Operational Policy 4 - Grandfather Clause

Canadian EQAT along with Transport Canada has recently developed a CVSA Dangerous Goods Course which requires implementation. There currently is not a CVSA Dangerous Goods Course in Canada and therefor are no CVSA inspectors that are "CVSA certified" in dangerous goods. An amendment to Operational Policy 4 is being requested to grandfather dangerous goods-trained CVSA inspectors.

Current requirements in Ops 4 for Hazardous Materials/Dangerous Goods Inspection Certification require inspectors who are certified to conduct Level I, II or V inspections to complete and pass a CVSA-approved DG inspection course. The new CVSA soon-to-be-approved DG course is expected to be implemented in Canada as of April 1, 2026. CVSA inspectors in Canada do not enforce dangerous goods requirements unless they have been formally trained and pass either a federal course, instructed by Transport Canada, or their provincial course, which closely mirrors the federal course. Along with taking and passing the course, they must be either provincially or federally designated as a DG inspector for proper authorities. An amendment to Ops 4 to include a grandfathering clause is being requested to grandfather existing CVSA inspectors who are Level I, II or V certified and have successfully taken and passed a federal or provincial DG training course in lieu of needing to take the new CVSA DG Inspection Course. Requiring inspectors who have already successfully taken and passed a federal or provincial DG training course to take the CVSA DG course would cause unnecessary burden on agencies training programs.

After the last paragraph in the Hazardous Materials/Dangerous Goods Inspection Certification in Operational Policy 4 (on page 6, just before the Cargo Tank Inspection Certification section starts), the following addition is requested: Grandfathering of Canadian Inspectors Canadian inspectors who hold a certificate of proficiency to conduct North American Standard Level I, II or V Inspections and have completed and passed a provincial/territorial or federal dangerous goods course prior to April 1, 2026 are not required to meet the requirements of Operational Policy 4 regarding Hazardous Materials/Dangerous Goods Inspection Certification. The requirements in Operational Policy 4 only apply to new inspectors certified on or after April 1, 2026. All inspectors under this provision shall remain certified to perform dangerous goods inspections, provided they continue to meet the requirements of Operational Policy 4 regarding “General Maintenance of Certification”.