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This report details the results of a Transportation of Dangerous Goods (TDG) Regulatory Sandbox project (the Sandbox project) that was conducted between January 2020 and March 2022. The goal was to see if using electronic shipping documents (e-shipping documents) might be a viable alternative to the mandated paper format for transporting dangerous goods in Canada via air, marine, rail, and road.
The project evaluated whether an equivalent level of safety can be achieved with e-shipping documents. The report analyzes the results of the project and recommends how e-shipping documents can be adopted in a way consistent with the Transportation of Dangerous Goods Regulations (TDG Regulations).
Collaboration and engagement
Establishing and maintaining engagement with groups who might be affected by e-shipping documents is the heart of the Sandbox project. E-shipping documents potentially affect many groups of people including:
- consignors (also known as shippers)
- first responders
- software developers, and
The groups most directly affected are those who transport the dangerous goods (i.e. the carriers) and those who respond to incidents. We used various methods of communication to keep these groups involved throughout the project.
Transport Canada identified companies interested in trialing e-shipping documents and worked one-on-one with them to come up with safe solutions using their existing operating systems. Interviews were conducted with several motor carriers to identify barriers to using shipping documents and opportunities that might arise from using them. In addition, various social media platforms such as Facebook, Twitter, and LinkedIn were used to reach a broader audience to seek participants, provide updates and gather feedback.
As a critical source of information for first responders, a shipping document contains information on the dangerous goods being transported, such as the UN number, shipping name and class of the dangerous goods. This information is vital if there is an incident while the dangerous goods are being transported.
In this study, special focus was given to firefighters because they are often called to the scene for accidents involving dangerous goods. By working closely with the Canadian Association of Fire Chiefs, we were able to actively engage firefighters during all phases of the project. This collaboration has been instrumental in helping to inform the future of emergency response for dangerous goods in Canada.
Strategies to evaluate e-shipping documents
Key parts of our strategy to evaluate the performance, impacts, costs, and benefits of e-shipping documents included:
- testing e-shipping documents by issuing equivalency certificates to allow e-shipping documents instead of paper shipping documents. Equivalency certificates were issued to selected businesses which met specific safety requirements. Permission was granted for the duration of the project (early 2020 to spring 2022). Having companies test e-shipping documents allowed us to assess their performance
- arranging a series of exercises to test the effectiveness of e-shipping documents in emergency response situations. These exercises in the form of simulations focused on communicating shipping document information
- researching international regulations and comparing shipping document practices in other countries
- assessing the readiness of Canada's trucking industry for e-shipping documents
- studying the role of the shipping documents for first responders
- Establishing and maintaining engagement with groups who might be affected, including emergency response personnel, industry representatives, law enforcement personnel, and Transport Canada's provincial, territorial, and regional counterparts
- gathering information and opinions from provincial and federal inspectors across Canada using surveys
We used these guiding principles to determine the best approach for this study:
- It is critical that first responders attending an incident involving dangerous goods be able to access and retrieve information
- The existing shipping document requirements should remain the same, except that the document could be electronic instead of paper. All the information required on the paper shipping document must be displayed on the electronic document and in the order required by the regulations
- Although e-shipping documents have many benefits, companies won't be forced into using them, and Transport Canada will keep the option of submitting paper shipping documents
- Requirements for e-shipping documents should allow for businesses to use their own systems or customize their systems to meet their operational needs rather than specifying software, language, or hardware requirements. No specific technology or system was used for this project because Transport Canada wanted to evaluate a variety of platforms and technologies
- Building a centralized database of shipping documents or a common platform wasn't part of this study
Challenges and context
This project was launched in January 2020, a couple of months before the start of the COVID-19 pandemic. COVID-19 has impacted all areas of Canada's economy, including retail trade, transportation services (notably the air sector), energy, tourism, and manufacturing, which saw many business closures, high job losses and a sharp drop in production.
COVID-19 also increased the severity of vulnerabilities in the supply chain and congestion in the movement of goods. In this context, fewer companies than expected applied and were accepted, which limited the amount of data we collected. Three rail carriers, three road carriers and one remotely piloted aircraft company participated in the Sandbox project.
Travel restrictions due to COVID-19 limited our ability to test e-shipping documents in realistic mock emergency simulations. Two of the rail simulations we tried to organize were hard to arrange due to public health restrictions and the vital importance of ensuring safety at every step.
The impact analysis in this report is based on the latest developments when this report was written.
The shipping document
Through this study, we learned that the shipping document contains more information than required and that some regulatory provisions may be outdated, making complying with the regulations more difficult. The shipping document can also be difficult to understand, especially in an emergency situation.
From an industry compliance perspective, errors on a shipping document consistently account for the largest number of violations in the TDG Regulations. We learned that e-shipping documents can increase compliance.
During software demos with participating companies, some came to realize that their shipping documents didn't comply with the regulations. The project team worked one-on-one with the companies to find any errors and recommend adjustments to ensure compliance.
The different modes of transport in Canada
We researched the four modes of transport (air, marine, rail, and road) to better understand how shipping documents work.
- emergency response information
- isolation distances
- car type, and
- points of interest like schools and hospitals
For road, the state of readiness for e-shipping documents varies. Although there's an interest from road carriers in using e-shipping documents, information management for road transportation is more complex.
It cannot be addressed with a one-size-fits-all solution because road transportation can involve multiple carriers with some using electronic documents and others using paper. The costs associated with investing in the systems and the technology required to transmit dangerous goods information electronically may not be feasible for some road carriers.
Factors such as a lack of consistent internet and cellular coverage throughout Canada, a shortage of funding for first responder technological resources like tablets, and the absence of a centralized data-sharing platform showed that we need to do more research and consultation before allowing e-shipping documents for road transportation.
The marine mode differs from the other modes because an electronic copy of a shipping document is already allowed for dangerous goods transported by vessel. Many marine carriers have electronic information management systems in place, and most international marine commerce is performed electronically. The data exchange language that is used is Electronic Data Interchange (EDI) to allow intermodal transfers with rail carriers.
We could only collect limited information from the conventional air sector due to the impact of COVID-19. We learned that paper shipping documents stay with dangerous goods cargo and aren't provided to the flight crew. Instead, a “Notification To Captain” (NOTOC) is the only document that flight crew have to identify the nature, quantity and location of dangerous goods carried as cargo.
When dangerous goods are transferred from the air carrier to a road carrier, paper copies are needed because trucking companies do not have the legal option to use electronic documents unless they have been granted an equivalency certificate.
One remotely piloted aircraft (RPA) accident simulation exercise was conducted to observe how first responders approach an incident involving a RPA and identify potential areas that pose challenges to response to a downed RPA. Overall, it demonstrated a functional use of e-shipping documents in a rural area with cellular or radio coverage.
E-shipping documents are not widely implemented in other countries
Although some regulations governing international transportation of dangerous goods recognize that electronic documents can be used as an alternative to paper, at the time of this report, they were not widely implemented in most countries.
We learned that Europe is the most advanced and has developed guidelines (Guidelines for the use of RID/ADR/ADN 188.8.131.52) which specify how electronic transport documents should be used. These European countries allow e-shipping documents for road and rail transportation:
- United Kingdom
- Germany, and
Despite being allowed, e-shipping documents are not often used in Europe. When they are, their use is generally limited to in-country transportation. What is interesting about the guidelines is that they detail a data-sharing architecture of trusted parties to ensure that authorities and first responders can access information on request. Work is underway to develop a standard information-sharing platform that can be used across Europe.
While work is still underway to streamline the use of e-shipping documents in Europe, we can draw many strengths from the guidelines as we develop regulations in Canada. What is most important is collaboration between government, industry and first responders to ensure a streamlined approach.
The role of first responders
The ability to test the conversion of traditional hard copy shipping documents to digital format identified a unique set of challenges for first responders. For example, until there is consistent cellular or internet coverage across Canada, accessing a digital document can be especially challenging in remote or other areas with limited cellular or internet access.
Another concern is that many fire departments have very limited or no funding for equipment like tablets and cell phones. This lack of funding needs to be considered before allowing widespread use of e-shipping documents.
Across Canada, dangerous goods training varies by department and municipality. Through the different surveys and studies, we found that many firefighters have limited awareness of dangerous goods and that they don't see a lot of shipping documents.
As such, it's hard for them to compare paper vs electronic documents. Shifting to e-shipping documents would require training with firefighter schools across Canada.
CANUTEC is a public entity within the Transportation of Dangerous Goods Program and plays a central role in supporting first responders. Through surveys, interviews and rail derailment simulations, firefighters consistently mentioned that CANUTEC is a valuable resource.
Based on the findings of this project, we will:
- modernize parts of the Transportation of Dangerous Goods Regulations that refer to shipping documents to reduce administrative burden and to allow the use of e-shipping documents initially for transport by rail and by remotely piloted aircraft (RPA)
- develop an approach, including a possible central repository, for the use of e-shipping documents in the Transportation of Dangerous Goods Regulations and ultimately allow e-shipping documents for all modes of transport
- look at increasing CANUTEC's role in helping first responders throughout the transition to e-shipping documents
- continue working with international and U.S. partners on the implementation of a global approach for the use of e-shipping documents in the transportation of dangerous goods
The complete report on the use of electronic shipping documents for the transport of dangerous goods is available upon request.