Form amendment: Application for review of dangerous goods policies and procedures and trainings programs

From: Transport Canada

Transport Canada’s Transportation of Dangerous Goods (TDG) Directorate has completed a review of Form 16-0090 for air operators submitting their dangerous goods policies, procedures and training programs for approval.

This bulletin is intended to inform air operators of the change to Form 16-0090 - Application for the Review of Dangerous Goods Policies & Procedures and Training Programs.

Relevant information about the changes made to Form 16-0090 can be found below.

Description of amended form 16-0090

Form 16-0090 was revised and published in 2021. This new version is more efficient and user friendly. It was modified based on feedback from inspectors and industry, and incorporates any applicable regulatory changes.

Key changes to the revised form include:

amending the terminology to harmonize with the Canadian Aviation Regulations, the International Civil Aviation Organization (ICAO) and the Canadian General Standards Board (CGSB) CAN/CGSB-192.3-2020 Transportation of dangerous goods training, assessment and competency. For example, special authorization will now be referred to as specific approval and evaluation will be referred to as assessment
removing all references to categories of staff as training programs based on categories of staff are no longer found in the 2023-2024 edition of the ICAO Technical Instructions. Therefore, section C1 does not refer to categories of staff and the corresponding column was removed from Part C. However, to assist air operators who have difficulty determining the task of their personnel, examples of roles and responsibilities related to each task were included
adding a third option in Section A3 for identifying the type of submission (i.e. review of the TDG Procedures and Policies and/or TDG Training Program). Air operators can choose between “New”, “Amendment” or “No Amendment”. When “New” or “Amendment” is selected, the form will prompt you to complete Part B and/or Part C. When ‘’No Amendment’’ is selected, the form will automatically indicate “No Change” in all columns in Part B or C. The air operator will no longer need to complete that part by clicking “No change” in each row/field
enabling air operators who submit multiple training programs at one time for review to no longer complete a full Form 16-0090 for each training program, only additional Part Cs. In the forms catalogue, there will be two forms 16-0090: one containing Parts A to D and the other only Part C. The benefit to this is that Part A will only need to be completed once and only one document will be used for the company file
removing inapplicable/inappropriate options. In Part C, when requirements apply to all TDG Tasks, the option “Not Applicable” will not be permitted. Air operators will only be able to select either “No Change” or ‘’Section and page’’
merging certain requirements to simplify the completion of the form. For example, in C7 (Training requirements: Classification), one entry replaced nine similar entries pertaining to the classification of classes 1 to 9
conducting a review of the numbers in column “TDG tasks’’ of Part C to better guide operators in identifying the knowledge components their personnel need to be competent to perform their dangerous goods tasks
removing Task 7, which addresses the collection of safety data, in most entries. The previous form included Task 7 in almost all entries which required personnel responsible for collecting safety data to be trained in all knowledge aspects which may not be necessary or reasonable. However, the air operator must ensure that these personnel will have the necessary knowledge to complete a report on dangerous goods accidents, incidents and occurrences or undeclared/misdeclared dangerous goods. All persons involved in the transport of dangerous goods should know what to do in these situations occur

Clarification on the contents of the submissions

Air operators who structure their training programs in separate modules adapted to various tasks and/or personnel should specify which modules apply to which tasks or personnel.

Air operators who submit multiple training programs in the same submission will get their approval once all documents have been reviewed by the TDG inspector.

Air operators who do not submit their training program(s) and procedures and policies for revision may be requested to submit the corresponding document(s).

From 2023/01/01

The amended Form 16-0090 will be effective and available online on January 1 2023, for air operators to submit their application for the review of dangerous goods policies, procedures and training programs. From January 1, 2023 to March 31, 2023 air operators may continue to use the previous version of Form 16-0090. As of April 1, 2023, only the amended form can be used for any TDG document review request.

Note that Form 16-0090 will be revised and published again when Part 6 of the Transportation of Dangerous Goods Regulations is amended in Spring 2023 and comes into effect 12 months following publication.