Temporary certificate TU 0752.1: Hand sanitizer

Temporary certificate pursuant to Subsection 31(2.1) of the Transportation of Dangerous Goods Act, 1992

Certificate Number: TU 0752 (modification 1)

Pursuant to subsection 31(2.1) of the Transportation of Dangerous Goods Act, 1992 (TDG Act) the Minister may, in the public interest, issue a temporary certificate authorizing any activity to be carried on in a manner that does not comply with the TDG Act.

Following the declaration of a pandemic outbreak of a novel coronavirus (COVID-19) by the World Health Organization, on March 11, 2020, Canadian industry has been asked to reorganize its operations to manufacture essential medical supplies such as masks, ventilators and hand sanitizer.

Many of the new producers of hand sanitizers do not have the required transportation of dangerous goods (TDG) training or the appropriate resources to handle, offer for transport or transport dangerous goods, such as hand sanitizer, in compliance with the TDG Act.

To respond to this unprecedented situation, the Minister authorizes the handling, offering for transport, or transport of hand sanitizer by issuing a temporary certificate under subsection 31(2.1) of the TDG Act. This certificate takes into account existing safety and TDG requirements and the fact that these new producers of hand sanitizers are not familiar with these requirements.

In my opinion, the issuance of a temporary certificate is in the public interest and I hereby authorize the handling, offering for transport, transport, or importation of dangerous goods in a road vehicle, railway vehicle or a vessel between two points in Canada in a manner that does not comply with, either:

  • Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks), Part 5 (Means of Containment), Part 6 (Training) and Part 8 (Reporting Requirements) of the Transportation of dangerous goods Regulations (TDG Regulations) when the capacity of the means of containment is less than or equal to 30 litres; or
  • Part 3 (Documentation), Part 6 (Training) and Part 8 (Reporting Requirements) of the TDG Regulations when the capacity of the means of containment is greater than 30 litres but less than or equal to 450 litres.

This temporary certificate is subject to the following terms and conditions:

1. General Conditions

These conditions apply to the handling, offering for transport or transportation of dangerous goods listed in this certificate.

  1. The dangerous goods are one of the following:
    1. UN1170, ETHYL ALCOHOL SOLUTION or ETHANOL SOLUTION containing at least 60% ethanol by volume but not more than 80% ethanol by volume,
    2. UN1219, ISOPROPYL ALCOHOL or ISOPROPANOL containing at least 60% isopropanol by volume but not more than 80% isopropanol by volume,
    3. UN1987, ALCOHOLS, N.O.S., containing at least 60% ethanol and/or isopropanol by volume but not more than 80% ethanol and/or isopropanol by volume;
  2. The dangerous goods will be used as a hand sanitizer;
  3. The person handling, offering for transport or transporting the dangerous goods must be familiar with the conditions of this temporary certificate.

2. Specific conditions - volume less than or equal to 5 litres

In addition to the general conditions, the conditions provided for in paragraphs a) to f) below apply to the handling, offering for transport, or transport of dangerous goods in quantities less than or equal to 5 litres:

  1. The dangerous goods are placed in a combination packaging with an outer and inner means of containment;
  2. Each outer means of containment has a gross mass that is less than or equal to 30 kg and the dangerous goods in the inner means of containment have a volume that is less than or equal to 5 litres;
  3. The dangerous goods are placed in a means of containment that is designed, constructed, filled, closed, secured, and maintained so that under normal conditions of transport, including handling, there will be no accidental release of the dangerous goods that could endanger public safety;
  4. The Class 3 flammable liquid label, as illustrated below and described below, must be displayed on any side of the outer means of containment, other than the side on which it is intended to rest or to be stacked during transport:
    1. Class 3 flammable liquid label
    2. Each side of the label must be at least 100 mm in length;
    3. If a 100 mm label cannot be displayed because of the irregular shape or size of the means of containment, each side of the label may be reduced in length by the same amount to the point where the label will fit that means of containment, but must not be reduced to less than 30 mm.
  5. Despite paragraph d), the label required on the outer means of containment may be replaced by one of the following:
    1. "Hand sanitizer - flammable" or "Désinfectant pour les mains – inflammable";
    2. "Hand sanitizer - contains ethanol" or "Désinfectant pour les mains – contient de l'éthanol";
    3. "Hand sanitizer - contains isopropanol" or "Désinfectant pour les mains – contient de l’isopropanol".
  6. When outer means of containment are placed in an overpack or in a container, and the information required by paragraphs 2)d) or 2)e) above is not visible through the overpack or container, the following information must be displayed on two opposite sides of the overpack or container:
    1. The information required by paragraphs 2)d) or 2)e), and
    2. The word "Overpack" or "Suremballage", in letters that are at least 12 mm high

3. Special conditions - volume greater than 5 litres but less than or equal to 30 litres

In addition to the general conditions, the conditions provided for in paragraphs a) to e) below apply to the handling, offering for transport, or transport of dangerous goods in quantities greater than 5 litres but less than or equal to 30 litres:

  1. Each means of containment has a volume of more than 5 litres but less than or equal to 30 litres;
  2. Each means of containment must:
    1. comply with the requirements of Part 5 of the TDG Regulations, or
    2. be placed and secured in crates, cages, carts, boxes, or similar overpacks and must be designed, constructed, filled, closed, secured and maintained so that under normal conditions of transport, including handling, there will be no accidental release of the dangerous goods that could endanger public safety;
  3. The Class 3 flammable liquid label, as illustrated below and described below, must be displayed on any side of the means of containment, other than the side on which it is intended to rest or to be stacked during transport:
    1. Class 3 flammable liquid label
    2. Each side of the label must be at least 100 mm in length;
    3. If a 100 mm label, cannot be displayed because of the irregular shape or size of the small means of containment, each side of the label may be reduced in length by the same amount to the point where the label will fit that small means of containment, but must not be reduced to less than 30 mm.
  4. Despite paragraph c), the label required on the outer means of containment may be replaced by one of the following:
    1. "Hand sanitizer - flammable" or "Désinfectant pour les mains – inflammable";
    2. "Hand sanitizer - contains ethanol" or "Désinfectant pour les mains – contient de l'éthanol";
    3. "Hand sanitizer - contains isopropanol" or "Désinfectant pour les mains – contient de l’isopropanol".
  5. When means of containment are placed in an overpack or in a container, and the information required by paragraphs 3)c) or 3)d) above is not visible through the overpack or container, the following information must be displayed on two opposite sides of the overpack or container:
    1. The information required by paragraphs 3)c) or 3)d), and
    2. The word "Overpack" or "Suremballage", in letters that are at least 12 mm high;

4. Special conditions - volume greater than 30 litres but less than or equal to 450 litres

In addition to the general conditions, the conditions provided for in paragraphs a) to d) below apply to the handling, offering for transport or transport of dangerous goods in quantities greater than 30 litres but less than or equal to 450 litres:

  1. Each means of containment has a volume of more than 30 litres but less than or equal to 450 litres;
  2. The dangerous goods are accompanied by a document providing the following information:
    1. The words "Hand Sanitizer classified as:" along with the appropriate applicable description, either:
      1. UN1170, ETHANOL SOLUTION, Class 3, PG II;
      2. UN1170, ETHYL ALCOHOL SOLUTION, Class 3, PG II;
      3. UN1219, ISOPROPANOL, Class 3, PG II;
      4. UN1219, ISOPROPYL ALCOHOL, Class 3, PG II;
      5. UN1987, ALCOHOLS, N.O.S. (ethanol), Class 3, PG II; or
      6. UN1987, ALCOHOLS, N.O.S. (isopropanol), Class 3, PG II;
  3. The person handling, offering for transport or transporting the dangerous goods must:
    1. Possesses a valid training certificate as per Part 6 of the TDG Regulations;
    2. performs those activities in the presence and under the direct supervision of a person who is adequately trained as per Part 6 of the TDG Regulations, or
    3. be assisted, either in person or by phone, by a person who is trained as per Part 6 of the TDG Regulations. The contact information of the person providing assistance must be given to an inspector immediately upon request.
  4. A paper or electronic copy of this temporary certificate accompanies the dangerous goods during transport and must be provided to an inspector or a peace officer immediately upon request.

Unless the context requires otherwise, words and expressions used in this certificate have the same meaning as in section 1.4 of the TDG Regulations.

For greater certainty, this temporary certificate provides no regulatory relief other than specifically stated herein. Therefore, all other requirements of the TDG Act and the TDG Regulations apply.

For greater certainty, this certificate TU 0752 (Modification 1) replaces the Temporary Certificate TU 0752.

This temporary certificate takes effect on April 23, 2020. It remains in effect until the earliest of:

  • September 30, 2020, or
  • the day it is cancelled in writing by the Minister of Transport.

Benoit Turcotte
Director General
Transportation of Dangerous Goods Directorate
Transport Canada

Date: April 23, 2020

For more information:
Approvals and Special Regulatory Projects
Transportation of Dangerous Goods,
Transport Canada
300 Laurier Avenue West
Ottawa, Ontario K1A 0N5

E-mail: tdgpermits-permistmd@tc.gc.ca

TDG regional offices:

Atlantic

TDG-TMDAtlantic@tc.gc.ca

Quebec

TMD-TDG.Quebec@tc.gc.ca

Ontario

TDG-TMDOntario@tc.gc.ca

Prairie & Northern

TDG-TMDPNR@tc.gc.ca

Pacific

TDGPacific-TMDPacifique@tc.gc.ca