2019-2020 Transportation of Dangerous Goods - Inspection Summary

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Background

The objective of the Transportation of Dangerous Goods (TDG) Program is to enhance safety in the transportation of dangerous goods by all modes of transport in Canada. TDG's oversight activities include:

  • inspections
  • regulatory authorizations
  • quality control activities
  • enforcement actions and investigations
  • education, outreach and awareness activities

The goal of the inspection program is to identify threats to public safety and to enforce compliance with the Transportation of Dangerous Goods Act, 1992 (TDG Act) and its regulations (TDG Regulations).

To achieve this, the TDG Directorate inspects commercial sites in Canada that handle, offer for transport, transport, or import dangerous goods (using any mode of transportation). TDG also inspects registered Means of Containment (MOC) facilities (in Canada and abroad). Through an agreement with the Government of Alberta, inspectors from that province inspect TDG sites that transport by road or provincially-regulated railways, as well as highway tank facilities.

Inspection cycle

TDG categorizes all known TDG sites and MOC facilities into risk categories, based on the likelihood and consequences to the public, infrastructure and the environment of a release of dangerous goods. These risk categories each have their own inspection cycle, as illustrated in the table below.

Risk Level TDG Sites MOC Facilities
Very High 1 year 1 year
High 2 years 3 years
Medium 5 years 8 years
Low 8 years 10 years

The following graphs illustrate the number of TDG sites and MOC facilities that fall into each risk category.

TDG sites by risk category. See text description below.
Text description

Percentage of TDG sites for each risk category (total = 21,816):

  • Very high: 1%,
  • High: 7%,
  • Medium: 21%,
  • Low: 53%,
  • Unknown: 18%
MOC facilities by risk category. See text description below.
Text description

Percentage of MOC facilities for each risk category (total = 1,944):

  • Very high: 1%,
  • High: 10%,
  • Medium: 36%,
  • Low: 53%
 

In 2019-2020, TDG Program's inspections were divided into two (2) categories and nine (9) types:

Planned inspections, which made up 81.4% of inspections, consisted of:

  • risk-ranked general compliance inspections
  • risk-ranked MOC facility inspections
  • compliance estimation program inspections
  • major TDG Hub Inspections

Reactive activities, which made up 18.6% of inspections, consisted of:

  • follow-up inspections
  • unplanned MOC facility inspections
  • triggered inspections
  • opportunity inspections
  • consignment inspections

Inspections activities, results and statistics for 2019-2020

TDG conducted 5,313 inspections - with 4,965 inspections at TDG sites and 348 inspections at MOC facilities – of the 5,881 inspections anticipated for the fiscal year.

These inspections found 5,060 non-compliances, resulting in a variety of enforcement actions and risk reductions measures.

Verbal Warning Written Warning Ticket Detention / Grounding Directions / Notices / Orders Public Interest Suspension / Cancelation Ministerial Orders / Interim Orders
4,652 57 40 70 34 2 1

TDG's annual Compliance Estimation Program, a survey of known TDG sites that are regulated under the TDG Act and the TDG Regulations, estimates that 48% of TDG industry was non-compliant in 2019-2020, which represents a 5% drop from 2018-2019 and a 14% drop from 2015-2016.

Rate of Non-Compliance for TDG sites, 2010-2011 to 2019-2020
Text description

Rate of non-compliance for TDG sites by fiscal year since 2010-2011.

  • 2010-11: 38%,
  • 2011-12: 42%,
  • 2012-13: 41%,
  • 2014-15: 56%,
  • 2015-16: 62%,
  • 2016-17: 57%,
  • 2017-18: 55%,
  • 2018-19: 53%,
  • 2019-20: 48%

Most common observations/finding (trends)

According to the results of the Compliance Estimation Program, Part 3 (documentation) and Part 6 (training) of the TDG Regulations, report the highest levels of non-compliance (34% and 22%, respectively). This is in alignment with previous years, with these two parts reporting consistently high non-compliance. Most violations of Part 3 are for provision 3.5 which is the information on a shipping document. Part 6 non-compliance are mostly related to provision 6.1 – training certificate requirements or provision 6.3 - insurance and content of training certificate. Regionally, the largest decreases in non-compliance were in the Atlantic and Pacific regions, as both individually experienced a 15% decline in their non-compliance rate.

Conclusion

In 2019-2020, TDG implemented, or began implementing, several improvements to its oversight program:

  • Significant efforts were undertaken to close sites and facilities that are no longer handling, offering for transport, transporting or importing for transport dangerous goods. Historically, approximately 30-50% of an inspector's planned inspections cannot be conducted because the TDG site or MOC facility is found to be closed or otherwise out of scope (i.e., the site no longer transports dangerous goods as part of its business). Over the coming years, as rigorous efforts are taken to identify and close these sites (i.e., by Data Quality Analysts in each region), it is anticipated that inspectors will encounter fewer of these sites and facilities.
  • In May 2019, TDG initiated a comprehensive review of the tool it uses to assign risk scores to each TDG site. As part of that review, numerous improvements have been identified. A new algorithm for risk scoring and a refined approach for prioritizing inspections based on risk will be developed, which will be implemented as part of the National Oversight Plan for 2022-2023.
  • In March 2020, TDG updated its approach for follow-up inspections. Similar to previous years, an on-site follow-up inspection is considered necessary when there is an identified increased risk to public safety (i.e., the number and severity of non-compliances exceed the defined threshold and suggest that there is a systemic issue indicative of a weak ‘safety culture' at the site). Moving forward, any sites that require a follow-up inspection will automatically be added to the inspection workplan for the following year (i.e., follow-up inspections triggered in 2020-2021 will appear in the inspection workplan for 2021-2022).

Additionally, Transport Canada is planning regulatory amendments to Part 6 (training) of the TDG Regulations, in order to:

  • clarify the training requirements for persons who handle, offer for transport, transport, and import dangerous goods across all modes by developing a competency-based framework for general awareness and function specific training and assessment
  • develop a national training standard outlining the requirements for this competency-based training and assessment, which includes general awareness

These amendments should result in an improvement in the rate of non-compliance found for Part 6.

Contact us

Transport Canada welcomes your comments on this report
Email: tdg-tmd@tc.gc.ca