The Chamber of Shipping has responded to Transport Canada’s second discussion paper on potential regulations to increase access to marine emergency services and to improve response to pollution incidents. On behalf of our members we support the continued engagement and consultation on this import initiative, particularly in view of the imminent implementation of the International Maritime Organization’s 2010 Hazardous Noxious Substance Convention (HNS Convention). Canada was one of the first countries to ratify the HNS Convention in April 2018.
Our recommendations to Transport Canada on the discussion paper include:
- adopting a risk-based and proportionate approach to HNS requirements, considering cargo type, volume and operational context;
- allowing integration of HNS plans with existing oil pollution response plans to reduce duplication;
- exploring the potential expand the role of existing oil spill Response Organizations to support HNS preparedness and response;
- establishing or supporting access to centralized technical expertise for HNS incidents; and
- engaging further with affected industries, including mining, agriculture, and bulk commodity sectors, to fully understand operational impacts.
Click here to view our full submission dated April 17, 2026.
