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Policy & Compliance


Dangerous goods by sea – the importance of training


Following the introduction of a further amendment to the International Maritime Dangerous Goods Code, appropriate training for relevant shore-based personnel is more essential than ever


Approximately 10 years ago it became mandatory for all shore-based staff involved in dangerous goods transport by sea to be trained. From the enquiries received at BIFA and discussions at the Dangerous Goods Group, it is evident that there is still a lack of awareness of the need to meet this requirement. The latest amendment to the International


Maritime Dangerous Code (IMDG Code (38-16)) came into force on 1 January 2018 for two years and should prompt all those moving dangerous goods to review their training of staff. For a considerable number, too many in fact, the suspicion is that it is not a question about the adequacy of the training that has been provided, but whether training has been undertaken at all. Who needs to be trained? For the sake of


clarity, the IMDG Code defines the population of “shore-based personnel” as all who are involved in the shipment of dangerous goods and mandates that they receive training “commensurate with their responsibilities” before they undertake them. Training is therefore required by those who:


• Classify dangerous goods and identify Proper Shipping Names of dangerous goods,


• Pack dangerous goods, • Mark, label or placard dangerous goods, • [Pack/unpack] cargo transport units, • Prepare transport documents for dangerous goods,


• Offer dangerous goods for transport, • Accept dangerous goods for transport, • Handle dangerous goods in transport, • Prepare dangerous goods loading/stowage plans,


• Load/unload dangerous goods into/from ships,


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• Carry dangerous goods in transport, • Enforce, survey or inspect for compliance with applicable rules and regulations,


• Are otherwise involved in the transport of dangerous goods as determined by the competent authority.


In effect, the population of shore-based


personnel covers all who are involved in the shipment of dangerous goods by sea. The Code in Chapter 1.3 proceeds to describe


three levels of training, which are: 1. General awareness/familiarisation training – all persons should be trained to be familiar with the general provisions of the transport of dangerous goods, including classes, labelling, marking, placarding, storage, segregation and compatibility. Also included is the purpose of the dangerous goods transport document and the container/vehicle packing certificate.


2. Function specific training – persons must be trained in the specific dangerous goods transport provisions that are applicable to the function(s) undertaken. A guide to what provisions are applicable to a specific job function is provided in the table in IMDG 1.3.1.6. At this point, it is important to remind the reader that records of all training must be retained by the employer.


3. Safety training – commensurate to the risk of exposure in the event of the release of dangerous substances into the environment,


persons handling dangerous goods or in the immediate vicinity should be trained in the following activities: procedures for accident avoidance, available emergency response information, the general dangers posed by certain classes of dangerous goods, the personal protective equipment (PPE) to be used, and emergency procedures to be followed.


The IMDG Code 1.3.1.5 has a useful table that


identifies the function that shore-based personnel fulfil and provides specific training recommendations. It is important to train staff and have these records available. When engaging other parties in the supply chain, it is important to establish that they train staff appropriately and have these records available, should they be required. Such requirements should be included in any contracts between the parties involved. While there are many individuals and


companies who competently handle dangerous goods, there are still some who fail to do so. It was telling that when handling an recent enquiry, when asked whether they had read the relevant section of the IMDG Code, the caller replied “What is that?”


BIFA would like to thank the TT Club for providing the information on which this article is based.


April 2018


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