Looking for advice with TDG

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Squaretail
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Looking for advice with TDG

Post by Squaretail »

At the moment I am trying to put together a ops manual for a 702 operation and have come up against the stumbling block of getting Transport of Dangerous Goods approval. The regulator as one might guess is spectacularly unhelpful in this regard. It seems under Canadian regulation that almost everything is considered a “dangerous good” including it seems according to 3.1 of AC 700-001 the aircraft itself. Any of the recommended training I have come across seems like overkill for a crew only operation that transports no goods, passengers, or mail (its a survey operation). Of note it seems that the bureaucrats have run amok with this, since they have determined that EVERYONE in Canada is subject to this regulation ( be careful going camping if you are carrying, well, anything without training) as opposed to the FARs which only delineate such programs necessary for those actually transporting such things for hire.

Either way, does anyone have suggestions about where to possibly outsource this training requirements to, or have advice from creating their own training program it would be appreciated.
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Captain X
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Re: Looking for advice with TDG

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valleyboy
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Re: Looking for advice with TDG

Post by valleyboy »

Solo likely is not what you need initially. I will try and find a name for you but what you need is someone to develop a manual for you. Take my word it's worth the cpl grand it will cost you. You can then make your own training or sub contract to a service like solo.
You are better to go on your own. A lot of 702 is under remote access which is lacking with most of the on line providers.
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photofly
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Re: Looking for advice with TDG

Post by photofly »

Squaretail wrote:
Tue Aug 27, 2019 11:03 am
since they have determined that EVERYONE in Canada is subject to this regulation ( be careful going camping if you are carrying, well, anything without training)
There's a 150kg gross mass exemption that covers people for road and water transport, so we're ok to go camping.
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Squaretail
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Re: Looking for advice with TDG

Post by Squaretail »

Don’t be so sure. Since anything with an engine is considered a dangerous good (which the regulation seems to include the motor vehicle of choice you may be travelling in) if you were to tally up any propane cylinders, personal electronics, toiletries, bug spray, fire starting devices and your requisite body spray, you’re probably over. Never mind any products you may be taking along containing the right amount of ethanol to get through the weekend. I suspect 99% of guys transporting any dirt bikes, quads, side-by-sides or argos are doing it in contravention of the regulations.

Moving along...

Valleyboy is correct. In the initial application one is required to make references to the training manual you propose to use, which it seems to TDG directorate must approve of. Which put you in the position of requiring an approved manual to get further approval.
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Heliian
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Re: Looking for advice with TDG

Post by Heliian »

https://worksitesafety.ca/product/train ... tification/

You will need to keep a copy of the IATA tdgr's and keep your employees current.

It's not difficult, don't get caught up too much in making your own manual, everything is already laid out by the regulations and IATA.
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Capt. Underpants
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Re: Looking for advice with TDG

Post by Capt. Underpants »

The DG minefield may soon be tougher to navigate. TC recently sent out the draft of a new national standard for public consultation. It covers training, assessment and competency requirements for DG and it would apply to all modes of transportation. I'm still working through it but it seems that an online course such as the Solocks 4 hour nap inducer and written exam may no longer be sufficient unless your involvement is strictly administrative.
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photofly
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Re: Looking for advice with TDG

Post by photofly »

Squaretail wrote:
Tue Aug 27, 2019 12:39 pm
Don’t be so sure. Since anything with an engine is considered a dangerous good (which the regulation seems to include the motor vehicle of choice you may be travelling in)
Obviously not.

While an internal combustion engine is listed as a Class III dangerous good under Schedule 1 of the Transport of Dangerous Goods Regulations, exemption 1.27 states:
(1) These Regulations do not apply to dangerous goods on a means of transport that are required for
(a) the propulsion of the means of transport and that are
(i) intended to remain on the means of transport until used, and
(ii) contained in a fuel tank permanently installed on the means of transport;
(b) the safety of individuals on board the means of transport;
(c) the operation or safety of the means of transport including, while installed in the means of transport and used or likely to be used for purposes related to transport, air bags, air brakes, flares, lighting, shock absorbers or fire extinguishers; or
(d) ventilation, refrigeration or heating units that are necessary to maintain environmental conditions within a means of containment in transport on the means of transport and are intended to remain with the units or on the means of transport until used.
Additionally whether or not the actual engine of the vehicle, internal combustion engines are subject to special rule 154 of which para. 11 states:
"(11)These Regulations, except for Part1 (Coming into Force, Repeal, Interpretation, General Provisions and Special Cases) and Part2 (Classification), do not apply to dangerous goods other than fuel that are contained in an engine or piece of machinery and that are required for the functioning or safe operation of the engine or piece of machinery if the engine or piece of machinery is on a road vehicle, a railway vehicle or a vesselon a domestic voyage. The dangerous goods other than fuel include batteries, fire extinguishers, compressed gas accumulators and safety devices"
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Squaretail
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Re: Looking for advice with TDG

Post by Squaretail »

To save an arguement photofly, my initial reading of the rules was congruent with your reading of the rules. The inspector I am dealing with maintains a wider interpretation which has led to my current frustrations.
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