Temporary certificate TU 0754.1: Transporting hand sanitizer by air

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

Certificate Number: TU 0754 (Renewal 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. However, many 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.

Under normal circumstances, hand sanitizer is typically transported by road vehicle. However, the shortage of supply is forcing distributors to look for ways to quickly deliver their product to market. Some distributors are looking to ship their hand sanitizer beyond their normal service area, thereby creating a sudden increase in interest in moving their product by air.

To respond to this unprecedented situation, and in order to allow air carriers to contribute to the pressing need to provide hand sanitizer to communities across Canada, the Minister hereby authorizes the handling, offering for transport, or transportation 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 Dangerous Goods while providing air carriers with the needed relief from certain requirements to provide hand sanitizer shipments by air to communities across Canada.

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

The handling, offering for transport, or transporting of 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

The handling, offering for transport, or transporting of dangerous goods, by aircraft in Canada, in a manner that does not comply with the requirements prescribed in sections 5 to 9 below, if the conditions of paragraphs a) to k) of this temporary certificate are met:

  1. 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;
  2. 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;
  3. The means of containment requirements in Part 5 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 following must be displayed on any side of the package, other than the side on which it is intended to rest or to be stacked during transport:
    1. The limited quantity mark illustrated below:
      Limited quantity mark
    2. The class 3 flammable liquid label illustrated below:
      Class 3 flammable liquid label
    3. Each side of the limited quantity mark and class 3 flammable liquid label must be at least 100 mm in length,
    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 package orientation label illustrated below:
      Package orientation label
    6. The package orientation label must have two black or red arrows on white or suitable contrasting background. Dimensions shall be at least 74 mm wide by 105 mm high. The rectangular border is optional,
    7. The UN number and shipping name of the dangerous goods,
    8. The words "hand sanitizer" or "désinfectant pour les mains", and
    9. One of the following expressions:
      1. "TU 0754",
      2. "Temporary Certificate - TU 0754", or
      3. "Certificate Temporaire - TU 0754";
  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. Packages need not display the information required by paragraph e) above, when they are placed in an overpack or container that is not intended to be dismantled during transport and the information required by paragraph e) is displayed on two opposite sides of the overpack or container;
  8. The dangerous goods must be accompanied by a document that contains the following information:
    1. The name and address of the consignor and consignee,
    2. The UN number, shipping name, class and packing group of the dangerous goods,
    3. The maximum net quantity per package and the total number of packages,
    4. A consignor's certification statement using the following words:
      "I hereby declare that the contents of this consignment have been properly prepared, packaged, marked and labelled. All the requirements of the Temporary Certificate TU 0754 have been met.",
    5. The name of the individual and his/her signature making the certificate statement,
    6. The date the certification statement was made, and
    7. A 24-hour number at which the consignor or air carrier can be reached immediately for technical information about the dangerous goods in transport. The consignor must get written permission from the air carrier to use their 24-hour number;
  9. 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,
    2. Perform those activities in the presence and under the direct supervision of a person who is adequately trained as per as per Chapter 4 in Part 1 (1;4) of the ICAO Technical Instructions and Part 6 of the TDG Regulations,
    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, or
    4. Have received training by way of an information bulletin or guidance material prepared by a person who is trained in accordance with the ICAO Technical Instructions and Part 6 of the TDG Regulations;
  10. Despite paragraph i) above, an employee of an air carrier involved in the handling or transportation of the dangerous goods by aircraft, must 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;
  11. The air carrier shall provide written information to the pilot-in-command regarding the quantity and loading locations of the dangerous goods. The information shall be consistent with the information provided by the consignor on the document required by paragraph h) above.

The following definition apply in this temporary certificate:

  • "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.
  • "air carrier" means a person who, whether or not for hire or reward, has possession of dangerous goods while they are in transport by air.
  • 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

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TDG-TMDPNR@tc.gc.ca

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