Regulatory Affairs
March 20, 2020

UPDATE: Federal – Transport Canada selects CPA for peer review of TC regulations

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Transport Canada has selected the CPA to participate in a peer review of certain issues in the TC regulations. The CPA’s feedback, along with other industry responses, will be used to determine which issues will receive funding for the review. After discussions with ERAC, the CPA proposed the following projects toTC; the list does not include supporting the PRV project considering members have initiated this project within the industry.

Key issues that TC has put forward for peer review are:

1. Analysis of considerations for the development of TankFax, a database of vehicle histories of highway tanks in Canada. 

Objective: To evaluate and improve current safety standards and safety requirements for in-use highway tanks by:

  • determining if TC should participate in the TankFax initiative jointly with the United States to have a North American-wide database of vehicle histories of highway tanks;
  • analyzing the hurdles that would exist in the implementation of a TankFax system in Canada (e.g., privacy concerns, the definition of accident differing between the U.S. and Canada); and
  • determining the ownership of the collected data in a TankFax initiative (e.g., government, private industry, or a combination of both).

2. Evaluation of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC) Section XII requirements for the manufacture and continued service of highway tanks in Canada.

 Objective: To improve safety standards and safety requirements for highway tanks, this project would inform a decision regarding the acceptance of highway tanks in Canada designed in accordance with ASME’s BPVC Section XII, Rules for Construction and Continued Service of Transport Tanks (“ASME Section XII”).

3. Submitted by the CPA - Evaluation of CG-7 pressure-relief devices for cylinders to consider the possible extension of the requirement for replacement/re-test within 10 years of the date of manufacture. 

Objective: To determine if CG-7 pressure relief devices on TC4BWM propane cylinders up to 450 L in water capacity will reliably protect the cylinder from overpressure scenarios beyond the initial 10-year replacement or re-test interval as set by the safety standards.

4. Validation of recommended emergency actions for liquefied natural gas (LNG) in the Emergency Response Guidebook (ERG).

Objective: To determine if the recommended emergency actions for LNG in the ERG are suitable by comparing the properties of, and the risks associated with, incidents involving LNG and liquefied petroleum gases (LPG) for the purpose of improving safety requirements (e.g., emergency response assistance plan (ERAP) requirements) for LNG.

5. Review of the recommended distances for boiling-liquid expanding-vapour explosions (BLEVEs) in the Emergency Response Guidebook (ERG).

 Objective: To improve safety requirements (e.g., ERAP requirements) for dangerous goods with potential for BLEVE by considering the following and their possible impact on the recommended distances in the ERG for BLEVE events:

  • changing safety standards, including new types of means of containment made of composite materials;
  • data from actual BLEVE events and/or further testing with means of containment of varying sizes; and
  • analysis of risks, including for shelter-in-place versus evacuation.

6. Comprehensive review of the criteria and thresholds for emergency response assistance plans (ERAPs) in the Transportation of Dangerous Goods (TDG) Regulations.

Objective: To improve safety requirements regarding ERAPs by: 

  • developing a hazard- and risk-based assessment tool/algorithm for systematically establishing ERAP requirements for the nine classes of dangerous goods; and
  • conducting a full review of criteria and thresholds for ERAPS currently in the TDG Regulations in order to reflect today’s TDG landscape.

7. Development of a geographic-information-system (GIS) based risk assessment methodology for the transport of dangerous goods by road.

Objective: To improve safety requirements for the transport of dangerous goods by road through the development of a GIS-based risk assessment methodology that provides:

  • link-level risk assessment of the national road system in Canada, where each link represents a two- to five-kilometre section of the highway network; and
  • optimized risk mitigation solutions for the identified high-risk areas. 

8. Consideration of human factors in TDG training requirements.

Objective: To improve safety requirements for training by considering human factors in TDG training requirements. 

Should you wish to provide information or insight on any of these issues, please contact CPA Vice-President of Regulatory Affairs and Safety Robert Loenhart at


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