OOSC, Part I, Item 2. b. Endorsements and 3. c. Endorsements - TDG Training Certificate

The current North American Out-of-Service Criteria (OOSC) identifies the Canadian Transportation of Dangerous Goods (TDG) training certificate as a licence endorsement in Sections 2.d and 3.c of Part I. In Canada, a TDG training certificate is not a driver licence endorsement. Under the Transportation of Dangerous Goods Regulations, the training certificate is issued by the carrier (employer) after determining that an employee has received adequate training and is competent to handle, offer for transport, transport, or accompany a shipment of dangerous goods. The certificate serves as proof of TDG training and competency, rather than an endorsement attached to a driver's licence. As the TDG training certificate is not a licensing credential, its inclusion within Part I, which addresses driver qualifications and licensing requirements, is not appropriate. It is therefore recommended that references to the Canadian TDG training certificate be removed from Sections 2.d and 3.c of Part I and relocated to Part III, where requirements related to dangerous goods transportation are more appropriately addressed.

A driver transporting dangerous goods is out of service when a person required by the Transportation of Dangerous Goods Regulations to hold a valid TDG training certificate is unable to produce a valid training certificate or demonstrate that they are operating under the direct supervision of a person who holds a valid training certificate. The TDG training certificate should not be treated as an endorsement on a licence for the following reasons: A TDG training certificate is issued by the carrier, not a licensing authority. The certificate demonstrates TDG training and competency, not driving privileges. Treating the certificate as a licence endorsement does not accurately reflect Canadian regulatory requirements. Therefore, placement in Part III would better align the requirement with its purpose and regulatory context.

Remove references to the Canadian TDG training certificate from Sections 2.d and 3.c of Part I of the OOSC and incorporate the requirement into a newly created TDG Training Certificate section in Part III of the OOSC. The OOS wording for the new TDG Training Certificate heading in Part III could be the same as the note in sections 2.d and 3.c. of Part I of the current OOSC.