Transport Canada (TC) has issued two Protective Directions that will affect the transportation of crude oil by rail in Canada.
Protective Direction No. 33 requires persons who offer for transport or import crude oil (as well as diesel, gasoline and certain other petroleum products) to have in place by September 20, 2014, an Emergency Response Assistance Plan (ERAP) approved by TC. ERAPs are intended to assist local emergency responders at an accident site by providing them access to technical experts and timely assistance by industry response teams with specialized equipment. Industry members subject to this new Protective Direction may choose to comply by developing their own individual ERAPs or joining a mutual and/or umbrella-type ERAP.
Protective Direction No. 34 prohibits rail car owners from transporting crude oil (and other petroleum products such as diesel and gasoline) in certain types of tank cars that are of a CTC 111, DOT 111 or AAR 211 specification and do not have continuous reinforcement of their bottom shell. Tank car owners must by May 23, 2014, have each of such cars marked with, "Do not load with dangerous goods in Canada/Ne pas charger de marchandises dangereuses au Canada" or words to that effect.
TC proposed a new standard for the DOT 111 tank car in Part 1 of the Canada Gazette on January 11, 2014. It has now announced it will formalize the updated DOT 111 standards in Part II of the Canada Gazette this summer and require that tank cars built before the January 2014 proposed standard be phased out or retrofitted within three years.
TC also issued an Emergency Direction to Canada's railway companies to review and revise their operating practices for transporting various dangerous goods, including reducing maximum speeds of trains transporting crude oil.
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