TT Talk - Reducing danger in the supply chain
Peregrine Storrs-Fox, the TT Club's Risk Management Director, comments on IMDG Code Amendment 34-08:
'As highlighted in the article in TT Talk Edition 115, a key change in IMDG Code Amendment 34-08 is the new mandatory training requirements for shore side staff involved in the preparation, handling and transport of dangerous goods by sea. Accidents involving packaged dangerous goods continue to occur and this measure is seen as an important element in the wider programme of tackling this issue.
The IMDG Code revision affects all those involved in classifying, consigning, packaging, marking, declaring, documenting, container packing, handling and accepting DG - a vast array of people through the entire supply chain, not just involved at the port or onboard ship. As the Club has previously advised, everybody involved in the chain, including booking staff, carry responsibility to be aware of and apply these important international rules.
The mandatory requirement comes into effect on 1 January 2010 and it is clear that the attitude that the maritime chain adopts is crucial. Furthermore, it is also clear that it must itself play a part in making this new provision effective. Those members, therefore, who deal with shippers, consignors and consolidators are encouraged to develop a simple strategy aimed at informing and, eventually, achieving the goal of the new requirement as far as its customers are concerned. It is recommended that this strategy should have a timescale of some 6-12 months and the following sequential points could form part of it, each following on at orderly intervals:
- Clearly informing the customer of the substance of the new requirements;
- Seeking information regarding the status of the customer's preparedness, i.e. are all relevant employees properly trained;
- Seeking a commitment to implement appropriate training;
- Seeking confirmation that all relevant employees have been trained; and
- Seeking evidence that all relevant employees have been trained.
As a start, Members are recommended to use the next four months to make a concerted effort to inform their customers in some detail of the requirement for training and to ask whether each customer's employees are trained.
Where customers are unable to find appropriate training help is at hand. The Club is aware of a number of different approaches being taken - from face-to-face training courses to online tools.
One example of the latter is an e-learning system developed by Exis Technologies. The course has been developed by a dedicated team of specialists and the support of industry and IMO, and has been certified against the DNV (Det Norske Veritas) Standard for Certification of Learning Programmes. It is tailored to the IMDG Code requirements for both general awareness and function specific training.
The course comprises modules dealing with topics such as classification or consignment, with elements corresponding to lessons. There are self assessment tests at the end of each element to ensure that a good understanding of the course content is being gained as the student progresses, building towards a Course Completion Certificate score.
IMDG Code e-learning can be downloaded and purchased from the course website for stand alone applications and is also available for corporate intranet for broader training programs (providing full administrator management including course configuration for job functions, setting pass marks and timeframes for completion and progress monitoring). Furthermore, the package can accommodate company-specific training elements. There is a course demonstration and online brochure at http://www.imdge-learning.com. For further information please contact Melanie Stephenson at Exis Technologies (+44 1325 467836 or email@example.com). Other information can be found also at http://www.hazcheck.com, including validation of products against the IMDG Code requirements, from packing to segregation and marking and placarding to documentation.
Whatever methodology is adopted, the underlying message is important: the new responsibilities to demonstrate training reach to the originator of any packaged dangerous goods - even the manufacturer. As the requirement will date from 1 Jan 2010, it does mean there is no time to be lost in ensuring that everyone involved in moving such cargo internationally is aware and trained. The Club lobbied for this legal change and now urges robust implementation through the industry.'
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Approaching a decade ago it became mandatory for all shore-side staff involved in dangerous goods transport by sea to have training. There's still too much to do!
The announcement of another fire on board a container ship early in January 2020 – the first publicised this year – reinforce the vital importance of increasing rigour around the transport of dangerous goods (and not just by sea).