Interpretation Policy Improvement Priorities (2015-2017)

I. Introduction

In Transport Canada’s Regulatory Interpretation Policy, published December 19, 2014, the department committed to check in with stakeholders on current interpretation practices and identify areas for improvement and metrics for evaluating their implementation. Transport Canada also committed to implement these improvements within two years and update Canadians on performance in implementing these improvements by March 31, 2017.

In consultation with key stakeholders, Transport Canada has undertaken joint efforts to identify areas for improvement related to the department’s current regulatory interpretation policies and practices. The areas identified led to the creation of this Regulatory Interpretation Improvement Plan for the purpose of improving regulatory interpretation practices.

It should be noted that the Improvement Plan is an evergreen document which will be reviewed on a regular basis.

II. Improvement Plan

Transport Canada has assessed its current interpretation practices, and, with stakeholder input, identified the need to improve several areas, including predictability, stakeholder engagement, and service.

Transport Canada will implement these improvements over the next two years and will update Canadians on progress each year until March 31, 2017.

Performance will be measured through an annual questionnaire wherein targeted stakeholder organizations will be asked to assess their satisfaction with Transport Canada’s interpretation practices.

2.1. Improving Predictability

Providing Guidance and Building Awareness

Transport Canada will:

  • Update Railway Safety Management System Regulations (SMS) FAQs to avoid any confusion between both (2001 and 2015 SMS regulations) links referred in the interpretation policy;
  • Update the Railway Safety Act Compliance and Enforcement Policy with a new Oversight Policy to include the Administrative Monetary Penalties (AMPs) and the Railway Operating Certificate (ROC);
  • Transfer the content of Transport Canada’s website, which is currently accessible to the public, to the Canada website ( within a few months. At that point, it will be easier to find information to aid in the interpretation of transportation regulations;
  • Create this year a Safety Awareness team within the Transportation of Dangerous Goods Directorate to develop tools and materials to help the public better understand the Transportation of Dangerous Goods Regulations.

2.2. Stakeholder Engagement

Stakeholder Engagement

Transport Canada will:

  • Continue to engage stakeholders through existing consultation mechanisms. In addition, other engagement methods such as webinars, teleconferences and surveys will take place across Canada to gauge stakeholders’ satisfaction in this regard;
  • Transport Canada’s Civil Aviation Directorate will seek stakeholder input on advisory circulars, where appropriate, and when a lack of internal technical expertise has been identified to provide advice.

2.3. Service

Staff Training

Transport Canada will:

  • Create a Transportation of Dangerous Goods (TDG) subcommittee of the National Compliance Working Group to harmonize dangerous goods training for TDG inspectors across Canada;
  • Provide training to all inspectors and employees who carry out oversight activities on behalf of the Minister of Transport in order to enhance consistency in the interpretation and enforcement of transportation regulations.