Competency-Based Dangerous Goods Training

Summary#

This is a proposed change, published on December 11, 2021, that would tighten and clarify training rules for people who handle, offer for transport, or transport dangerous goods in Canada. Transport Canada proposes replacing the vague phrase “adequately trained” with a clear, competency-based approach based on the new CAN/CGSB-192.3-2020 training standard. The proposal was open for public comment for 60 days (Part I stage), so it is not law yet.

What it does#

• Removes the phrase “adequately trained” from the Transportation of Dangerous Goods Regulations and replaces it with a competency requirement.
• Requires two kinds of training for people who work with dangerous goods:
  • general awareness training, and
  • function-specific training tied to the worker’s actual tasks.
• Introduces competency assessment and replaces the current “certificate of training” with a recorded “certificate of competency.”
• Incorporates the CAN/CGSB-192.3-2020 standard by reference to spell out training, assessment, task lists, and performance criteria.
• Requires employers to keep training records (including task descriptions and performance criteria) for two years after a certificate expires.
• Keeps certificate expiry periods the same: 36 months for road/rail/marine and 24 months for air.
• Allows electronic certificates and treats self-employed people as having the same responsibilities as employers for Part 6 tasks.
• Provides a 12-month transition period after the regulation comes into force before new training requirements must be followed.

Who's affected#

• Employers and workers who handle, offer for transport, or transport dangerous goods in the air, road, rail and marine sectors. This includes shippers, carriers, drivers, loaders, and others with TDG duties.
• The analysis estimates about 39,000 businesses and 659,000 employees could be affected. About 80% of those businesses are estimated to be small businesses.
• Most costs fall on industry; government training costs are minimal. The regulatory analysis estimates total costs of $15.79 million (present value) and total benefits of $17.43 million, for a net benefit of $1.63 million over ten years.
• Small businesses were estimated to face an average compliance cost of $559 per business over the 10‑year period (about $80 per year).

Why it matters#

• The change aims to remove confusion about what “adequately trained” means and make training consistent across Canada. Clearer rules make it easier for employers to know what training to give and for inspectors to check compliance.
• Better training and verified competence are intended to reduce incidents caused by poor or inconsistent training. Transport Canada data linked about 55 dangerous-goods incidents to training problems between 2014 and 2019; those incidents included 3 fatalities and 174 injuries.
• The standard brings Canada’s rules closer to international expectations (for example, U.S. rules and ICAO guidance). That can help cross-border transport and make training more consistent for international operations.
• There will be some one-time and ongoing costs for businesses to update task descriptions, tests, certificates, records and, in a small share of firms, to revise training programs. The government expects overall benefits from avoided injuries and fatalities to slightly exceed those costs.