TT Talk - Do you comply with dangerous goods legislation?
Readers may recall being invited to take a quick survey in Edition 133 on 21 September 2010 in relation to compliance with the shoreside training requirements mandated in the IMDG Code from 1 January 2010. ICHCA International carried out a parallel survey amongst its membership. The level of completion of the survey was reflected in the substance of the responses given.
Disturbingly, 15% of logistics and terminal operators admitted they had not implemented an effective training programme within their own organisation for all relevant employees. Just 45% of respondents confirmed that they had clearly informed their customers of the detail of the training requirements in IMDG Amendment 34-08. And only 30% advised that they had received documentary evidence that all relevant employees of the customer had been trained.
The Club has repeatedly alerted the industry to the training requirements and therefore the findings are surprising. They would appear to confirm anecdotal evidence that the shoreside supply chain market falls into the following categories:
- Those who are simply unaware that this training is mandatory and that they have to comply;
- Those that recognise the training is mandatory but believe that it will not be enforced in their jurisdiction or that there will be a period of grace;
- Those that are aware that the training is required, but it is not a priority;
- Those that have put training in place.
Let's also explode the myth that awareness and familiarisation training is adequate; the Code clearly requires function specific training. What's more, Amendment 35-10 (see below), which entered transitional force on 1 January 2011, has been modified to require that employees 'shall be trained' and training records have to be kept by the employer.
Where effective training is not already in place in your company and not easily available to you, the Club continues to recommend the e-learning system developed by Exis Technologies. This certified course, developed by a dedicated team of specialists, is tailored to the IMDG Code requirements for both general awareness and function specific training. A demonstration of IMDG Code e-learning and online brochure can be downloaded here. For further information please contact Melanie Stephenson at Exis Technologies +44 1325 467836 or email Melanie.
Other information can be found on the Hazcheck website, including validation of products against the IMDG Code requirements, from packing to segregation and marking and placarding to documentation. You can order Exis Technologies IMDG training through ICHCA International and this will attract a discount for TT Club and ICHCA members.
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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!