Our members, both SME and large corporations feel that the proposed registration system will be extremely onerous, requiring additional staff ($100,000 USD+) just to keep up with the reporting requirements. Our large multinational members who both manufacture in Canada and import into Canada, are uncertain if they would be required to register all international sites involved in handling hazmat materials to be imported into Canada, or just domestic sites. exact numbers would be dependent on the frequency of registration, the number of transactions to be reported and the duplication with existing federal, provincial and international registration programs. The compliance burden would be significant for SME members as they would require software and additional staffing to meet the minimum reporting requirements.US based companies already register hazmat materials through PHMSA.

A one-time registration would not take a significant amount of time; having to renew a registration that has not changed, however, would be time consuming and would provide no added value. In addition, this new registration requirement should be risk-based and should only apply to ERAP material and should not apply to all dangerous goods.Transport Canada is requesting a lot of duplicate information which simply adds another burden to the industry. Transport Canada has the capacity to extract the information it already has through its existing regulatory requirement such as the ERAP and CANUTEC and industry should not have to bear the cost of duplicate or multiple submissions to compensate for the inefficiencies of the regulatory agencies. This is unacceptable.

The overall impact would be negative (as most other comments have already suggested).- Additional personnel (at least 1 full time) to be hired to deal with the requirements of this new regulation.- Additional equipment/licensing costs associated with each new hire. If the requirements are expanded - costs to business would be as well. One of the points under "Objectives and expected safety results" is to "allow for targeted outreach, awareness, and regulatory consultation efforts" - would a simple e-mail mailing list not have the same effect with much less cost/burden to industry? There is already a newsletter mailing list from Transport Canada stating it is distributed to more than 23,000 readers - https://www.tc.gc.ca/eng/tdg/newsletter-menu-268.htm - The last newsletter was June 2017. Perhaps this could be better utilized.

I agree with most of the comments already made. The TDG CID is a duplication of efforts from other federal reporting requirements in the SWIM system as well as the Provincial HWIN system. A lot more details are required to estimate how it would impact business on daily basis. How would this regulation change impact owners of equivalency certificates to consolidate dangerous goods from various field locations prior to shipping as wastes.

April 12, 2018 Transport Canada Government of Canada330 Sparks StreetOttawa, ONK1A 0N5Re: Transportation of Dangerous Goods Client Identification Database (CID)The Dangerous Goods Advisory Council (DGAC) is an international, non-profit educational organization that promotes safe and efficient transportation of hazardous materials in domestic and international commerce. DGAC’s diverse membership includes hazmat shippers, carriers, trade associations, and providers of related goods and services such as packaging, test labs, labels, warehousing facilities, freight forwarding, software, and consultants and trainers. We actively participate in U.S. rulemaking and international regulatory activities, including those in Canada, and provides classroom training, webinars and conferences. DGAC has Observer status at the United Nations Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and Labelling of Chemicals (UNCETDGGHS), Advisory status at the International Civil Aviation Organization (ICAO), and Consultative status at the International Maritime Organization (IMO).In general, DGAC believes that more detail is needed from Transport Canada on exactly what information would be required and who would be required to submit the information. If detailed information is needed for every shipment of hazardous material within Canada, it would be very costly and time-consuming, if not impossible. It is also unclear as to why the volume of hazardous materials, the type of packaging, specific number of shipments by mode, is necessary.The terms “importer” and “site” are not defined, it is important to understand the potential impacts of the CID for these terms to be defined and well understood. The issue of trans-movements is not addressed. For example, how are shipments that are merely transiting Canadian ports and not initiated in or destined for a Canadian facility by vessel impacted? Additionally, how routine business transactions are going to be addressed needs to be clarified. For example, business often develop or introduce new materials to their inventories, they may also drop certain materials, acquire new customers or drop existing customers. These actions could impact the types of hazardous materials being shipped/transported, quantities of hazardous materials, and the types of packaging used. Additionally, DGAC is also concerned about the security of the CID system. Much of the information being requested is proprietary and confidential business information that could cause significant economic harm to a company if such information was released.Further, the proposed CID appears to be duplicative of other required registration requirements within Canada, including the HWIN system and the Emergency Response Assistance Plan (ERAP) requirement and could duplicate the registration program for hazardous materials shippers and carriers within the US. DGAC believes that a CID program, if implemented, should focus on high hazard/potential high consequence hazardous materials and not focus on low hazard/low potential hazardous materials.• 1. How would Transportation of Dangerous Goods Client Identification Database (TDG CID) information requirements impact (e.g., financial, administrative, human resources) your organization and its operations? Please be specific. Please refer to the above discussion and the response to question 2.• 2. How much time (e.g., weeks, months, if any) would your organization need to compile the information necessary to register with Transportation of Dangerous Goods Client Identification Database (TDG CID), as proposed? DGAC members are not able to provide an estimate of time it would take to collect, compile and submit the information necessary to register. Each company’s ability would be different, based on the hazardous materials being shipped or transported, the packagings involved and the total volume of shipments. The ultimate use of the information contained in the CID is unclear. Certainly, identification of high volume or high hazard material shippers/transporters may be of importance, however, identification of all shippers would not be necessary. Commerce/sales can vary greatly from time to time, season to season, years to years. The types, packagings, quantities of hazardous materials and the mode of transportation used can also experience this variability. This effort would be greatly complicated if “all” shippers and transporters are required to register. For example, manufacturers, distributors, and retail sales stores of hazardous materials commonly used by end use consumers, such as drugs, medicines, personal care products, household commodities, etc., would be almost impossible to identify and track. Other users of hazardous materials as part of their routine business, such as lawn care, carpenters, welders, painters, house repair companies, would not be able to effectively maintain the necessary information. Overall, it is questionable how this type of information can be useful. Registration, itself, does not help ensure compliance, does not help identify regulatory deficiencies or burdens, and does not assist in responding to hazardous materials incidents. Regular re-registration would only compound the burdens.3. What sort of support (if any) from Transport Canada would your organization need to complete your registration with Transportation of Dangerous Goods Client Identification Database (TDG CID), as proposed? DGAC members recommend an on-line registration system that includes drop-down selections, ranges for quantities for amounts and types of hazardous materials, and simplified instructions. Additionally, it may be necessary to develop brochures and live help capabilities.General Comments:We appreciate this opportunity to comment on the establishment of the Transportation of Dangerous Goods Client Identification Database. We look forward to providing additional comments when a more detailed proposal is issued.Sincerely,Delmer F. BillingsTechnical DirectorDangerous Goods Advisory Council7501 Greenway Center Drive, Suite 760Greenbelt, Maryland, USA 20770202-289-4550(Note: A signed-letter head copy of this response will be submitted.)

As we are a small operation and that we wear different hats during the course of the day, this proposal would be completely ridiculous. As mentioned in other comments, the database would be huge and to what extent is it all needed or required? I would say that a short, random amount of info could be extracted from certain areas to give to TDG. The only people that get excited about these projects are those who gain employment or get their contract extended because of it.

Updating of systems would be required and at least one individual if not 3 to analyze and input the data. How often would updates be required and is it site specific? With hundreds of sites across Canada, this will be a very tedious task. A little more detail is required for frequency of data input and data required to would help better anticipate how this will impact the organization and operations.

- Data Security/Privacy is a concern.- Analytical resources will be used to research the requirements and comply with the legislation, including maintaining the data and updated registrations in accordance with the legislations management of change protocols. These functions will require allocating to a role, which arguably will have little value, particularly considering the potential duplication.- The National Energy Board (pipelines), Environment Canada CEPA E2 Regulations, and similar provincial agencies all require registration of facilities, their substances, risk assessments and emergency response/contingency plans. Reciprocity, at least between federal agencies might help alleviate the regulatory burden, as well as make it easier for Transport Canada to meet its objectives with this legislative change.

In the case of the industry I am involved in this will be a significant duplication of information that is already collected by the Ministry of Environment and Climate Change through their HWIN system. They implemented the HWIN database system in 2001 with the goal of going to a completely electronic reporting system which to this day the majority is still done by paper manifest. We deal with over 4000 customer sites most of which ship TDG regulated material and if the HWIN system is any guide we would require 2 additional administrators full time just to report the TDG movements to Transport Canada. For materials that are considered waste the process could be simplified by having a copy of each waste movement document forwarded to Transport Canada, or as another comment suggested, connecting to an already existing database where reporting is being done already.

More detail is needed from Transport Canada on exactly what information would be required. If this proposed rule is similar to the US DOT's hazmat registration program, it would be relatively easy to implement. The US DOT hazmat shipper registration requires that a shipper indicate which modes of transport are used for hazmat, the states with hazmat activity and some information regarding volume. If Transport Canada wants detailed information for every hazmat shipment within Canada, it would be costly and time-consuming, if not impossible. If I ship hazmat to a customer in Canada and I'm the importer from a customs perspective, do I need to include the customer's site information in my registration? Or would my customer, who handles hazmat, need to register his site under this rule? It is not clear how changes to the information provided in a registration would be managed. If I begin to import a new hazmat (a hazmat class that was not included in my current registration) to a new customer that is not included in the "current" registration, do I need to update the registration before the shipment is made, within a specified period of time after the shipment, or during the next registration? Are any fees anticipated for this registration?

I can see this as being extremely onerous on the part of importers, especially if I understand correctly that Transport Canada wants both volume of dangerous goods shipped and location of every customer/site that importers ship to in Canada. Of what potential safety benefit is volume of DG shipped? If you wanted package sizes used, that would be more relevant (e.g. drums, rail cars, cargo tanks, etc). Also US shippers are already subject to a registratio requirment by the DOT, and Transport Canada may want to consider modeling their requirements on those already existing in the US. It would certainly cut down on the number of people/hours required to compile this information. Other issues - how often is "regular" when you state "regular re-registration"? And what about cost? We're already paying a substantial amount of money to register our companies in the US. I doubt this database registration requirement is going to end up being no cost to the companies involved.

Dan (WestJet):Currently we are registered with CANUTEC to whom we provide applicable Dangerous Goods information on DG articles that we offer for transport. On that note and in this case, Transport Canada already has relative CID information with the current CANUTEC process. If additional information can be instrumental to Transport Canada, we feel that working the CID process through CANUTEC i.e. working off an existing TC process, would be advisable.

It is not clear how much detail will be required in the information that businesses will have to provide. The statement " Transport Canada must know who, when, how and where dangerous good are transported" seems like it could require a very high degree of detail of information. There is nowhere in the consultation information that defines clearly what will be required of business. We need to have a better explanation of the information that will be required before being able to comment on the impact on business, I am concerned that Transport Canada will be collecting information that will put an unnecessary burden on small business. Where is the evidence if any that the collection of this information will result in any reduction in injury, loss of life and property damage? I am very skeptical because I have seen transport Canada require information or changes in documentation and procedure that do not result in any reduction in injury, loss of life and property damage. Some examples are 1- The change in the required order of information on shipping documents that cost my company and many others a tremendous amount of time and money to change software to comply. I do not think a single accident was avoided by changing the order of information on shipping documents from Class - Name - UN Number - Packing Group to UN Number - Name - Class - Packing Group.2 - The requirement to "(a) notify the air carrier, in writing, of the shipping name, UN number, primary class and compatibility group of the explosives at least 48 hours before the explosives are loaded on the aircraft;" because there is no benefit to the 48 hour notice. Neither the air carrier nor the remote airports do anything different because there is notice of the air transport of explosives. Sometime business that does not fit into the 48 hour window is lost. There is also unnecessary work generated by the notices and record keeping. All of the other requirements to ship explosives by air provide the procedure that is necessary to ship explosives by air with the greatest possible level of safety.3 - Transport Canada continues to require the Issuing of NOTAMS for fireworks shows when nowhere ever in the entire history of aviation anywhere in the world has there been an aircraft shot down by a fireworks. Any certified Display Supervisor in Canada will notice an aircraft overhead before starting to shoot fireworks and any pilot will notice fireworks before flying in to them.In closing I think we need to see evidence that shows this new paperwork burden on business will result in a reduction of death, injury and property damage before placing greater expense on business and presumably government as well. Any analysis of expected reduction in injury, death and property damage has to take all of the historic incidents where there was compliance with documentation and procedure requirements of the regulations out of the risk reduction calculation.Craig Henderson - Owner Big Top Fireworks

This would cause a huge administrative burden. Exemption should be considered if an ERAP is not required. I do not agree with the stated rationale as to why this is required.

As has been previously stated, without any idea of what this will look like it's impossible to know how it will play out and impact my business. I'd like to see some fact based evidence that shows this does anything to enhance safety.

I guess the first question is what is the intent of this CID from Transport Canada's use, (i.e. Purely for statistical purposes, enforcement & inspections, etc.), secondly what would the cost of this registry be to industry, as I am sure there will be some type of registry fee to pay for the databases upkeep? For some organizations pulling together this list will be easier than for others, however I question why Transport Canada or the Provincial & Federal governments wouldn't use the databases / information collected that is already reported through E2, AER, AEP registries that already exist & have that information recorded? Professionally I don't see the value that this CID would add to public safety & would find it a cost burden both financially & on resources for both Industry & Transport Canada in upkeep, monitoring for what limited relevance & use it would have on public safety as per Transport Canada's (TDG) mandate.

If the intent is to track and report every location DG are: goods are handled, offered for transport, transported, or imported. This would be a near impossible task. We routinely transport DG, for our own purposes, to multiple sites daily. We have hundreds of technicians who could be doing this everyday. While locations are tracked for other regulatory reasons (i.e. Class 7) managing this data would require a full time person if we had to report it at any regular frequency. Even once per year reporting could take weeks of distilling data. Conversely, a more real-time style tracking solution for hundreds of employees would be significant costly. Given the history in our industry, there could be very little to be gleaned from increased data given the solid safety record and low likelihood for negative consequences.thanks,

For our organization, we do have an active monitoring system available for the Nuclear Densometers we carry. Further our facilities are always under 24/7 CCTV monitoring. Now if this is just about registering and knowing about your assets at any given point of time, this is not going to impact any operations unless there is a mandatory fee applied to it.

We have an extensive network of collection sites for dangerous goods Canada Wide, as part of a stewardship program. Although we would not be reporting for them, it adds another layer of administration that creates a deterrent for those sites and new sites to operate within our program. As yet, there are no details on the reporting requirements with regards to frequency, format, level of details, etc.; these details will determine the impact of this administrative burden. If there was a requirement to report all dangerous goods shipment activity monthly, this would occupy an administrator for many hours. This seems like a way for Transport Canada to mitigate the risk of non-compliance during transport, as existing inspection activities are either insufficient or being scaled back. however, the industry is already regulated; those that are not currently complying, are unlikely to register with the CID, meaning that compliant companies, that present the lowest risk, are the ones shouldering the added costs for this administration, in order for Transport Canada to appear to be mitigating risk. The funds and time devoted to maintaining this CID would be better allocated to activities that affect the companies that present the highest risk.

Assuming that there would be an administration cost on the employers side for implementation and keeping up with the ever changing regulations with respect to TDG CID, what is the cost if any that TC will be charging companies to comply? Will there be a fee companies have to pay to partake?

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