I recently returned from a trip to Falkirk, Scotland. Although I have traveled to more than 100 countries across the globe, I had never been to Scotland. The purpose of my visit? No, not the Single Malt Scotch nor the golf either! I traveled over 4,600 miles to take an exam. I sat for the Dangerous Goods Safety Advisor certification exam under the watchful eye of the Scottish Qualifications Authority. Although the test was also offered in Germany and China, my Chinese and German language skills are not quite up to par. Frankly, neither is my Scottish!
I figured that, having had 25+ years experience in the transport of dangerous goods by all modes, I would be able to quickly brush up on the standards of the European Agreements on the Transport of Dangerous Goods by Road (ADR) and Inland Waterways (ADN), take the “short” exam, receive my credentials and then I would enjoy the beautiful countryside in the midlands and highlands for the balance of my short trip.
How wrong I was; the exam was not short at all. There were four exams in total, each two hours in length. I found the exam to be extremely challenging, consisting of approximately 50 questions, all based on a typical shipping scenario. Much of the exam was comprised of essay questions, not the expected true/false and multiple choice questions that I’ve been accustomed to on other professional accreditation tests.
After completing the grueling 10-hour day, I reflected on the test I had just completed. It occurred to me that it was the same test required for all Dangerous Goods Safety Advisors, which the European authorities require each company to have in order to transport dangerous goods in other than limited quantities.
Dangerous Goods Safety Advisor
Within Europe and other ADR countries, shippers, carriers and other businesses involved with the transport of dangerous goods must usually appoint a Dangerous Goods Safety Advisor [Adviser] (DGSA) in order to comply with ADR and/or national regulations.
The DGSA has three main duties per the UK’s Health & Safety Executive (HSE):
- monitoring compliance with rules governing transport of dangerous goods;
- advising their business on the transport of dangerous goods; and
- preparing an annual report to management on the business’ activities in the transport of dangerous goods.
To become a DGSA, candidates must generally receive training from a specialized training organization and then sit for the various modal examinations. The DGSA qualification lasts five years. The examining body in the UK is the Scottish Qualifications Authority.
The rules involving the transport of dangerous goods are complex and each mode of transport (e.g., surface, air and ocean) has its own set of regulations. The various sets of regulations are based upon “Recommendations on the transport of Dangerous Goods: Model Regulations,” known as “The Orange Book,” issued by the United Nations Committee of Experts on the Transportation of Dangerous Goods and the Globally Harmonized System of Classification & Labeling. Although there are many similarities with respect to hazard communication, packaging and documentation, there is enough difference between the different modes that it really takes a well-trained person to understand the modal requirements in order to be fully compliant.
I thought to myself, why aren’t the U.S. standards the same as those of Europe? How can a person in the U.S. take a 30-minute online hazmat course and be “qualified” to offer dangerous goods for transportation in commerce? Why doesn’t the U.S. Dept. of Transportation (DOT) require each company to have a designated and “qualified” person, such as a Dangerous Goods Safety Advisor, at each location that offers hazardous materials for transport?
The DOT requires that all hazardous materials employees, as defined in 49 CFR 171.8 to receive training, be tested and “certified” by the hazmat employer in the following areas:
- General Awareness & Familiarization
General awareness/familiarization training is designed to provide familiarity with the requirements of 49 CFR subchapter C, and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standards of the DOT’s Hazardous Materials Regulations (HMR).
- DOT General Safety
Every hazmat employee is also required to receive safety training concerning: (a) emergency response information required by 49 CFR, part 172, subpart G; (b) measures to protect the employee from the hazards associated with dangerous goods to which they may be exposed in the work place, including specific measures the hazmat employer has implemented to protect employees from exposure; and (c) methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials.
- Hazardous Materials Security Awareness
Each hazmat employee must also receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats.
Each hazmat employee must be provided function-specific training concerning requirements of 49 CFR subchapter (or exemptions or special permits issued thereunder) that are specifically applicable to the functions the employee performs. As an alternative to the function-specific training requirements of the subchapter (49 CFR subchapter C), training relating to the requirements of the International Civil Aviation Organization (ICAO) Technical Instructions and the International Maritime Dangerous Goods (IMDG) Code may be provided to the extent that such training addresses those functions authorized by 49 CFR part 171, subpart C.
- Professional Accreditation
However, unlike Europe, the DOT does not require each dangerous goods shipper to employ an accredited hazardous materials professional. The DOT only specifies that the training provided to its hazardous materials employees be relevant and of sufficient length to meet the minimum regulatory requirements specified in 49 CFR § 172.704.
Because of the complexity of the HMR, companies should consider reducing the number of hazardous materials employees and assign those functions to a smaller group, which is then provided more detailed hazardous materials transportation training. Companies are also encouraged to consider funding the training for one or two individuals that seek professional accreditation.
In the U.S., there are several organizations that offer professional accreditations including the Institute of Hazardous Materials Managers (IHMM), the Dangerous Goods Trainers Association (DGTA), and the Board of Certified Safety Professionals through which you can earn the Certified Hazardous Materials Manager (CHMM), Certified Dangerous Goods Professional (CDGP), Certified Dangerous Goods Trainer (CDGT), Certified Environmental Health & Safety Trainer (CET) or Certified Safety Professional (CSP) designations. Each board certified accreditation requires that candidates have minimum educational and/or work experience, written letters of recommendations from peers and successful completion of a series of written exams.
To receive more information about professional safety and hazardous materials accreditations, contact ShipMate, Inc. at +1 (310) 370-3600 or contact any of the following organizations:
Institute of Hazardous Materials Management (IHMM)
11900 Parklawn Dr., Suite 450
Rockville, MD 20852-2624
E-mail: [email protected]
Dangerous Goods Trainers Association, Inc. (DGTA)
1138 N. Germantown Pkwy
Suite 101, #356
Cordova, TN 38016
Phone: +1 (901) 290-2270 International / +1 (888) 400-4953 toll-free (North America only)
E-mail: [email protected]
Board of Certified Safety Professionals (BCSP)
2301 W. Bradley Ave.
Champaign, IL 61821
Phone: +1 217-359-9263
Fax: +1 217-359-0055