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Transport Canada Exemption 1.36(b)

Recently, Transport Canada updated their guidance on Aqueous Solutions of Alcohol, class 3 Flammable liquids. The full guidance can be found here.

This guidance does not change the Transportation of Dangerous Goods regulations but clarifies Paragraph 1.36 (b), which is an exemption for flammable liquids.

Paragraph 1.36(b) states:

an aqueous solution of alcohol if the aqueous solution has a flash point greater than 23°C and

  • (i) contains alcohol that is less than or equal to 50% by volume and at least 50% by volume of a substance that is not dangerous goods, and
  • (ii) is contained in a small means of containment.

The guidance specifically states that aqueous solutions are a mixture of alcohol and water. These solutions could be windshield washer fluids. Those containing methanol may especially benefit from the exemption.

Such solutions would be exempt if they have a flash point greater than 23°C, an alcohol content less than or equal to 50% by volume, and at least 50% by volume of a substance that is not a dangerous good, and it must be contained in a small means of containment.

It should be noted that flammable liquids (with the exception of methanol) with a subsidiary hazard are excluded from this exemption.

The user must also be careful of the concentration shown. WHMIS allows a range of 30-60% or 45-70%. Those ranges would not be permitted, as it would be unknown if the actual concentration were less than or equal to 50%.

Do you have questions about shipping dangerous goods? Our team of experts is just a call away for our customers at 855.734.5469 or send us an email, we’re happy to help.

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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.

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