Transportation of Dangerous Goods (TDG) - Reporting Requirements

Reporting requirements for road incidents or anticipated incidents are specified in Part 8 of the TDG Regulations. Depending on the type of incident and mode of transportation, certain TDG reports are required, including:

• Reports for incidents involving emergency response assistance plan (ERAP) dangerous goods:
  • A release or anticipated release ERAP incident report
  • A release or anticipated release 30-day follow-up report
  • Implementation of an approved ERAP report
• Reports for incidents involving non-ERAP dangerous goods above the prescribed quantities in the TDG Regulations that endanger or could endanger public safety: 
  • Emergency report when there is a release or anticipated release
  • Release or anticipated release report as soon as possible after an emergency report was made provided the incident meets the criteria in Section 8.4 of the TDG Regulations, and
  • A Release or anticipated release 30-day follow-up report
• Reports relating to the security of all dangerous goods:
  • A “Loss or theft report” for lost or stolen dangerous goods.
  • An “Unlawful interference report” for illegal or unauthorized interference with the dangerous goods.

When reporting incidents or completing TDG forms it is important to understand the terminology. Definitions for the various terms are provided in the TDG Directorate document “Guide for reporting dangerous goods incidents: Definitions related to reports.”

This OSH Answers document will focus on reporting requirements for road transportation.

Note: The information below is provided as guidance only. Always check with Transport Canada and the the TDG Act and Regulations to ensure compliance. Transport Canada has issued a guide titled “Guide for reporting dangerous goods incidents."

Please also see the following documents in this series for road transportation of dangerous goods:

• Transportation of Dangerous Goods (TDG) - "Special Case” and “Special Provision” Exemptions (Road)
• Transportation of Dangerous Goods (TDG) - 9 Classes
• Transportation of Dangerous Goods (TDG) - Classification (Road)
• Transportation of Dangerous Goods (TDG) - Dangerous Goods Safety Marks (Road)
• Transportation of Dangerous Goods (TDG) - Emergency Response (Road)
• Transportation of Dangerous Goods (TDG) - Means of Containment (Road)
• Transportation of Dangerous Goods (TDG) - Overview (Road)
• Transportation of Dangerous Goods (TDG) - Segregation of Means of Containment (Road)
• Transportation of Dangerous Goods (TDG) - Shipping Documents (Road)
• Transportation of Dangerous Goods (TDG) - Training (Road)

A “release” of dangerous goods is defined in the TDG Act as:

"(a) a discharge, emission, explosion, outgassing or other escape of dangerous goods, or any component or compound evolving from dangerous goods, from a means of containment being used to handle or transport the dangerous goods, or

(b) an emission, from a means of containment being used to handle or transport dangerous goods, of ionizing radiation that exceeds a level or limit established under the Nuclear Safety and Control Act;”

For example, the following incidents would meet the definition for a release:

• A tank is punctured in an accident and gasoline drizzles out.
• A test tube containing infectious material falls to the ground and breaks during preparation for transport.
• A pallet of damaged lithium batteries releases hydrogen and catches fire.
• Gases endanger public safety while venting the container.

Anticipated release is not directly defined in the TDG Act or Regulations. However, a definition is provided in Transport Canada’s guide for incident reporting. The following incidents meet the criteria for “anticipated release”:

• an incident has occurred, and dangerous goods will likely have to be transferred to another means of containment; 
• a means of containment is damaged to the extent that its integrity is compromised, and dangerous goods could be released; 
• a means of containment does not comply with regulations, safety standards, and safety requirements during the course of the handling or transporting of dangerous goods; or
• a means of containment is exposed to a fire or unusual temperatures.

Examples of anticipated release are: 

• Package of lithium batteries with signs of overheating. 
• Leaking or shifted Intermediate bulk container (IBC) has to be offloaded into another IBC. 
• Container of infectious material with damaged outer packaging. 
• Highway tank has been involved in an incident (rollover, impact, tire fire, wheel off, in the ditch or other damage to the truck or tank) and product needs to be transferred to another highway tank.

Unlawful interference is not directly defined in the TDG Act or Regulations. However, the Transport Canada’s guide for incident reporting defines “unlawful interference” situation or incident where there is criminal intent or mischief to do harm to dangerous goods transportation activities that or could potentially impact public safety or national security. Examples of interferences with dangerous goods that may be considered unlawful include:

• The dangerous good in a container do not match the safety marks displayed on it. For example, filling propane cylinders with ammonia which is used to make illegal drugs. In this situation, the cylinder will bear safety marks for propane instead for ammonia.
• A means of containment that is purposely vandalized, damaged, or altered (e.g., a cylinder valve that is purposely damaged or altered, a tank is broken on purpose, etc.)
• Shipping document information that is purposely altered.

Section 18(1) of the Transportation of Dangerous Goods Act, 1992 (TDG Act) specifies that the person in charge, management, or control (e.g., driver, consigner/shipper, etc.) of the dangerous goods means of containment at the time of the incident has a duty to report incidents that endanger or could endanger public safety. 

As soon as possible after the release or anticipated release, the person in charge, management, or control of the dangerous goods means of containment must make an ERAP incident report by telephone to the person at the ERAP telephone number that is provided on the shipping document provided the dangerous goods are, or could be, in excess of the quantity set out in the Table 1 below.

Table 1 Reporting requirements: Quantity of dangerous goods release and anticipated release [TDG Regulations, S. 8.20]

A release or anticipated release must be reported to the authorities when:

• the dangerous goods are, or could be, in excess of the quantity set out in in Section 8.2 in the TDG Regulations (which is reproduced below in Table 2), and
• if it could endanger public safety.

Table 2: Reporting requirements: Quantity of dangerous goods release and anticipated release [TDG Regulations, S. 8.2]

A verbal emergency report must be made to any local authority that is responsible for responding to emergencies at the location of the release or anticipated release. Generally, local authorities can be reached by calling 911. See Table 3 for contact information.

In addition to notifying the local authorities, the following other authorities may need to be notified:

• Provincial dangerous goods authorities
• Provincial environmental authorities (e.g., spill centers)

Table 3: Contact information for reporting dangerous goods incidents during road transportation

The details required in each report are outlined in Section 8 of the TDG Regulations.  Specifically:

• Section 8.3 - Emergency Report 
• Section 8.4 - Release or Anticipated Release Report 
• Section 8.5 - Information to be Included in a Release or Anticipated Release Report 
• Section 8.7 - Information to be Included in a 30-Day Follow-up Report
• Section 8.17 - Loss or Theft Report
• Section 8.19 - Unlawful interference report
• Section 8.23 - Information to be Included in an ERAP Implementation Report

These reporting requirements are listed in Table 4. 

Table 4: TDG Reporting Requirements for non-ERAP dangerous goods

Adapted from Alberta EDGE (Environmental and Dangerous Goods Emergencies, Government of Alberta, (2021). Reporting Requirements.

Yes, when a "Release or Anticipated Release Report"  is submitted to Transport Canada.

The person who made a "Release or Anticipated Release Report" or the person's employer must submit a 30-day follow-up report. 

A 30-day follow-up report form is available from Transport Canada. The contact information is as follows.

Transportation of Dangerous Goods Directorate, Transport Canada
 Place de Ville, Tower C, 9th Floor
330 Sparks Street
Ottawa, Ontario K1A 0N5
e-mail: dor-rcd@tc.gc.ca