Client Identification Database (CID)

Slide 1 : Title page

Welcome to this video from Transport Canada on the Transportation of Dangerous Goods Regulations (or TDG Regulations) – Part 17, Site Registration Requirements.

Slide 2: Table of contents

In this video, we’ll review the background and benefits of the Part 17, site registration requirements. We’ll look at exemptions and offer a precise definition of what is considered a “site” as well as what else is included in the regulation, such as the yearly renewal of the registration and requirement to update administrative information.

Slide 3 : Why these new requirements?

Let's start with the big question first.

Why have these new requirements been introduced to the TDG Regulations?

In 2006 The Transportation of Dangerous Goods (or TDG) Directorate did a self-assessment of the program, which was followed in 2011 by an audit of TDG program conducted by the office of the Commissioner of the Environment and Sustainable Development (or CESD).

The self-assessment and the audit resulted in the same observation:

• Transport Canada did not have sufficient information to understand the risks of some premisesand operations, or the means to collect such information; and
• Transport Canada did not have the tools to assess risk and properly evaluate priorities for the risk-based oversight program. 

Following the 2011 audit, the CESD recommended that Transport Canada develop and implement a national risk-based system to prioritize its inspections of sites operated by persons involved in dangerous goods activities.

When referring to Dangerous goods activities, we mean: a person who imports, offers for transport, handles, or transports dangerous goods. The TDG Act defines a “person” as an individual or an organization.

Next, came extensive consultation over the following years and a policy was approved by TDG Program authorities.

In 2019, the CESD came back with a second audit to assess Transport Canada’s improvement on their first recommendation and published a full report in 2020.

While the CESD acknowledged in its 2020 audit report that Transport Canada had developed an inspection program, the CESD concluded that it still did not have a complete and accurate picture of its TDG community and that the information on many Sites was incomplete, inaccurate and/or out-of-date.

The 2020 report included more formal recommendations such as the improvement of the national risk-based system to prioritize its inspections and the development of a database for the regulated community.

Their second set of recommendations was the key driver for Transport Canada to proceed with the regulatory amendment and build the Database (called Client Identification Database or CID).

Slide 4: Benefits of Part 17

Some of the benefits of Part 17 include:

• Better knowledge of the regulated community
• Geographical mapping of sites
• Broader risk analysis
• Better informed decision making
• Enhanced efficiency of oversight framework
• And promoting compliance

All of which result in reducing the likelihood or severity of incidents on sites.

Slide 5: What are the exemptions?

It is important to note that exemptions to registration will be permitted only when all the dangerous goods at a Site are covered by any of the exemptions, so if one dangerous goods at a site is not exempt, then that site must be registered. Being exempted from the registration requirements does not exempt the person from the regulations themselves or from being inspected by a TDG inspector.

Let’s have a look the 6 exemptions:

The first exemption applies when a person is involved in dangerous goods activities under any of the Special Cases listed under Part 1 of the TDG Regulations other than:

• Section 1.16 – 500 kg Gross Mass Exemption;

In other words, if you use section 1.16 of the TDG Regulations for your dangerous goods activities, the site registration exemption cannot apply and the organization is required to register its sites.;

The second exemption applies when a person is involved in dangerous goods activities which are exempted under a provision that exempts the Regulations in Schedule 2 of the TDG Regulations.

The third exemption applies when a person conducting cross border movements does not have a headquarters or owns/operates a dangerous goods site in Canada, such as third-party providers and freight forwarders.

The fourth exemption applies to foreign carriers operating cross-border movements that do not have a headquarters or own or operate a Site in Canada where dangerous goods activities take place.

The fifth exemption applies to a person involved in dangerous goods activities that are in quantities necessary for a federal, provincial or municipal officer to carry out their duties with respect to the enforcement of federal, provincial or municipal law (a concrete example of this would be a law enforcement premises such as police station).

And exemption 6 applies to Oil and Gas industry extraction premises, such as wells and well pads.

Slide: What is considered a site?

Considering why these new requirements have been put in place and the exemptions, let’s look at the core of the regulatory requirements…

The sites!

The TDG Regulations introduced a definition of “Site” which means a permanent location where dangerous goods are imported, offered for transport, handled or transported and are in the direct possession of a person conducting these activities, but does not include a location where dangerous goods are used only in the scope of a person’s work or as raw materials in products that they manufacture.

Let’s look at some concrete examples.

For marine transport, the definition of Site includes locations where dangerous goods are being loaded and unloaded but does not include a warehouse or a vessel (meaning a boat, a ship or a craft), even if docked at the port. For example, a common-use terminal will be registered as a Site. For ports where there is no terminal, the port will be registered as the Site.

In the context of air transportation, since dangerous goods are loaded onto and unloaded from aircraft at a company’s respective common-use cargo terminal, the location to be registered will be associated with the cargo terminal. For smaller airports with no distinct cargo terminal, the airport will be registered as a Site. In these cases, any road vehicle, such as aircraft refuellers, or aircraft sitting at the airport are not considered Sites.

However, any permanent location where dangerous goods are imported, offered for transport, handled, or transported would be considered a site. This would mean that there are locations which meet the definition of a site but are not specifically a "cargo terminal" or "airport". For example, lodges, fishing outpost camps and some mines.

In addition, warehouses storing dangerous goods to be used by the airport do not have to be registered as Sites as this type of storage is not considered as in transport as per the TDG Regulations.

For rail transport, Sites include any rail terminal that receives dangerous goods to be loaded on a train as well as any location where dangerous goods are offloaded from a train and transferred to another means of transport. Sites also include rail yards where rail cars are coupled into a train. Warehouses where dangerous goods are stored (not in transport) and sidetracks do not fall under the scope of Site. Stations where trains are only passing through without any handling of dangerous goods will not be required to register as Sites.

For the oil and gas industry, Sites include the terminals, refineries, and distribution centers where Dangerous Goods activities are conducted with the intent of being transported.

When looking at the definition of “Site” we can conclude that the following are also exempted from the registration requirements:

A consignee of dangerous goods, which is also an end user, such as a facility receiving chemicals for their scope of work, temporary construction sites or forest harvesters temporarily storing fuel on a harvesting area to be used in their harvesting.

For the freight forwarding industry, if the person offering for transport is never in direct possession of the dangerous goods, this person will not be required to register. Specifically, when they are only handling paperwork.

Please note that

Slide 7: What else is included in the new Regulation?

In addition to what is included in the regulation, let’s review the information that needs to be provided, discuss the yearly renewal, the requirement to update administrative information, as well as the one-year transitional period.

Slide 8: Yearly renewal and Administrative Information Requirement

A person must renew their registration annually within 30 days of the anniversary date of their initial registration by validating or, if applicable, updating the information referred to in subsection 17.3(2).

This includes:

• the business number assigned to them by the Canada Revenue Agency, if any;
• their name and the address of their headquarters;
• the phone numbers and email addresses of both a contact person and their replacement when absent;
• the addresses of all sites where dangerous goods are imported, offered for transport, handled or transported;
• the mode of transport of dangerous goods used at each site;
• for each site, the classes and divisions of dangerous goods that were imported, offered for transport, handled or transported within the previous fiscal year, if any;
• and for each site, the importing, offering for transport, handling or transporting activities that were undertaken in the previous fiscal year, if any.

As part of the registration, the organization’s primary contact will need to be identified.

Primary contacts are responsible for initiating the registration, making administrative changes, and updating the administrative information, as needed. The primary contact will also be responsible for the organization’s information in the online Client Identification Database.

The difference between the Primary Contact and Secondary Contacts is the access level to edit information in the online platform:

• The primary contact can make any changes to information at the organization level and the sites.
• Those listed as Secondary Contacts will have access to change site level information only, for example, , updating and attesting site information.

A person must also update within 60 days after the day on which any change occurs, their administrative information provided under paragraphs 17.3(2)(a) through (e) on their initial registration or annual renewal.

This can be done through the TDG Client identification Database platform available online.

It is important to note that Transport Canada is giving you flexibility to choose your anniversary date by providing a 12-month transition period. This means, you can align your reporting requirements with any other reporting you might have to comply to.

Slide 9: What’s Next?

In closing, let’s review the timeline and see what is next.

Publication in Part II of Canada Gazette took place on October 25th, 2023.

The Registration Database and guidance documents were published online at the same time which started the registration timeline.

The end of the transition period will be October 25th, 2024.

Slide 10: Wrap up and contact info

Thank you for taking the time to review this video. If you have additional questions about the requirements of part 17 or want to know more about using the online platform, check out the Frequently Asked Questions section, review the CID user guide or use the “contact us” link available online.