How to apply and renew to manufacture aerosol containers and gas cartridges

Obtain a copy of the applicable standard, CGSB 43.123 from the CGSB. Once obtained, review the standard, in particular the design and manufacture sections to make sure your facility is in compliance.

Clause 7 of CGSB 43.123 then lays out the registration requirements and what must be submitted in your application for registration with Transport Canada.

If you are in the business of making DOT specification aerosols in accordance with 49CFR, note that the primary differences between 49CFR and CGSB 43.123 requirements are:

1. Requirements of what must be submitted for registration (Clause 7)
2. The marking that must be on the can
3. If you are making plastic aerosols, CGSB 43.123 requires a 4^th batch of samples conditioned at low temperature for the drop test.

Examples of the type of information expected to be submitted for each part of Clause 7 are below. If successful, you will receive a Certificate of Registration for your facility.

Submit the application via email to MOCRegister-RegistreContenant@tc.gc.ca.

CGSB 43.123 Clause 7.2 Initial Registration

7.2.1 A manufacturer of aerosol containers and/or gas cartridges shall obtain a Certificate of Registration from the Director prior to the application of markings in compliance with Section 5 of this standard. The registered manufacturer must perform its functions at the location stipulated on the Certificate of Registration unless the Certificate authorizes the facility to conduct these activities elsewhere.

• Submit a sample marking that demonstrates that the requirements of Clause 5 are met. See Clause 5.1 of CGSB 43.123 for what is required. The markings must make the can traceable to the manufacturing facility where it is made.

7.2.2 The following information shall be submitted in the application for registration:

1. Name, address and telephone number and email address of the applicant
   • Include a business license or registration that shows the legal name of the company.
   • Indicate the specification of cans the facility will manufacture (specify TC-2P, TC-2Q, etc)
   • Include an example drawing of a can for each specification identified to enable verification that the requirements of the standard for wall thickness, diameter, openings, etc. have been met.
2. Symbol of the applicant, if applicable
   • Indicate what the symbol used on the cans will be. This can be an M# that has been assigned to the applicant by the US DOT, any symbol or company name. This symbol must be printed on the can as per Clause 5 of CGSB 43.123. If successful in the application process, this symbol will serve as the registered mark on the Certificate of Registration issued to the company.
3. Description of the manufacturing processes
   • Include a description of how the cans are manufactured as well as the material used. A procedure or flowchart are examples of documents that would demonstrate the process.

4. If the quality management system conforms to the requirements of ISO 9001 and is registered with a quality management registrar accredited or recognized by the Standards Council of Canada (SCC), or a foreign quality assurance systems registrar recognized by the SCC, a copy of the quality management system Certificate of registration shall be submitted.

   • ISO 9001 Certificate of registration

   If the facility does not have a registration to a quality assurance system, then documentation in accordance with Clause 6 in the form of a manual, procedures, work instructions, checklists or forms that address each of these items:

   • Relevant inspection and test, quality control, quality assurance, and process operation instructions that will be used, including but not limited to:
     • Purchasing of raw materials and inspection of incoming product
     • Material identification and traceability
     • Marking
     • Inspection and testing
     • Finishing processes (e.g. painting, labeling)
     • Control of monitoring and measuring devices (calibration of equipment and devices used in the manufacturing, inspecting, and testing of cans)
   • Quality records, such as inspection reports, test data, calibration data and certificates. The procedures must address the lot testing that is required by CGSB 43.123 for the specifications being made, examples are burst testing, leak testing, drop testing.
   • Management reviews to ensure the effective operation of the quality system, including but not limited to internal audits
   • Process for control of documents and their revisions, including but not limited to a record retention policy
   • Means for control of non-conforming containers;
   • Training programs and qualification procedures for relevant personnel; and
   • Procedures to ensure that there is no damage to the final product, including but not limited to:
     • Monitoring and measurement of product
     • Preservation of product

CGSB 43.123 Clause 7.4 Application for renewal

To renew a Certificate of Registration, the certificate holder must submit a written application for renewal in accordance with clause 7.4 of the CGSB 43.123 standard, at least 3 months prior to expiry of the existing registration. The renewal application must indicate any changes to the information included in the initial application. If there are no changes, a statement to that effect should be made in the renewal application.