, approval, temporary approval, refusal, or revocation). The length of the approval will also be communicated. The length of the approval can vary depending on various factors such as public safety, shipment frequency, modes of transportation, geographic area, etc.

The ERAP reference number and ERAP telephone number must be included on the shipping documents.

As mentioned, formal ERAPs are required when the dangerous good is listed in Schedule 1 or Part 7 of the TDG Regulations. 

While there is no formal process, it is good practice for consignors who ship non-ERAP dangerous goods to have a response plan that will be used in case of spills, etc. These plans will help to:

• protect the public from being exposed to dangerous goods
• minimize damage to the environment as per the requirements in the environmental legislation/s
• demonstrate due diligence for various legislation (e.g., health and safety, environment, etc.

Thus, many consignors provide emergency response information along with the shipping document. This information can be in the form of a safe operating procedure (SOP), information from the Emergency Response Guidebook (ERG), and/or the Safety Data Sheet (SDS) for the dangerous good.

The Emergency Response Guide identifies the significant potential hazards and gives information and guidance for initial actions to be taken based upon the material involved. It was developed for use by first responders (e.g., police, fire, and ambulance services). It can be used in combination with the company’s safe operating procedure for emergencies to determine appropriate safety measures.

Drivers and responders should be trained before transporting or responding to an incident.

During the incident, follow company policies and procedures in the event of an emergency at the scene.  For example, there should be a document containing procedures and emergency telephone numbers of those designated to help manage the consequences of a spill involving a load of hazardous materials.

• Take steps to ensure public safety, if safe to do so.
• Call the appropriate authority (e.g., 9-1-1)
• Call (when registered or listed on the shipping documents), CANUTEC at *666 on a mobile phone, 613-996-6666 or 1-888- CANUTEC 
• The 24-hour number found on the shipping document

Follow company procedures regarding scene management and report the event to the company contact person and enforcement personnel and emergency responders.  Be prepared to inform the responding services of the details of the goods, amounts released (or anticipated release), means of containment, steps taken to secure the area, etc.