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Twelve drums, no documents, one leaking bung

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Twelve drums, no documents, one leaking bung

You are at a shipper's dock in east-end Montreal to pick up 12 drums, 205 L each, of a Class 3, Packing Group II flammable liquid with a flash point of 12 °C. Gross mass of the shipment is about 2,600 kg; the destination is a depot in Quebec City, about 250 km away.

The clerk hands you a bill of lading reading "Solvent - 12 drums" with no UN number, no class, no packing group and no 24-hour emergency number. The drums are unlabelled. No placards are offered. One drum is seeping at the bung and there is a strong solvent smell on the dock. Your TDG training certificate is current and in your wallet. You are alone, and you have gloves but no spill kit, no respirator and no other PPE.

1. Assess the shipment and decide: accept, refuse, or accept on conditions. Explain each deficiency and the basis for refusing.

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Refuse as presented. Each deficiency is independently disqualifying.

  • The document is not a shipping document. It must show the proper shipping name (a trade name like "Solvent" is not one), the UN number, the primary class (3), the packing group (II), the total quantity, the number and kind of packages, and a 24-hour emergency response telephone number or an ERAP number. Without those entries you don't know what you are carrying or who to call at 02:00, and the document is what a police officer or fire department reads first at a scene.
  • The drums are unlabelled. The Class 3 label is the shipper's responsibility. You cannot apply it yourself to make a non-compliant shipment compliant.
  • No placards. At about 2,600 kg gross you are well past the 1,000 kg gross mass threshold that triggers placarding for this class, so the vehicle must carry Class 3 placards. But you do not placard a load whose paperwork and packaging do not match the goods.
  • A leaking package may not be offered or accepted for transport. The seeping bung and the smell on the dock are the decisive facts.
  • Your training is the basis for the refusal, not a reason to proceed. Being trained means knowing how to recognise a non-compliant shipment and declining it, including when the dock is busy and the load is already on the apron.

Don't sign a document you know to be false, and note the refusal.

2. Assume the paperwork, labels, and packaging were all corrected. What must be in place before you leave the dock?

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Documents: a complete shipping document for every dangerous good in the load - proper shipping name, UN number, class, packing group, quantity, package count and kind, and a 24-hour emergency number. Where the class and quantity require an emergency response assistance plan, the ERAP number must be on the document and the plan must exist.

Marks and placards: Class 3 placards displayed on both sides and both ends of the vehicle, supplied and applied before departure. Placards must match the goods actually on board.

Training: your TDG training certificate is current and carried. Training certificates are time-limited (three years) and are the employer's obligation to provide and renew - check the expiry date, not just that the card exists.

Packaging: every drum upright, bung up, no leaks, and blocked or braced so the drums cannot roll, slide or fall against each other. Drums are heavy, round and unforgiving in a hard stop.

Vehicle: a charged fire extinguisher with at least a 5 BC rating, mounted and accessible; no smoking; the load area clear of anything that could puncture a drum; and a route check for restrictions that apply to placarded vehicles.

Only when every one of those is true do you sign for the load.

3. The seeping drum: what do you do in the first ten minutes, and what are you not going to do?

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First ten minutes:

  1. Stop the loading. Do not put that drum on the truck and do not accept it in any condition.
  2. Do not touch the bung. No tightening, no tape, no rags. It is the consignor's package and the consignor's problem; anything you do makes you the person who altered a leaking package.
  3. Remove ignition sources. A flash point of 12 °C means the vapour is flammable at ordinary dock temperatures - that, not toxicity, is the immediate hazard. No smoking, no running engines nearby, no hot work.
  4. Isolate and stay upwind. Keep other people and equipment back, and don't let the puddle spread toward a drain.
  5. Notify. Tell the shipper's supervisor, call your dispatcher, and call CANUTEC (1-888-226-8832, or 613-996-6666 collect) for advice on the product.
  6. If it spills beyond the drum - 911, evacuate upwind, keep everyone out, and report it. Do not wash it into a storm drain; do not attempt cleanup without training and equipment.

What you will not do: put on gloves and a hope, try to overpack it, hose it down, or drive it "just to the depot." Your role at a spill is isolate and notify - you are a driver, not a hazmat technician, and the training does not make you one. Record the refusal and the reason.