Tagged: Alberta
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Hello! We are a Janitorial cleaning company servicing work on an oilsand. We purchase different kinds of cleaning chemicals.
My first clarification is, our chemicals when stored in our warehouse on the site is regulated by WHMIS (hazardous product) not TDG (dangerous goods). Is that right and why are we not regulated by the STORING and HANDLING section of TDG’ What determines this’
Secondly, we deal with the handling (removal and replacement) of yellow biohazard bags and containers (usually for sharps and needles) placed in the washrooms. When we collect this containers, we transport them to the onsite medical center. We don’t dispose them ourselves, the medical center is responsible for that. Does our workers dealing with the handling require TDG training or WHMIS training is sufficient to complete this task’
One thing I am quite sure of is the Dangerous Goods Act does not apply to Division 6.2 (Infectious Substances) thereby not regulated under the Storage and Handling Regulation. Please Clarify! Thanks!You’re asking whether TDG storing and handling requirements apply to you if you’re just handling or storing goods AT YOUR SITE rather than moving them to or from an outside site. Right’
In that case, I believe the answer is no. TDG is about shipping–a kind of WHMIS on wheels. If you’re just an employer using the stuff in situ, your workplace-related health and safety obligations come from WHMIS and the designated substance or substance-specific regulations contained in the Alberta OHS Code, e.g., for asbestos or flammables. As long as you comply with those rules, you can leave the TDG concerns to the shippers and consignors. Hope that helps and circle back if I misunderstood your Q. GlennThanks Glenn, that does help and answers the first part of my question.
However, what about the Biohazard part of the question?
Oops. Sorry about that. Since you are transporting the biohazards, your staff would probably need to meet the TDG training requirements unless an exception applies (or they’re accompanied by somebody who does have the required TDG training). Most of the exceptions are in Part 1 of the Regs. (Secs. 1.15 to 1.50). Exceptions covering Class 6.2 Infectious Substances transported domestically by vehicle include when substance is transported:
*In “limited quantities” provided that Sec. 1.17 marking, containment and other precautions taken (See Sec. 1.17 for details, which are too extensive to paste in)
*In “excepted quantities” provided that Sec. 1.18 precautions are taken (See Sec. 1.18)
*Sec. 142.3 There’s also a special exception for medical or clinical waste (other than medical waste containing infectious substances included in Category A) where:
(a) the dangerous goods are UN3291, (BIO) MEDICAL WASTE, N.O.S.;
(b) the dangerous goods are in a means of containment that is in compliance with CGSB-43.125; and
(c) the following information is displayed on the means of containment:
(i) the biohazard symbol; and
(ii) the word “BIOHAZARD” or “BIORISQUE”Keep in mind that I’m not a TDG expert. Recommend that you:
1. Look at the Part 1 exceptions yourself to see if any apply
2. Directly ask a Transport Canada dangerous goods officer, for Manitoba: 1-888-463-0521 TDG-TMDPNR@tc.gc.caHope this helps. Glenn
For all goods/material that are classified as dangerous goods, training in TDG MUST be provided to workers whether handling/storing or shipping. If workers are handling that material on site in preparation for another company/broker to transport it, the workers MUST receive the TDG training. For example, If you receives batteries from the public or a company at your site, the workers handling the batteries must be trained in TDG, but, it could be specific to batteries alone. Its not just about shipping, its also about Awareness/Responsibilities/Hazards.
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