Submission 1: Transportation of Dangerous Goods and PSAC Equivalency Certificates
Did you know that PSAC offers members access to four Transport Canada Equivalency Certificates that allow for the transportation of various goods in a way that meets the unique needs of our industry? Click here to find out more.
What is an Equivalency Certificate?
If a person wishes to carry on an activity related to transporting dangerous goods in a way that is not in compliance with the Transportation of Dangerous Goods (TDG) Regulations, they must apply for an Equivalency Certificate following the information requirements in Part 14 of the TDG Regulations and must show that the way in which the activity will be carried on will provide a level of safety equivalent to complying with the Regulations.
PSAC Equivalency Certificates:
PSAC has the following Equivalency Certificates which require current proof of membership with the Petroleum Services Association of Canada for their use. Members are required have a paper or electronic copy of the relevant Equivalency Certificate along with proof of PSAC membership which accompanies all transports of dangerous goods. These documents must be produced for an inspector or officer immediately upon request.
Note: Please ensure that you have the most current version of the Equivalency Certificate. Previous versions become invalid as soon as a new version is issued by Transport Canada. Please reach out to Andrea Hardie or Doug Journeay for updated versions of Equivalency Certificates
Updates to Equivalency Certificate SU 12967 to Address Transportation of Propane Tanks in a Wellsite Shack
During a review of TDG documentation, a member identified an issue for transporting propane tanks in a wellsite shack. Equivalency Certificate SU 12967 for the transportation of service and drilling rigs covers the transportation of class 2.1 Flammable Gas up to a gross mass of 500 kg. The challenge: when a wellsite shack has both of its propane tanks full, the gross mass will typically exceed that limit.
To address this situation, PSAC has obtained approval from Transport Canada to amend the Equivalency Certificate to allow for an increased volume of the gross mass of all dangerous goods transported on this Equivalency Certificate to be less than or equal to 750 kg.
The new amended Equivalency Certificate SU 12967 was distributed to impacted members on April 28, 2022. If you have not received a copy and currently use SU 12967 in your operations, please reach out to Andrea Hardie or Doug Journeay.
Updates to Equivalency Certificate SH 11775 to Modernize Wording and Provide Clarity Around the Use of a Fifth-Wheel Trailer
It was recently identified by our Oilwell Perforators Council that the wording in the current Equivalency Certificate under Clause 3 subclause (b) does not accurately reflect the different methods of transportation of guns that are used in the industry, namely accounting for the use of fifth-wheel trailers or the “pallet” transport that is common in pump-down perforating operations. When using a flat deck trailer, the requirement in previous versions of the Equivalency Certificate for the use specially built racks or carrying cases wouldn’t apply as the guns are instead secured properly to each other. We rely on the jet perforating guns to touch for load securement.
In 2008, PSAC Oilwell Perforating members funded a PSAC study on drop and vibration testing of jet perforating guns that are used by members. The data from this study is required as part of an application to Natural Resources Canada’s Explosives Regulatory Division to assemble, store, and transport jet perforating guns and provides for the justification of Equivalency Certificate SH 11775 in the transportation of Class 1, Explosives, jet perforating guns and initiation systems.
The new amended Equivalency Certificate SH 11775 was distributed to impacted members on August 19, 2022. If you have not received a copy and currently use SH 11775 in your operations, please reach out to Andrea Hardie or Doug Journeay.