Training in the requirements for the transport of dangerous goods (TDG) should be given to anyone whose job involves a function that may affect the safe transport of the dangerous goods.
This includes, for examples, those that:
- Choose the packaging and filling levels
- Decide on the labelling/marking
- Fill and label packages
- Load pallets
- Classify the goods
- Document the goods
Training should be given before commencement in the role (unless working under the direct supervision of a trained person) and periodically supplemented to refresh and keep up to date (due to changes that occur toward the end of every even numbered year) is recommended – for air it must not be longer than 24 months after the last training.
Training requires four aspects to be addressed, for each mode of transport (road, rail, sea, air):-
- An overall awareness of the whole scheme so that trainees are aware of the system of control used;
- Function specific training as appropriate to their involvement (e.g. if a person is responsible for documentation for road and sea, then training shall provide the detail requirements necessary). CHCS Module 8 “Classification for Transport”, Module 10 “Transport documentation and labelling”, and Module 70 “Packaging of Dangerous Goods for Transport” provide function specific training to meet the requirements of sea and road/rail, and just awareness of the air issues (see Note 4 below!);
- Safety training – appropriate to the likelihood of exposure to the goods (e.g. for someone who only documents the goods only very basic training would be needed);
- Security training – appropriate to the mode and subject to any exemptions - to make the person aware of the need and methods to try and keep dangerous goods out of the hands of terrorists and other criminals.
Notes:
- The term “awareness training” is often used without it being clear whether it relates to just point one above – or indicates that a minimum level to meet the requirements of all four points above has been addressed.
- For those just involved with what are called “Limited Quantity (LQ) packages”, there is no requirement under ADR/RID for training as above, but there is for any involvement with sea and the general requirements of the Health and Safety at Work Etc Act 1974 may indicate that such training is appropriate.
- For those companies who load, or carry, dangerous goods on vehicles whose load size exceeds the threshold laid down in ADR/RID 1.1.3.6 then they must appoint a Dangerous Goods Safety Adviser who, in ADDITION to the above, must have been trained and successfully passed the DGSA examinations within the last five years.
- Training for air must be carried out in accordance with the provisions of the Civil Aviation Authority (CAA) CAP 483, which, inter alia, requires that third party trainers must have passed a special instructors examination and be approved to train others. This applies whatever the level of involvement in transport by air of the employees being trained. NOTE BENE CHCS SDS Training Modules and Module 70 (Packaging of dangerous goods for transport) are NOT approved by the CAA, and any information about air provision is provided so that attendees can be aware of the air provisions in case they may subsequently consider becoming involved in this mode.
|