Temporary certificate TU 0753.2: Canada Post Corporation - Shipping hand sanitizer by air

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

Certificate Number: TU 0753 (Renewal 2)

Canada Post Corporation
2701 Riverside Dr, N170,
Ottawa ON K1A 0B1

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.

In order to support these efforts, it is necessary to ensure the availability of hand sanitizer throughout Canada during this pandemic. Under the Transportation of Dangerous Goods Regulations (TDG Regulations), Canada Post Corporation is restricted from transporting a number of dangerous goods by air, such as hand sanitizer. In order to allow Canada Post Corporation to contribute to the pressing need to provide medical supplies to remote communities (referred to as limited access locations below), the Minister hereby 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 the need to ensure the safe transportation of dangerous goods, while allowing the Canada Post Corporation the needed authority and relief from certain requirements to provide hand sanitizer shipments by air to remote communities.

In my opinion, the issuance of a temporary certificate is in the public interest and I hereby authorize either:

Canada Post Corporation to handle, offer for transport, or transport, and authorize any person to handle or transport, on behalf of Canada Post Corporation, dangerous goods, by road vehicle to or from an aircraft, an aerodrome or an air cargo facility, in a manner that does not comply with the requirements prescribed in sections 1 to 4 below, if the conditions of paragraphs a) to i) of this temporary certificate are met:

  1. Part 3 (Documentation) of the Transportation of Dangerous Goods Regulations (TDG Regulations)
  2. Part 4 (Dangerous Goods Safety Marks) of the TDG Regulations;
  3. Part 5 (Means of Containment) of the TDG Regulations;
  4. Part 6 (Training) of the TDG Regulations; or

Canada Post Corporation to handle, offer for transport, or transport, and authorize any person to handle or transport, on behalf of Canada Post Corporation, dangerous goods, by aircraft anywhere in Canada provided the final destination is a limited access location, in a manner that does not comply with the requirements prescribed in sections 5 to 9 below, if the conditions of paragraphs a) to i) of this temporary certificate are met:

  1. Paragraph 3.1 of Chapter 2 of Part 1 (1;2.3.1) of the Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions), as incorporated by reference in subsection 12.1(2) of the TDG Regulations.
  2. The quantity limits of Packing Instruction Y341 of Paragraph 1 of Chapter 5 in Part 4 (4;5.1 Packing Instruction Y341) of the ICAO Technical Instructions, as incorporated by subsection 12.1(2) of the TDG Regulations;
  3. The quantity limits in column 11 of Table 3-1 of Chapter 2 in Part 3 (3;2 Table 3-1, Column 11 - Maximum net quantity) of the ICAO Technical Instructions, as incorporated by subsection 12.1(2) of the TDG Regulations;
  4. The Training requirements of Chapter 4 in Part 1 (1;4) of the ICAO Technical Instructions, as incorporated by subsection 12.1(2) of the TDG Regulations, and Part 6 of the TDG Regulations;
  5. The dangerous goods transport document requirements of Chapter 4 in Part 5 (5;4) of the ICAO Technical Instructions, as incorporated by subsection 12.1(2) of the TDG Regulations, and Part 3 of the TDG Regulations;

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

  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 dangerous goods are handled, offered for transport, or transported in accordance with Chapter 4 of Part 3 (3;4) of the ICAO Technical Instructions;
  4. The dangerous goods must be packaged according to Packing Instructions Y341 of the ICAO Technical Instructions with the following quantity limits:
    1. The quantity of each inner packaging must not exceed 1 L and the total quantity per package must not exceed 10 L; and
    2. The total gross mass per package must not exceed 30 kg;
  5. The outer package must display the following:
    1. the limited quantity mark illustrated below;
    2. the class 3 flammable liquid label illustrated below;
      Limited quantity mark
    3. Each side of the limited quantity mark and class 3 flammable liquid label must be at least 100 mm in length;
      Class 3 flammable liquid label
    4. If the size of the package so requires, the minimum outer dimensions may be reduced to be not less than 50 mm × 50 mm provided the mark and label remains clearly visible. The minimum width of the line forming the square on point may be reduced to a minimum of 1 mm;
    5. The words "TU 0753";
    6. The words "hand sanitizer" or "désinfectant pour les mains";
    7. The UN number, shipping name, class and packing group;
    8. The total number of bottles and volume of each bottle; and
    9. The name and address of the company who has prepared the package;
  6. When packages are placed in an overpack or in a container, the information required by subparagraphs e)i) to e)ix) above must be displayed on two opposite sides of the overpack or container when the information is not visible through the overpack or container. In addition, the word "Overpack" or "Suremballage", in letters that are at least 12 mm high, must be written on two opposite sides of the overpack or container;
  7. Instead of marking the package with the information required by conditions e)vi) to viii), the dangerous goods may be accompanied by a dangerous goods transport document that complies with the requirements of Chapter 4 of Part 5 (5;4) of the ICAO Technical Instructions;
  8. The person handling, offering for transport, or transporting the dangerous goods must:
    1. Possess a valid training certificate as per Chapter 4 in Part 1 (1;4) of the ICAO Technical Instructions and Part 6 of the TDG Regulations; or
    2. Perform those activities in the presence and under the direct supervision of a person who is adequatel y trained as per as per Chapter 4 in Part 1 (1;4) of the ICAO Technical Instructions and Part 6 of the TDG Regulations; or
    3. Be assisted, either in person or by phone, by a person who is trained as per Chapter 4 in Part 1 (1;4) of the ICAO Technical Instructions and Part 6 of the TDG Regulations. The contact information of the person providing assistance must be given to an inspector immediately upon request; and
  9. Canada Post Corporation ensures that all personnel handling and transporting the dangerous goods have received training on the conditions of this temporary certificate.

The following definitions apply in this temporary certificate:

  • A limited access location means a location that is not accessible year-round by permanent roadway, railway, or waterway. Included in this definition is:
    • A place serviced by an ice road
    • A place not serviced year-round by vessel due to seasonal ice
  • "ICAO Technical Instructions" means The Technical Instructions for the Safe Transport of Dangerous Goods by Air, published by the International Civil Aviation Organization (ICAO), as amended from time to time.
  • 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.

This temporary certificate takes effect on September 18, 2020. It remains in effect until the earliest of:

  • January 31, 2021, or
  • the day it is cancelled in writing by the Minister of Transport.

Benoit Turcotte
Director General
Transportation of Dangerous Goods Directorate
Transport Canada

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