Proposed Modifications to Transportation of Dangerous Goods Regulations

Transport Canada has been working on a revision of Part 6 of the Transportation of Dangerous Goods Regulations (TDGR) for several years now. This part of the regulations deals with mandatory training related to the transportation of dangerous goods. This section specifies:

• Training requirements
• The content of the training
• The training certificate's content, validity period, and presentation requirements

Transport Canada, after assessing incidents involving the transportation of dangerous goods in Canadian territory between 2014 and 2019, concluded that several injuries and deaths could have been prevented with better training.

In 2021, the federal agency published a proposed regulatory amendment to update Part 6 of the TDG Regulations. However, after receiving extensive feedback from the industry, Transport Canada decided to withdraw the proposal in the summer of 2023. Today, the agency is consulting with industry on publishing a new draft regulatory amendment. Let’s look at some of Transport Canada’s proposed changes in 2021, as well as industry feedback.

Proposed Changes

One of the key changes proposed by Transport Canada to the Transportation of Dangerous Goods Regulations is the requirement for trained personnel to receive "General Awareness Training" in addition to "Function-Specific Training" and "Related Assessments". The specifics of this training would be defined in the Canadian General Standards Board (CGSB) standard CAN/CGSB-192.3-2020, Transportation of Dangerous Goods—Training, Assessment and Competency.

The implementation of this standard will be part of the TDG regulations. It stipulates that the evaluation of proficiency must be documented in a "Certificate of Competency", which will supersede the existing training certificate.

Additionally, this standard stipulates that employers should evaluate employees upon the expiration of their certificates to determine if recertification is necessary and keep a record of this for each employee.

Companies would also have to keep a current inventory of the hazardous materials transportation duties carried out by each staff member. This information would be essential for identifying the customized training that each worker needs. Additionally, the list would include performance benchmarks, which would be used when assessing employees when they receive their competency certificates.

Upon the unveiling of the proposed regulatory update, Transport Canada suggested a 12-month implementation period to align with the revised guidelines.

Industry Reception

During the consultation period, a multitude of feedback was received on the proposed regulatory change. Several stakeholders voiced their opinions on the matter.

Regulatory Amendment via a Standard

One criticism of the proposed regulatory amendment is the move towards a reference standard, which was not subjected to public consultation. Incorporating this standard into the regulations would effectively create a de facto regulation without subjecting its contents to public consultation.

Some stakeholders have also expressed concerns about the complexity of incorporating standards into the regulations. Standards may change without undergoing a regulatory amendment process.

General Awareness Training Requirement

One recurring comment was the proposal to require general awareness training on the TDG Regulations. Many stakeholders reported that in many companies, only one or two classes of dangerous goods are handled, and often only under a few UN numbers.

In this context, stakeholders question the true value of general TDG training for employees.

Certificate Amendment

Among the proposed amendments to the Transportation of Dangerous Goods Regulations, several stakeholders expressed concerns about renaming the training document, suggesting that there was no added value.

Numerous individuals expressed their dissent towards Transport Canada’s plan to incorporate codes in this certificate to designate learning areas. They contended that the use of codes renders the certificate perplexing and hard to decipher without a key, potentially causing confusion among employees regarding the permissible tasks they can undertake.

Some stakeholders also brought up the point that the requirement to produce the certificate "on the spot" should not apply to material handlers, since the information is readily available in their workplace and employees are often forbidden from carrying personal belongings.

Cost assessment for businesses

Many stakeholders believe that Transport Canada underestimates the real costs to business when it assesses the amendments to the Transportation of Dangerous Goods Regulations. They mention that creating new training materials internally involves a significant cost, as well as having to train their experts before they can train their employees.

Transport Canada estimated that updating training would take companies about three hours. Many stakeholders considered this estimate to be far too low.

Positive reception of the objective

Many players in the industry expressed their support for the goal of Transport Canada’s proposed regulation, which is to reduce the number of accidents, especially those resulting in injury or death. However, several stakeholders expressed doubt that Transport Canada’s proposed measures could meet this objective.

Transport Canada's Decision

In response to these comments, Transport Canada withdrew its proposed modifications to the Transportation of Dangerous Goods Regulations in the summer of 2023. However, this does not mean that the organization is no longer pursuing its goal of improving training for transporting hazardous materials throughout Canada. Most recently, in March 2025, the federal agency conducted a survey of industry stakeholders to gain a better understanding of the underlying problems.

Undoubtedly, the regulatory requirements for appropriate training for transporting hazardous materials in Canada will undergo modifications in the near future. The specifics of these adjustments are yet to be finalized, but Transport Canada seems committed to clarifying the curriculum.

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