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Change in consignor responsibilities regarding appointment of a DGSA


Whether or not BIFA Members should appoint a DGSA is a frequently discussed question. The general view is that Members should appoint a DGSA because they are organisations who pack, consign, load and/or carry dangerous goods


Traders must appoint a dangerous goods safety advisor (DGSA) if their business regularly transports, packs, fills, loads or unloads dangerous goods. This applies to goods sent by: • road, • rail, • inland waterway.


DGSAs are not expected to monitor


procedures related to the carriage of dangerous goods by sea or air. However, it should be remembered that most consignments to (air)ports travel by road, which brings BIFA Members within the scope of the regulations. There are exemptions to the requirement to appoint a DGSA, depending on how often your business handles dangerous goods and in what quantities.


Exemptions from the requirement to appoint a DGSA In Britain and Northern Ireland there are some exemptions from the requirement to appoint a DGSA.


The exemption applies if: • A business is involved in the carriage of dangerous goods in quantities per transport unit that are smaller than those referred to in 1.1.3.6, 1.7.1.4, and in chapter 3.3, 3.4 and 3.5 of the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR Regulations);


• If the main or secondary activities of the undertaking are not the carriage or related


April 2020


loading or unloading of dangerous goods, but the undertaking does occasionally engage in the national carriage or the related loading or unloading of dangerous goods posing little danger or risk of pollution;


• If that carriage operation complies with the conditions specified in the Road Derogation 11 (RO-bi-UK-1), the crossing of public roads, as set out in the Carriage of Dangerous Goods: Approved Derogations and Transitional Provisions document 2012;


• If that carriage operation complies with the conditions specified in 1.1.13 of the ADR Regulations.


The exemptions do not apply to international carriage.


Consignors only exemption


The rules that applied until 31 December 2018 said that you did not have to appoint a DGSA if


you only acted as a consignor of dangerous goods.


This has now changed and businesses that only act as consignors have until 31 December 2022 to appoint a DGSA. Whether or not BIFA Members should appoint/employ a DGSA is frequently discussed at the Association’s Dangerous Goods Advisory Group meetings. The general view is that Members should appoint a DGSA because they are organisations who pack, consign, load and/or carry dangerous goods.


Further information can be found in the publication ‘Employing a Dangerous Goods Safety Adviser’ which is published on the GOV.UK website. The DfT has also set up a dedicated e-mail address to answer dangerous goods-related questions at DangerousGoods@dft.gov.uk


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