TDG Exemption 1.39

A recent helpdesk call led me to investigate the exemption outlined in the Transportation of Dangerous Goods Regulations called (1.39) Class 6.2, Infectious Substances, UN3373, BIOLOGICAL SUBSTANCE, CATEGORY B Exemption.

The exception as outlined in the regulations state

Part 3, Documentation, and Part 4, Dangerous Goods Safety Marks, except section 4.22.1, do not apply to the handling, offering for transport or transporting of infectious substances that are included in Category B if:

(a)  one external surface of the means of containment for the substances measures at least 100 mm × 100 mm;
(b)  the means of containment is in compliance with Part 5, Means of Containment, and has displayed on the external surface
- (i)  the mark illustrated in Part 4, Dangerous Goods Safety Marks, for infectious substances included in Category B, and
- (ii)  the shipping name, on a contrasting background, next to the mark in letters at least 6 mm high; and

(c)  the 24-hour telephone number required under paragraph 3.5(1)(f) is displayed next to the shipping name on the means of containment.

The helpdesk question involved (c) the 24-hour number – Can they use Canutec’s number. I said no because the phone number needs to be the shipper. The shipper is the only one who would really be able to provide the technical information and properties about the substance in question.

Recently, Transport Canada added this exact scenario to their FAQ Page.

Can I use CANUTEC’s phone number when using exemption 1.39?

The 24-hour telephone number required by Paragraph 1.39(c) is the phone number of the consignor who is, in most cases, the only person able to provide technical information about the dangerous goods in transport. CANUTEC’s phone number cannot be used for this purpose.

Have another question or need clarification? Our helpdesk is available to our customers Monday-Friday 8:30 am to 5:00 pm. Give us a call, we are happy to help.

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