TT Talk - Dangerous goods training
The inter-relationship between training and competence must be a pressing issue in relation to the transport of dangerous goods, surely? Here’s a review of the current state.
Training, supported by the appropriate training records, is the cornerstone of any successful organisation, in that it ensures that employees are aware of their roles and duties and, for employers, that their staff are trained. Dangerous goods training complements the general safety training undertaken by an organisation and can be considered to be an ‘advanced’ element supplementing such a training programme.
There is, however, a misconception that having been given training there is competency to carry out a role. Training alone does not check that the employee is competent; there needs to be systems in place to ensure demonstrable competence, and appropriate supervision until an employee is deemed to be competent.
"Training alone does not check that the employee is competent"
Whilst the UN Model Regulations for the transport of dangerous goods (the UN Orange Book) are the basis for each set of modal regulations, the requirements for dangerous goods training and how it is implemented varies from
• mode to mode (air, road, rail, inland waterway and sea)
• region to region, (e.g. Europe, North America)
• and country to country (e.g. Germany, USA)
Such variations are as result of the culture within that mode and/or within the region.
The air mode has always been the gold standard for dangerous goods training, albeit that some claim that the process is very bureaucratic, especially those organisations offering dangerous goods training.
For the air mode the legal requirements of ICAO (International Civil Aviation Organization) are given in their Technical Instructions for the safe transport of dangerous goods by air, while IATA (International Air Transport Association), the trade association for the world’s airlines (representing some 280 airlines or 83% of total air traffic), brings the ICAO regulations into force through their own dangerous goods regulations, which have been developed over the years with input from their members, governments and ICAO.
IATA dangerous goods training requires that initial and recurrent in-depth training (every two years) must be taken by shippers and their agents, packers, freight forwarders, cargo agents, operators (or airlines), agencies handling operators and performing the cargo acceptance function. Additionally, IATA has an accreditation scheme for dangerous goods training schools and authorised training providers.
The air mode has taken the lead in developing the provisions and guidance material under a competency-based approach for dangerous goods training to be implemented in 2019-2020.
Training has always been required for seafarers under STCW (The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers) and, from 2010, it became mandatory for shoreside personnel under the IMDG Code (International Maritime Dangerous Goods Code).
In the process of making training mandatory there was much debate as to the level of detail and prescription required of employers (entities), and a compromise was reached that required entities to make an assessment as to who and to what level training is needed and to maintain training records.
Tables which outlined the various roles within an entity and training required were retained but for guidance only, as IMO (International Maritime Organization) recognised that each entity is different and that the entity was best placed to determine the level of training required.
Over the intervening period since the introduction of mandatory training, European administrations have made proposals for shippers who transport dangerous goods either to employ or retain a Dangerous Goods Safety Adviser (see Road, rail & inland waterways); thus far, such proposals have not been accepted.
Road, rail & inland waterways
These regulations (road – ADR, rail - RID and inland waterways – ADN) have training regimes similar to the IMDG Code. There are additional requirements for ‘drivers’, and organisations that handle, process or transport dangerous goods on a regular basis, to appoint a Dangerous Goods Safety Adviser (DGSA). Exemptions potentially apply where small quantities are handled or there is only occasional transport of dangerous goods.
The DGSA’s duties and responsibilities include:
• monitoring compliance with rules governing transport of dangerous goods
• advising the business on the transport of dangerous goods
• preparing an annual report to management on the business’ activities in the transport of dangerous goods
• monitoring procedures and safety measures
• investigating and compiling reports on any accidents or emergencies
• advising on the potential security aspects of transport
Nevertheless, the DGSA’s primary role is to provide advice to management of the organisation. It is the responsibility of the management of the organisation to ensure that a DGSA is appointed, and that systems and procedures are in place to manage their dangerous goods regulations.
The DGSA is a formal qualification and the ‘All Classes’ option gives an overall background on dangerous goods, but it also depends on the modal option chosen e.g. road, rail or inland waterway. It is a mis-conception that the DGSA qualification means that the person is qualified for all modes of transport, including sea and air. It is a qualification which is recognised in other ADR signatory countries.
In summary, it can be seen that there is little outside the air mode in relation to competency based training. Interestingly, Canada submitted a report to UN Sub-Committee of Experts on the Transport of Dangerous Goods for the meeting in June 2018 on aspirations to develop a training standard. This is an important and commendable initiative.
We gratefully acknowledge the assistance in the preparation of this article of Keith Bradley, formerly Hazardous Cargoes Adviser, UK Maritime & Coastguard Agency
We hope that you have found the above interesting. If you would like further information, or have any comments, please email us, or take this opportunity to forward to any colleagues who you may feel would be interested.
We look forward to hearing from you.
Risk Management Director, TT Club