Does my company need an ERAP?

What an ERAP actually is

An ERAP is required under the federal Transportation of Dangerous Goods Regulations. It applies to the person who offers dangerous goods for transport or imports them, not to the carrier. That distinction catches people out: you can hand a load to a trucking company and still be the party holding the obligation.

The plan has to describe a real capability. Transport Canada is assessing whether specialists and equipment can actually reach an incident involving your product, in the quantities you ship, anywhere along the route. A document that lists intentions without resources behind it will not be approved.

What triggers the requirement

Two things together decide it: the specific dangerous good, and the quantity in a single means of containment. The regulations list which goods require a plan and the index quantity above which it applies. Some goods require an ERAP at any quantity; many require none at all.

• ▸Identify the shipping name and UN number for every product you offer for transport
• ▸Check each against the ERAP requirement in the regulations, including the index quantity
• ▸Apply the quantity test per means of containment, not per shipment or per year
• ▸Repeat the check whenever a product, packaging or volume changes

What approval involves

An application goes to Transport Canada with the plan itself and supporting detail on your response capability, equipment and personnel. Submissions and subsequent correspondence run through ERAP Online Services. Expect questions. An approval carries a number and an expiry, and it can be issued with conditions.

Keeping it alive

An approved plan is a live obligation. Products change, volumes change, contact lists drift, and response resources move. Amendments are required when the plan no longer reflects reality, and renewal is required before expiry. Most plans that fail an audit fail on currency rather than on content.

• ▸Review after any change to product, packaging, volume or route
• ▸Exercise the plan and keep the record: regulators ask for evidence, not assurances
• ▸Track the expiry date separately from your last revision date
• ▸Confirm your named response provider is still able and willing to respond

Where we fit

We write ERAPs, submit them, carry the correspondence through to approval, and are named on plans as the response capability. That last part matters, because a plan naming a provider who cannot demonstrate capability is the most common reason an application stalls.