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Spray September 2016

34 Spray September 2016 Steven CharleS hunt President, ShipMate, Inc. From here to there: Topics in Transportation Dangerous Goods Safety Advisor 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 At 98.5 feet, the Kelpies in Falkirk, Scotland, are the largest equine sculptures in the world. 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).


Spray September 2016
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