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Hidden Dangerous Goods for Manufacturers

Manufacturers often focus on the end product, ensuring its quality and safety, but what about the hidden dangers lurking within their processes? It’s a question often overlooked until a surprise visit from regulatory authorities brings it to the forefront.

Take, for instance, a manufacturer who recently found themselves in hot water with Transport Canada. This company, specializing in products seemingly harmless, had never considered themselves in the realm of dangerous goods. However, they were in for a rude awakening.

Unbeknownst to them, the manufacturer was receiving dangerous goods for use in their manufacturing process. Moreover, they were generating hazardous waste as a byproduct of their operations. This meant they fell squarely under the jurisdiction of Part 6 of the Regulations concerning the Transportation of Dangerous Goods (TDG).

According to TDG Part 6.1(1), anyone handling, offering for transport, or transporting dangerous goods must be adequately trained and possess a training certificate in accordance with the regulations. This requirement extends not only to those directly involved in shipping hazardous materials but also to those who handle them as part of their manufacturing process. In essence, if you “handle” dangerous goods, you must comply with the regulations.

But the compliance journey doesn’t end there. In addition to handling dangerous goods, if a manufacturer offers hazardous waste for transport, they must also adhere to the new Site Registration Requirements (Part 17) effective October 2024.

This story serves as a wake-up call for manufacturers everywhere. It underscores the importance of understanding the full scope of their operations and the regulatory obligations that come with it. Ignorance is no defense when it comes to hazardous materials and waste management. Proper training, compliance, and staying abreast of regulatory changes are essential for the safety of employees, the environment, and the integrity of the business itself.

Training for these types of companies does not have to be long and tedious. The training focused on the general aspects of the regulations with more in-depth training on the areas pertinent to them.

If you are not currently using ICC as your training provider, ask us for a quote. We have some of the best trainers in the industry and can customize training – just for you! Contact us today!

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Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.