TT Talk - Unpacking the IMDG Code training obligation on land
It is inevitable that everything that is transported by sea starts and ends on land. As a result, the TT Club lobbied for training of shore side personnel in the requirements of the IMDG Code. While the United Nations continues to seek harmonisation across the different modes, it is necessary to be competent in handling dangerous goods throughout the anticipated transport chain. Good tools and training options are available, but is more required to ensure safety?
The IMDG Code requires the supply chain industry to 'train' those involved in dangerous goods. This obligation extends to shore-side personnel, where the Code states:
'Shore side personnel engaged in the transport of dangerous goods intended to be transported by sea shall be trained in the contents of dangerous goods provisions commensurate with their responsibilities'.
It is those last four words that are key as some have trained everyone in their organisation to the same level of competence, regardless of the precise role being undertaken. While too much must be arguably better than too little, neither is likely to aid compliance with what are complex regulations. In fact, the Code itself gives examples of the sorts of topics those engaged in certain tasks ('Function-specific training') should receive, against eleven 'indicative' roles that may be undertaken from initiating a dangerous goods shipment, through all aspects of transport and, implicitly, including emergency response. It should be noted that the IMDG Code provides detail about training shore side personnel only, since training of ship related personnel is covered under the Standards of Training, Certification & Watchkeeping (STCW) Code.How to comply with IMDG Code training
The TT Club's advice is that compliance with the IMDG Code training requirements can be summarised as:
- Ensuring that your own relevant employees are competent;
- Informing all your customers and contractors of their obligations to train to an appropriate level of competence; and
- Seeking documentary evidence that all relevant employees of your customers and contractors are trained to an appropriate level of competence.
'Competence' - or the ability to do a job properly - is based on both training and on-the-job experience.
There are, of course, many training courses and providers, sometimes supporting particular national regulatory requirements. Where effective training is not already in place and not easily available to you, the Club continues to recommend the IMDG Code compliance and training product range compiled by Exis Technologies, which has been expanded to cover road transport requirements arising from the ADR ('European Agreement concerning the International Carriage of Dangerous Goods by Road').Managing the sea/road interface
All dangerous goods regulations are based on the 'Orange Book', issued by the United Nations' Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and Labelling of Chemicals. While for many elements of the supply chain the regulations for each mode will be similar or identical, it is necessary to understand the differences. For example, when dangerous goods are moved into or out of Europe by sea under the IMDG Code, certain requirements imposed by ADR (or equivalent national regulations) must be met during the road leg to or from the port. Thus, compliance with the IMDG Code alone is not enough; ADR provisions relating to matters such as driver training, safety equipment, documentation and vehicle and trailer markings all need to be addressed.
Responding to this issue and the needs of many of its customers, Exis has enhanced its Hazcheck compliance systems to cover additional provisions and/or variations which apply during the road legs of a combined road/sea journey. For example, Hazcheck Online, an online subscription service, currently allows a consignor shipping a dangerous goods cargo transport unit to Europe to check the shipment against the IMDG Code; the new version also provides for the creation of a validation report highlighting ADR requirements for the road journey, including:
- tunnel restriction codes
- additional ADR documentation provisions
- transport unit marking and placarding
Additionally, ADR's Dangerous Goods List is available as a 'toolkit' which can be integrated into customers' software systems (alongside the IMDG Code data). Further, an ADR module has been added to Exis' IMDG Code e-learning package, the online training course which was developed in collaboration with the International Maritime Organization. As a result, students taking the IMDG Code course can now opt to include additional road transport elements covering the general provisions of ADR, additional documentation requirements, ADR carriage requirements and ADR exemptions.
The ADR module is intended for students already familiar with the international rules for the carriage of dangerous goods by sea and is designed to provide a means of extending knowledge of the sea regulations to cover European road regulations. It can be added to any of the courses - general awareness, function specific, advanced, freight forwarder or refresher.
Both the Hazcheck compliance systems and IMDG Code e-learning are necessarily regularly updated to reflect the latest editions of the IMDG Code and ADR. This alignment within the compliance and training software is welcomed, supporting the practical reality of intermodal transport and furthering the aspiration to bring greater harmonisation to the regulations for each mode. Further information is available atwww.hazcheck.com
.Time for a new way?
As yet the IMO has not followed the European requirement for organisations involved in the transportation, loading or unloading of dangerous goods by road to appoint 'one or more' Dangerous Goods Safety Advisor (DGSA). The responsibility of such an appointee is to 'guide. on the legal, safety and environmental aspects of the transport of dangerous goods [by road]'. Perhaps this role - part consultant, part mentor, part investigator, part auditor - should be replicated for other modes globally in order to strengthen compliance and reporting to Competent Authorities, and provide necessary expertise for safe operations through the supply chain.
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.Peregrine Storrs-Fox
Risk Management Director, TT Club