The following memo from Fertilizer Canada is being shared with CAAR members:
Fertilizer Canada has received a number of questions regarding the proper size of placard that would be acceptable under section 4.7 (3) of the Transportation of Dangerous Goods (TDG) Regulations. Further to the memos issues January 12 and April 27, the following information is intended to provide additional guidance on the placarding size requirements.
Placards provide important information on the dangerous good carried by the tank and needs to be displayed clearly. First responders and other authorities use the placard’s UN number and symbol to identify the product and risks in order to determine how best to manage an incident.
Section 4.7 of the TDG regulations describes the size and orientation of labels and placards on a large means of containment. Subsection (3) describes that each side of the placard must be at least 250 mm in length. However, if a placard of that size cannot be displayed properly due to the irregular shape or size of the tank, then a smaller placard can be used so long as the length of the sides is not less than 100 mm.
It is the responsibility of the tank owner to demonstrate which placard size is appropriate and provide rationale as to why a larger placard is not feasible should a TC inspector request it. While a placard of 100 mm in length is considered a minimum to comply with the subsection 4.7(3) of the TDG Regulations, the requirement is to keep the placard as large as possible to the point it will fit the tank and maintain legibility.
It is Transport Canada’s view that at least three full-sized placards can be displayed on a nurse tank in most cases. Nurse tanks vary in size and the ability to affix a full-sized placard may also vary. Section 4.7 (3) provides flexibility on placard sizing that allows compliance options for these varied design constraints. It will be left to the judgment of the TDG inspector if it is possible to fit a placard of 250 mm in length or if a reduced-size placard is needed. Fertilizer Canada strongly recommends tank owners unsure of their placarding needs contact their regional Transport Canada office for assistance.
Beginning June 1, 2017, nurse tanks will require placards identifying that it is carrying ammonia (UN 1005) on all four sides in a manner that complies with Part 4 (Dangerous Goods Safety Marks) of the Transportation of Dangerous Goods (TDG) Regulations.
Click here to view a PDF of the Fertilizer Canada memo (English).
Click here to view a PDF of the Fertilizer Canada memo (French).
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