COSTHA Transport Canada Equivalency Certificates

Authorization to use the updated lithium battery mark
(SU 14319)

Effective date:
January 29, 2024

Expiration date:
February 28, 2029

In January 2021, the ICAO Technical Instructions and the IMDG Code reduced the minimum allowable size of the Lithium Battery Mark from 120 mm by 110 mm to 100 mm per side. Additionally in January 2023, the requirement for a telephone number on the mark has been removed in the ICAO TIs and the IMDG Code (there is a transition period for the telephone number to still be displayed until January 1, 2027). These provisions are expected to be amended in the Transport Canada Transportation of Dangerous Goods Regulations (TDGR) in Part II of the Canada Gazette (anticipated publication in Spring 2025).

Some of the conditions for use of this Equivalency Certificate include:

• Must be a current member of COSTHA.
• The means of containment must legibly display the equivalency certificate number (SU 14319) in characters at least 6 mm high.

Authorization to use the exemption for medium lithium batteries found in 173.185(c) of 49 CFR
(SU 14355)

Effective date:
March 8, 2024

Expiration date:
March 31, 2029

In the United States’ 49 CFR, the exception for smaller cells and batteries found in § 173.185(c) allows for the transportation of “small” and “medium” lithium batteries in non-UN specification packaging without the requirement to mark, label and document shipments as fully regulated hazardous materials’ shipments. Medium-sized batteries can only be shipped under this exception by ground (i.e., road and rail).

In Canada’s TDG Regulations, the exemption found in SP 34 of Schedule 2 allows only the transportation of small cells and batteries. With this equivalency certificate, transportation of medium-sized lithium batteries becomes simpler between Canada and the United States.

Some of the conditions for use of this Equivalency Certificate include:

• Must be a current member of COSTHA.
• The cells/batteries design type must have successfully been tested in accordance with the provisions found in the UN Manual of Tests and Criteria, Part III, Subsection 38.3.
• The lithium content does not exceed 5 g for a Li metal cell, and 25 g for a Li metal battery, while the watt-hour (Wh) does not exceed 60 Wh for a Li ion cell, and 300 Wh for a Li ion battery.
• The means of containment must legibly display the following notation in characters at least 6 mm high: “Lithium Batteries — Forbidden for transport by aircraft — Equivalency Certificate – SU 14355“.

Shipment of display pallets under conditions similar to those in 49 CFR
(SU 14403)

Effective date:
April 10, 2024

Expiration date:
April 30, 2029

This equivalency certificate allows COSTHA members to offer dangerous goods intended for retail sale for transport in a palletized unit, described as a DISPLAY PACK, designed to be the actual display unit used at a retail location. The dangerous goods packed as described in the equivalency certificate are allowed to be shipped under the provision of Section 1.17, Limited Quantities Exemption, of the TDG Regulations.

Some of the conditions for use of this Equivalency Certificate include:

• Must be a current member of COSTHA.
• The dangerous goods are intended for retail sale and are transported by ground (road and rail).
• The quantity of dangerous goods per inner packagings does not exceed the Limited Quantity Index in Column 6(a) of Schedule 1.
• The inner packagings are packed into trays to prevent them from moving freely during transport. The gross mass of each tray is less than or equal to 30 kg.
• The trays are placed in a fiberboard box which is secured to a pallet by metal, fabric, or plastic straps to form a single palletized unit. The maximum net quantity of dangerous goods permitted in one display pack is 250 kg (550 lb). Display packs must not be opened during transport.
• Each display pack must display the limited quantity (LQ) mark. Each display pack must also display the equivalency certificate number (SU 14403) in characters at least 32 mm high next to the (LQ) mark.

Relief from some training certificate requirements
(SU 14396)

Effective date:
April 10, 2024

Expiration date:
May 31, 2029

This equivalency certificate allows COSTHA members and their employees to handle, offer for transport, transport, or import, by road or rail, dangerous goods in a manner that does not comply with paragraph 6.3(3)(a) and 6.8 of the TDG Regulations. More specifically, the equivalency certificate allows for training certificate not to be signed by either the employee and/or employer.

Some of the conditions for use of this Equivalency Certificate include:

• Must be a current member of COSTHA.
• The employer must manage/track employees’ TDG training through an electronic learning management system (LMS), and issue employees’ training certificates once all necessary TDG training has been successfully completed.
• The TDG training certificates contain the employees’ name and identification number (replacing the signature), as well as display the equivalency certificate number (SU 14396)
• The employer is responsible for providing the information in the electronic LMS with TDG inspectors.

NAAHAC – Transport and disposal of safety devices
(SU 8424)

Effective date:
August 26, 2020

Expiration date:
November 30, 2025

Part A of this equivalency certificate authorizes NAAHAC members to transport safety devices (UN3268) in accordance with Packing Instructions 902 of TP 14850, for small means of containment, or Packing Instruction LP 902 of the UN Recommendations, for large means of containment. It also authorizes the handling, offering for transport or transporting of safety devices (UN3268) in a dedicated handling device, vehicle, container or wagon if the dangerous goods are moved from the place of manufacture to an assembly plant or to, between, and from intermediate handling locations.

Part B of this equivalency certificate authorizes NAAHAC members to use removable head drums with a capacity of 208 L or less to transport non-refillable cylinders with safety devices (UN3268) for recycling or disposal purposes.

Some of the conditions for use of this Equivalency Certificate include:

• Must be a current member of COSTHA/NAAHAC.
• A copy of the equivalency certificate accompanies the dangerous goods during transport.
• The means of containment must be listed in the equivalency certificate, conform to the PG III performance level, and be designed and constructed to prevent movement of the articles and inadvertent operation during normal conditions of transport.
• The documentation must must legibly display the following notation: “Equivalency Certificate SU 8424 (Ren. 12)”.

NAAHAC – Transport of marked & labelled, empty packagings for reuse
(SH 11892)

Effective date:
January 25, 2024

Expiration date:
April 30, 2029

This equivalency certificate authorizes NAAHAC members to transport empty means of containment, without removing the dangerous goods safety marks, from their place of business to the manufacturer/supplier facility of the dangerous goods, when they follow the conditions outlined in this certificate.

Some of the conditions for use of this Equivalency Certificate include:

• Must be a current member of COSTHA/NAAHAC.
• The required dangerous goods safety marks displayed on packagings are comply with the provisions found in Part 4 of the TDGR.
• The packagings are transported in closed transport units so that the dangerous goods safety marks are not visible in transportation.
• The documentation must must legibly display the following notations:
  • “Equivalency Certificate SU 8424 (Ren. 12)”, and/or
  • “Empty means of containment returning to manufacturer / supplier for reuse”.