ERAP Explained: Canada's Emergency Response Assistance Plan Rules

Some dangerous goods are too hazardous to move without a pre-approved response plan in place. Here is who needs an ERAP, when the law requires it, and what happens when one is activated.

What an ERAP is

Transport Canada describes an Emergency Response Assistance Plan as a plan that sets out what will be done if there is a release or anticipated release of certain higher-risk dangerous goods in transport. It lists the specialized personnel and equipment available to respond to an incident and the actions those resources will take. In short, it ensures expert help is in place before the shipment moves, so local first responders are not left facing chlorine, propane, or crude oil alone.

Part 7 of the Transportation of Dangerous Goods Regulations covers the whole life of a plan: the requirement to have one, the approval process, the authorization to use another person's plan, implementation, and compensation. The first question every consignor must answer before loading is: does this shipment need one?

When an approved ERAP is required

The trigger lives in one column of the regulations. Every dangerous good in Schedule 1 has an ERAP index in column 7, and Section 7.2 makes that number the line.

Section 7.2(1) then extends the rule beyond the single container. For road and rail vehicles, the quantities in more than one container are added together when the goods share a UN number and fall into the listed higher-risk groups: Class 3 flammable liquids that carry a subsidiary Class 6.1, Class 4, Class 5.2 Type B or Type C organic peroxides, and Class 6.1 Packing Group I. The total across more than one large means of containment counts for any UN number. For Class 1 explosives in one or more containers, measure the total against the lowest ERAP index among the explosives on board. For Class 2 gases, interconnected containers over 225 L each that are piped together and permanently mounted on a frame are treated as a single unit. And under paragraph (g), any quantity of Risk Group 4 human pathogens requires a plan, with a narrow exception for UN3549 medical waste.

That covers the index-driven cases. One more trigger has nothing to do with column 7 at all, and it moves through Canada every single day.

The rail rule: 10,000 L of fuel in a tank car

Read the list again: ethanol, diesel, gasoline, crude oil, aviation fuel. These are ordinary fuels, not exotic chemicals, and a rail tank car holding more than 10,000 L of any of them cannot move without an approved plan behind it. Which class each product belongs to, and why that matters for every other rule, is covered in our guide to the 9 classes of dangerous goods.

So a shipment crosses the line and needs a plan. Who writes it, and what does Transport Canada demand before stamping it approved?

How a plan gets approved

Section 7.3 requires a written application to the Minister, signed by the applicant, with a copy of the ERAP attached. The contents read like a full audit of the company's response capability: a description of the operations, the classification of the goods and modes of transport, the frequency of shipments, the container types, and the geographic areas covered. The application names an ERAP telephone number that reaches a person identified in the plan at any time while the goods are handled or transported, describes the communications systems available at an incident site, and attaches agreements with any third-party emergency responders.

It then inventories the response machine itself: a detailed equipment list with locations and the person responsible at each one, the names, responsibilities, training, and experience of technical advisors, team leaders, and response teams, the measures the team can take, and an estimate of how long personnel and equipment need to reach an incident. Under paragraph 7.3(2)(m), the applicant must also analyze potential incidents across four set scenarios: an anticipated release, a release of less than 1% of the goods in a container, a release of more than 50%, and a container exposed to fire, with the consequences and the tiered response measures for each.

Three supporting sections round out the process. Section 7.4 lets emergency response contractors not required to have a plan apply for approval anyway. Section 7.5 requires an application for approval of changes as soon as possible when any of the application information changes. Section 7.6 gives an applicant 30 days to request a review if approval is refused or revoked.

Writing all of that is a serious undertaking, which raises the question smaller shippers ask first: can someone else's plan cover my shipment?

Using another company's approved ERAP

The conditions are strict for a reason: the borrowed plan must match the exact goods, mode, containers, and geography; the plan holder must agree to respond; and the written authorization must exist before the ERAP information goes on the shipping document. Section 7.7(2) adds the record duty: the authorized user must be able to produce a copy of that authorization for two years after it is no longer in effect, and within 15 days of a written request from the Minister.

Approved, authorized, and on the road. Then a valve fails on the highway. What exactly does "implementing" the plan mean?

Tier 1 vs tier 2 implementation

Section 7.8(1) requires a person with an approved ERAP to implement it to tier 1 or tier 2 in response to a release or anticipated release. The two tiers are defined precisely.

One more rule sits in the same section, and it is absolute.

Nobody in the chain may block an ERAP team from acting. Every activation also generates paperwork, starting with a number printed on the shipping document.

The paperwork and the two Part 8 reports

For a shipment that requires an ERAP, the shipping document carries the ERAP information under paragraph 3.5(1)(i), including the ERAP telephone number that Section 7.3(2)(f) requires to be answered at any time while the goods move. That number matters because Part 8 points straight at it when things go wrong.

The table under Section 8.20 sets the threshold at any quantity for Classes 1 through 6 and Class 8, and at the radiation level established under section 39 of the Packaging and Transport of Nuclear Substances Regulations, 2015 for Class 7. Section 8.21 lists what the incident report must contain, including whether a container's integrity could be compromised and whether a transfer to another container is anticipated or required.

The second report closes the loop when the plan holder activates the response.

Section 8.23 lists the implementation report contents, including the ERAP reference number, which tier was activated, when, and the measures taken. Reporting duties like these appear on the certification exam, and you can test yourself on them with our free TDG practice test.

One scenario remains: an incident where the responsible company cannot be identified, or refuses to act. The Act has an answer, and it comes with a bill.

"Column 7 of Schedule 1 decides this before the truck is loaded. Check the ERAP index for every UN number on the manifest first, because once the goods are moving, the plan either exists or it does not."

Samira AliCertified Public Health Inspector, 10+ years across Canada and the U.S.

Compensation when the Minister directs a response

Under section 7.1 of the TDG Act, the Minister can direct or authorize a person with an approved ERAP to implement it in response to a release or anticipated release, including situations where it is not clear whose plan applies. When a plan holder responds under that authority, Section 7.9 of the regulations lists the expenses the government will compensate: costs related to death, disability, or injury of responders acting in good faith and without negligence, wages of employees and contractors reasonably required, use and repair of tools and equipment, travel expenses, heavy equipment rentals, attributable overhead, replacement of single-use supplies and of tools lost or damaged beyond repair, property that had to be damaged to carry out the response, defending legal actions where the Act removes personal liability, and cleanup, handling, and disposal costs.

Section 7.10 caps several categories, including limiting compensation for damaged property to its fair market value immediately before the damage. And the clock runs on claims.

The short version

• An ERAP is pre-arranged expert response. Approved by Transport Canada, with named people, listed equipment, and a phone number answered at all times.
• Column 7 of Schedule 1 is the trigger. Exceed the ERAP index for a UN number and the shipment needs an approved plan, with aggregation rules for multiple containers.
• Rail fuel has its own rule. More than 10,000 L of listed fuels, including gasoline, diesel, ethanol, and crude oil, in a single tank car requires a plan.
• Plans can be shared. An authorized user can rely on another person's approved ERAP under the Section 7.7 conditions, with written authorization kept on file.
• Tier 1 is remote; Tier 2 responds on scene. Both tiers provide advice and monitoring; resources are dispatched only at Tier 2, and nobody may block the response.
• Two Part 8 reports follow. An incident report to the ERAP number on the shipping document, and an implementation report to CANUTEC each time a plan activates.

Part 6 of the regulations lists ERAP requirements among the topics every trained person must know, so this material appears on the certification exam. Teams that handle these goods inside a facility pair the certificate with WHMIS training for the workplace side of the same chemicals.

Regulations evolve. This guide reflects the federal Transportation of Dangerous Goods Regulations as consolidated to June 17, 2026, including the SOR/2026-112 amendments to Parts 7 and 8. Consignors and carriers remain responsible for verifying their ERAP duties against the current regulations and Schedule 1 before shipping.