TDG in Canada: Transportation of Dangerous Goods & the Law

Moving dangerous goods is subject to extensive regulatory oversight in Canada. Transport Canada's 2019–2020 inspection summary reported 5,313 TDG inspections and 5,060 findings of non-compliance, and its Compliance Estimation Program estimated a 48% non-compliance rate in the TDG industry during that fiscal year. These are historical findings, not current statistics, but they show why compliance matters. The regime behind them is the Transportation of Dangerous Goods Act, 1992 and the TDG Regulations: nine hazard classes, strict shipping-document and marking rules, and training certificates with legally prescribed expiry periods. This guide covers what TDG is, the federal and provincial rules, and how TDG training and certification actually work. 1

What is TDG?

TDG, or the transportation of dangerous goods, refers to the process of transporting materials that are considered dangerous or hazardous. These materials can include chemicals, explosives, flammable liquids, gases, and other substances that can pose a risk to human health and safety, as well as the environment.

The transportation of dangerous goods is not limited to the movement of goods by road; it also includes air, rail, and marine transport. Individuals and organizations involved in regulated TDG activities must comply with the applicable requirements, subject to the relevant exemptions.

The objective of the Transportation of Dangerous Goods (TDG) Program is to enhance safety in the transportation of dangerous goods by all modes of transport in Canada. The regulations are designed to prevent accidents, minimize risks, and protect the health and safety of people, property, and the environment. They also establish standards for the packaging, handling, and transportation of dangerous goods. 10

What are the nine TDG classes?

Dangerous goods are classified into nine hazard classes based on their physical and chemical properties, and each class has its own set of requirements that must be followed to ensure safe transportation. These classes include: 2

• Class 1: Explosives
• Class 2: Gases
• Class 3: Flammable Liquids
• Class 4: Flammable Solids; Substances Liable to Spontaneous Combustion; Water-Reactive Substances
• Class 5: Oxidizing Substances, including Organic Peroxides
• Class 6: Toxic and Infectious Substances
• Class 7: Radioactive Materials
• Class 8: Corrosive Substances
• Class 9: Miscellaneous Products, Substances or Organisms

Some classes have divisions. A product can have both a primary and a subsidiary hazard. 3

What are the key components of TDG?

Four key components of the TDG Regulations apply when shipping dangerous goods in Canada: classification, documentation, dangerous goods marks, and means of containment. Each of these plays a critical role in ensuring the safe transportation of dangerous goods.

Classification

Classification is the starting point. Dangerous goods are assigned to the applicable hazard classes according to their physical and chemical properties and the type of danger they present, and that classification determines the applicable documentation, marking, and containment requirements. 3

Documentation

Documentation is essential for the safe transportation of dangerous goods. A "shipping document" is defined under section 1.4 of the TDG Regulations. It contains the information required under Part 3 for dangerous goods being offered for transport, handled, or transported. Although the regulatory definition excludes an electronic record, certain provisions allow electronic copies to be provided or accepted under specified conditions. Under subsection 3.2(2), a carrier who accepts an electronic copy must produce a shipping document from it before taking possession of the dangerous goods. A shipping document is always required unless an exemption, special case or special provision states otherwise. While you will find most exemptions to the TDG Regulations in sections 1.15 to 1.52 of Part 1, some are found in Schedule 2. 4,7,18

Dangerous goods marks: labels and placards

Part 4 of the TDG Regulations requires dangerous goods marks to be displayed on a means of containment containing dangerous goods in transport. A dangerous goods mark can be a label, placard, orange panel, sign, mark, letter, word, number or abbreviation, or any combination of these things. The term "dangerous goods mark" has replaced the older "dangerous goods safety mark" throughout the English version of the TDG Regulations. 5

Means of containment

The TDG Act, Regulations and standards require dangerous goods to be contained in a safe means of containment. A safe means of containment is designed to prevent the release of dangerous goods that could constitute a danger to life, health, property or the environment under normal conditions of transport. A means of containment is a container or packaging, or any part of a means of transport that is, or may be, used to contain goods. Proper packaging must withstand the rigours of transportation and prevent leaks or spills. 19

Small means of containment are containers with a water capacity of 450 L or less. They may be drums, jerricans, boxes, pails, bags, barrels, cylinders or intermediate bulk containers (IBC).

Large means of containment are containers with a water capacity greater than 450 L. They may be highway tanks, tank cars, intermediate bulk containers (IBC), portable tanks or tubes. 19

The distinction concerns the container’s capacity, not how much product happens to be inside it. 7

What does federal law require for TDG?

TDG is primarily governed by federal transportation legislation administered by Transport Canada. It is a transport-law regime, not an occupational health and safety statute: the TDG rules flow from one federal Act down through its Regulations, while the workplace safety duties that surround dangerous goods sit separately in the occupational health and safety acts.

What is the TDG Act?

The federal legislation governing the transportation of dangerous goods in Canada is the Transportation of Dangerous Goods Act, 1992 (TDG Act). It establishes the regulatory framework for the handling, offering for transport, and transportation of dangerous goods in Canada, and it is administered by Transport Canada, which enforces the rules and oversees compliance. The Act itself was last amended in 2019. 8

What are the TDG Regulations?

The detailed rules sit in the Transportation of Dangerous Goods Regulations (SOR/2001-286). The Regulations are amended periodically to reflect developments in transportation safety and international standards; the 2019 update for rail containers (SOR/2019-75) is one example, and the framework has continued to evolve since. 20 Always consult the current consolidated Regulations, any applicable transitional provisions, and the requirements for your mode of transport. Among other things, the Regulations set out:

• Shipping documents: defined in section 1.4 and required by Part 3. 4
• Dangerous goods marks: the labels, placards and other marks required by Part 4. 5
• Exemptions and special cases: sections 1.15 to 1.52 of Part 1, plus the special provisions in Schedule 2. 7
• Means of containment: the standards and safety requirements of Part 5. 6

International alignment

The TDG Regulations incorporate, as referenced safety standards, Parts 171 to 180 of Title 49 of the United States Code of Federal Regulations and the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air. This is how Canadian TDG rules connect with U.S. requirements for cross-border shipments and with international requirements for air transport. Their use depends on the applicable Canadian provisions and mode of transport. 9

What do the provinces and territories require for TDG?

Canada's federal TDG framework is supported by provincial and territorial legislation and administrative agreements. Provincial and territorial laws generally apply the federal TDG Regulations to road transport within their borders, adding provincial enforcement and, in some cases, permit powers. 10 For example:

Ontario: the Dangerous Goods Transportation Act (R.S.O. 1990, c. D.1) applies the federal classes and regulations to highway transport. 11

Québec: the Transportation of Dangerous Substances Regulation (C-24.2, r. 43) under the Highway Safety Code expressly incorporates the federal TDG Regulations. It also contains provincial rules; section 1.1 states that these prevail where they conflict with incorporated federal provisions. 12

Alberta identifies the Dangerous Goods Transportation and Handling Act and its accompanying Dangerous Goods Transportation and Handling Regulation as the provincial instruments alongside the federal Act and Regulations. 13

While the federal TDG Regulations provide the principal national requirements, businesses must also consider applicable provincial or territorial rules, including any additional requirements concerning permits, enforcement, or transportation within the jurisdiction.

What training do the TDG Regulations require?

Transportation of Dangerous Goods (TDG) training is essential for individuals who handle, offer for transport, or transport dangerous goods in Canada. The training aims to ensure that everyone involved in the transportation of dangerous goods understands their responsibilities and is aware of the hazards associated with these goods. 15

Training must fit the person’s duties and the goods they will work with. A driver, a person preparing shipping documents and a worker packing dangerous goods may need different depths of knowledge. Completing a general course is useful evidence of learning, but adequacy depends on the actual work. 14

Who is responsible for training under Part 6 of the TDG Regulations?

Both individuals and employers have responsibilities under Part 6 of the TDG Regulations. Anyone who handles, offers for transport, or transports dangerous goods must be adequately trained and hold a valid training certificate, unless working in the presence and under the direct supervision of a person who meets those requirements (s.6.1(1)). Employers must not direct or allow an employee to do this work unless the employee meets those requirements (s.6.1(2)), and an employer who has reasonable grounds to believe an employee is adequately trained and will perform duties to which the training relates must issue the training certificate (s.6.3(1)). Separate provisions address self-employed persons. Training providers may supply instruction and course completion records that employers can consider when assessing their employees' training. 15

Who issues a TDG training certificate?

For employees, the employer issues the TDG training certificate when it has reasonable grounds to believe the employee is adequately trained and will perform duties covered by that training. The employee must sign the certificate, along with the employer or another employee acting on the employer’s behalf. A course completion document is evidence of training; it does not replace the employer-issued certificate.

Section 6.3 requires the certificate to identify the employer, employee, expiry date and aspects of work for which the person is trained. A self-employed person who meets the section’s conditions issues and signs their own certificate. 15

How do the training requirements differ by mode of transport?

TDG training requirements vary depending on the mode of transport and the duties performed. Road, rail, marine, and air transport are all subject to the TDG requirements, with additional mode-specific rules: air transport involves the ICAO Technical Instructions, while marine transport may require compliance with the IMDG Code and Part 11 of the TDG Regulations. Training programs are therefore usually organized by mode, most commonly TDG by ground and TDG by air. 15

TDG by ground: TDG by ground refers to the transportation of dangerous goods by road or rail. This training focuses on the TDG Act and Regulations administered by Transport Canada.

TDG by air: TDG by air focuses on the transportation of dangerous goods by aircraft. The legal basis for air transport is the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, published by the International Civil Aviation Organization, the United Nations civil aviation body, and incorporated into Canadian law by the TDG Regulations. Part 12 also sets Canadian requirements. 16 The International Air Transport Association (IATA), the airlines' trade association, publishes the Dangerous Goods Regulations (DGR), the industry's day-to-day operating manual built on the ICAO rules. 21 Depending on the person’s duties, air transport training can cover: 17

• ICAO and IATA requirements: understanding the ICAO Technical Instructions and working with the IATA Dangerous Goods Regulations that airlines apply in practice.
• Classification and identification: identifying and classifying dangerous goods according to their hazards under the air transport rules.
• Packaging and marking requirements: proper packaging, labelling, and marking of dangerous goods packages to ensure their safe transportation on aircraft.
• Documentation and reporting: completing the necessary documentation, including shipper's declarations, air waybills, and other required forms, accurately and in compliance with the air transport requirements.
• Handling and loading procedures: safe handling, loading, and unloading of dangerous goods onto aircraft, following the specified guidelines.
• Emergency response: becoming familiar with emergency procedures and response protocols in the event of incidents or accidents involving dangerous goods during air transport.

eSafetyFirst's course focuses on ground transportation, primarily by road, with relevant rail context. It does not replace specialized air or marine dangerous goods training.

Who must be trained under the TDG Regulations?

Subject to applicable exemptions and the direct-supervision option in section 6.1, TDG training is required for anyone who handles, offers for transport or transports dangerous goods. 15 The legal duty attaches to that work, not to a particular industry. Some examples of industries where employees, contractors, and suppliers commonly need TDG training include:

• Chemical manufacturing and distribution: chemicals moving to plants, warehouses and distribution centres.
• Oil and gas: flammable and dangerous substances moving by road or rail.
• Mining: explosives, fuels and process chemicals.
• Transportation and logistics: carriers, freight forwarders and warehouse operators.
• Healthcare: infectious substances, radioactive isotopes and medical gases.
• Agriculture: fertilizers, pesticides and fuel.
• Retail: consumer commodities that are regulated in transport, such as aerosols, batteries and propane.

These examples do not mean every product or every worker in a sector has the same requirements. Classification, duties, quantities and any applicable exemption determine what is needed.

Can the training be done online?

Yes. TDG training may be delivered online, provided the instruction is relevant to the employee's responsibilities and the dangerous goods involved. Online courses can provide essential theoretical knowledge, but employers remain responsible for determining whether additional job-specific instruction or practical training is necessary. 14

eSafetyFirst's online course provides foundational training for ground transportation. It is seven modules covering the TDG Act and Regulations, classification and the nine hazard classes, shipping documents, dangerous goods marks, means of containment, the special cases and exemptions for road transport, and emergency response and reporting. It takes about 2 hours and 30 minutes in total, with a test after each module. You can start and stop anytime, from any device.

Two things to know. First, the course focuses on ground transportation, primarily by road, with relevant rail context; it does not replace specialized air or marine dangerous goods training. Second, completion of the course does not, by itself, replace the employer's responsibility to assess adequate training and issue the required TDG training certificate. 14

What knowledge does section 6.2 of the TDG Regulations require?

Section 6.2 of the TDG Regulations identifies the knowledge required for adequate training, as applicable to a person's duties and to the dangerous goods they handle, offer for transport or transport. 15 It includes:

• Classification: the criteria and test methods of Part 2, shipping names, and the use of Schedules 1, 2 and 3.
• Shipping documents: the shipping document and train consist requirements of Part 3.
• Dangerous goods marks: the marking requirements of Part 4.
• Means of containment: the compliance marks requirements, safety requirements, and safety standards set out in Part 5.
• Emergency Response Assistance Plan (ERAP): the Part 7 requirements.
• Reporting: the report requirements of Part 8.
• Safe handling and emergency response: the characteristics of the goods you work with, safe handling and transportation practices, correct equipment use, and measures to reduce or eliminate danger to public safety from a release.
• Mode-specific rules: the ICAO Technical Instructions for air transport and the IMDG Code for marine transport, where relevant to your duties.

For air and marine transport, section 6.2 also specifies the applicable ICAO and Part 12 training topics, or IMDG Code and Part 11 requirements. The relevant topics depend on the work; the legal list is broader than any single provider’s module list.

How long is the employer-issued training certificate valid?

Under section 6.5 of the TDG Regulations, an employer-issued training certificate expires 36 months after its date of issuance for transport by road vehicle, railway vehicle or vessel, and 24 months after issuance for transport by aircraft. 15

The certificate that carries this clock is the one your employer issues under section 6.3 once satisfied you are adequately trained for your duties. Your eSafetyFirst course completion certificate can serve as evidence of training for that decision. Under eSafetyFirst’s program policy, it carries a printed expiry of three years from course completion. This is separate from the statutory period, which starts on the employer-issued certificate’s date of issuance.

Note the scope: this course focuses on TDG requirements for ground transportation, primarily by road, with relevant rail context. It does not constitute specialized marine or air dangerous goods training. Additional training may also be necessary before certificate expiry if regulatory changes or changes in duties affect the knowledge an employee needs. 15

Key takeaways

The principal rules come from the Transportation of Dangerous Goods Act, 1992 and the TDG Regulations, supported by provincial and territorial legislation. Training sits at the centre of the regime: it must match the work, and employers need to distinguish evidence of course completion from the training certificate they are responsible for issuing.