An alternate interpretation of Clause 4.7 (3) in the TDG regulations may lead Nurse Tank owners to be challenged by their inspector to demonstrate that a reduced size UN 1005 placard is required.

CAAR has recently been made aware of an alternate interpretation of Clause 4.7 (3) in the Transportation of Dangerous Goods (TDG) regulations that impacts the size of placard that a Transport Canada inspector may consider acceptable on an anhydrous ammonia nurse tank. Nurse Tank owners may be challenged by their inspector to demonstrate that a reduced size UN 1005 placard is required on the ends of an anhydrous ammonia nurse tank.

Excerpt from Transportation of Dangerous Goods Regulations:
Clause 4.7 (3)
Each side of a placard must be at least 250 mm in length and, except for the DANGER placard, have a line running 12.5 mm inside the edge. However, except for dangerous goods included in Class 7, Radioactive Materials, if that size placard cannot be displayed because of the irregular shape or size of the large means of containment, each side of the placard may be reduced in length by the same amount to the point where the placard will fit that large means of containment, but must not be reduced to less than 100 mm.

CAAR has completed field testing and found that the standard 250 mm placard may crinkle on the rounded end of a tank, particularly smaller tanks, which may impact legibility and secure application of the placard.

Clause 4.7 (3) in the TDG regulations allows for reduced placards no less than 100 mm, however the amount by which the placard needs to be reduced in order to fit each tank may vary depending on the size of the tank, and acceptability may be subject to interpretation by the Transport Canada inspector.

Determine Your Placard Needs

CAAR recommends testing what size of placard between 100 mm and 250 mm is required to fit the ends of your anhydrous ammonia nurse tank, and documenting your findings should your inspector request justification of a reduced placard. Fertilizer Canada is seeking an official interpretation of Clause 4.7 (3) from Transport Canada to ensure a consistent approach by inspectors. This process is expected to take time, so CAAR will update its membership immediately upon receiving the official interpretation.

CAAR’s field testing has determined that approximately 150 mm may be the largest placard that fits the rounded end of smaller nurse tanks without crinkling, while still being legible. Medium tanks may be able to fit 150-200 mm placards without crinkles. Large tanks may be able to use the full size 250 mm placards.

CAAR has access multiple placard sizes at member discounted rates, featuring a three year warranty against defects such as fading. In addition to the 100 mm placards, CAAR will stock 150 mm placards that are most visible without crinkling on application for smaller nurse tanks. Contact the CAAR office or visit http://caar.org/caar-mart to place your decal order before the compliance deadline of May 31, 2017.

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Tags: Advocacy NH3

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