CAAR has been advised that Transport Canada inspectors are actively inspecting nurse tanks in preparation for the pending change to placard requirements for nurse tanks beginning June 1, 2017.
Inspectors have been focused on the underlined portion of Clause 4.7 (3) below that states “each side of the placard may be reduced in length by the same amount to the point where the placard will fit”. If retailers choose to use a smaller placard on the ends of their nurse tanks, inspectors are requiring retailers to demonstrate that the placard size they have chosen for the ends of the nurse tank has been reduced only to the point where it will fit on the tank.
Retailers will be held responsible by Transport Canada for demonstrating that the size of placard chosen for the ends of each nurse tank is the largest possible placard that fits the size and shape of the end of the tank.
Summary of Nurse Tank Placard Requirements
Beginning June 1, 2017, nurse tanks will require placards identifying that it is carrying ammonia (UN 1005) on all four sides in a way that complies with Part 4 (Dangerous Goods Safety Marks) of the Transportation of Dangerous Goods (TDG) regulations. The two equivalency certificates that formerly allowed placards on the two long sides of a nurse tank (SH 6171 - Ren. 9, and SH 10006 - Ren. 5) will be discontinued on May 31, 2017.
Section 4.7 (3) in the TDG regulations indicates that each side of the placard must be at least 250 mm in length. If a placard that size cannot be displayed properly due to the irregular size or shape of the tank, then a placard can be reduced in size to the point where it fits, but is not less than 100 mm on each side. While a 100 mm placard may be considered to comply with the TDG regulation, it will be up to the tank owner to demonstrate to the Transport Canada inspector that a larger placard size is not feasible.
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.
For more information please contact your regional Transport Canada office https://www.tc.gc.ca/eng/regions.htm
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 has received an interpretation of Clause 4.7 (3) from Transport Canada, stating that it will be left to the judgment of the TDG inspector to determine if it is possible to fit a placard of 250 mm in length, or if a reduced-size placard is needed. While a placard of 100 mm in length is considered to comply with the TDG regulation, it will be up to the tank owner to demonstrate that a larger placard size is not feasible. Please click here to read the full memo from Fertilizer Canada.
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.
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