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Rail Safety Advisory Letter 06/14

Monitoring program for the classification of mined gases and liquids

Place du Centre
4th Floor
200 Promenade du Portage
Gatineau, Quebec
K1A 1K8


15 August 2014

Ms Nicole Girard (ASD)
A/Director General, Transportation of Dangerous Goods
Transport Canada
330 Sparks Street
Ottawa, Ontario
K1A 0N5

Dear Ms. Girard:

Monitoring program for the classification of mined gases and liquids

On 06 July 2013, shortly before 0100 Eastern Daylight Time, eastward Montreal, Maine & Atlantic Railway (MMA) freight train MMA-002, which was parked unattended for the night at Nantes, Quebec, started to roll. The train travelled approximately 7.2 miles, reaching a speed of 65 mph. At around 0115, when MMA-002 approached the centre of the town of Lac-Mégantic, Quebec, 63 tank cars carrying petroleum crude oil (UN 1267) and 2 box cars derailed. About 6 million litres of petroleum crude oil spilled. There were fires and explosions, which destroyed 40 buildings, 53 vehicles and the railway tracks at the west end of Megantic Yard. Forty-seven people were fatally injured. There was environmental contamination of the downtown area and of the adjacent river and lake. (TSB Occurrence No. R13D0054)

The petroleum crude oil had originated in New Town, North Dakota and was destined to Irving’s oil refinery in Saint John, New Brunswick. The product, which originated from 11 different suppliers, was being shipped mostly as UN 1267, Class 3, Packing Group (PG) II product to the rail loading facility by highway tank trucks. Once the product was transloaded into the tank cars (i.e., about 3 truckloads to fill each tank car), the shipper billed all the tank cars out as PG III product.

The tank cars were picked up at New Town by Canadian Pacific Railway (CPR) and were transported to Montreal. The tank car shipping documents were generated by CPR based on the shipper’s instructions. According to the Transportation of Dangerous Goods Regulations (TDG Regulations), the consignor is responsible for determining the classification of dangerous goods before they are offered for transport. The accurate classification and characterization of dangerous goods is critical in order to select the proper packaging, handling, hazard communication (placards, labels), and emergency response procedures for safe transportation. It is also required to properly identify potential hazards when performing risk assessments.

Although monthly tests on collected composite samples were being performed at the rail loading facility, these tests were not being carried out for the purpose of product classification—nor was the PG information on the rail cars’ shipping documents reconciled with the corresponding information from those on the cargo tank trucks. Had this been done, the discrepancy could have been detected.

When the oil reached Irving’s refinery in Saint John, samples were collected and tests were performed, but mainly for operational reasons. There was neither a determination nor a verification of the product’s initial boiling point and flashpoint, nor were these required or part of Irving’s operational needs. Irving relied on its suppliers for the proper classification of imported dangerous goods, as permitted by the TDG Regulations. As a result, the petroleum crude oil being transported by the train was incorrectly classified as PG III (lowest hazard), and remained that way throughout the transportation cycle.

While the properties of manufactured dangerous goods are generally well understood and predictable, those of naturally occurring organic materials such as mined gases and liquids (i.e., petroleum crude oil, natural gas) can vary throughout the life cycle of the extraction process and from well to well. Moreover, variability in the properties of the product being shipped can also result from the blending of product derived from different sources when loaded into large bulk containers such as tank cars. This emphasizes the need for consignors to have a system in place to consistently ensure that such products are accurately classified before being offered for transport, and for Transport Canada (i.e., Transportation of Dangerous Goods [TDG]Directorate) to be able to effectively monitor the accuracy of product classification for the purpose of enforcement.

In 2011, the TDG Directorate identified the rapid increase in the transportation by rail of petroleum crude oil as an emerging issue requiring greater regulatory oversight. As a result, the TDG Directorate started inspecting petroleum crude oil transloading facilities, focusing on specific areas of regulatory compliance in facility operations, such as tank car loading and securement practices. However, these inspections did not include a verification of the classification of the petroleum crude oil being handled, offered for transport, transported, or imported.

Following the issuance of TSB Rail Safety Advisory 12/13 in September 2013 regarding the determination of petroleum crude oil properties for safe transportation, TC issued Protective Direction No. 31 in October 2013. In July 2014, amendments to the TDG Regulations were enacted to address the accuracy of petroleum crude oil classification by consignors. However, Protective Direction No. 31 and the July 2014 regulatory amendments do not explicitly address the variability in the properties of mined gases and liquids, such as petroleum crude oil.

Given the importance of packaging and transporting properly classified dangerous goods, Transport Canada may wish to review its monitoring and inspection program to ensure that mined gases and liquids, such as petroleum crude oil, are accurately classified throughout the transportation cycle.

The original version was signed by
Kirby Jang
Investigation Operations Rail/Pipeline