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WHAT IS A DANGEROUS GOODS SAFETY ADVISOR?

A dangerous goods safety advisor (DGSA) is a person certified to provide advice to the employer or undertakings whose activities include the consigning, carriage, or the related packing, loading, filling or unloading of dangerous goods, to monitor compliance with the legal requirements and ensure the preparation of an annual report.

Since January 2000, companies and organisations involved in the transport of dangerous goods have been required to appoint at least one qualified DGSA and before undertaking involvement in the carriage of dangerous goods. The DGSA can be the head of the undertaking, an employee or an external DGSA – provided the person is capable of performing the duties of a DGSA. This requirement covers Road, Rail and Inland Waterways.

An Advisor must hold a certificate gained by passing a written examination. The examinations are designed to test 3 levels of understanding:

  1. Knowledge and understanding of the principal areas of a topic
  2. General understanding of a topic and the ability to apply that knowledge
  3. Comprehensive knowledge of a topic and the ability to apply it in practice

Principals duties of a DGSA

Monitoring Compliance

The DGSA can undertake activity audits personally or by those nominated by the DGSA or the Employer/Undertaking. The DGSA, however, needs to see the results of the audits and decide which items require action, and, of these, determine which can be delegated to others.

The auditing process must be seen as cyclical and carried out in the following order:

  1. Audit
  2. Report
  3. Undertake actions to be carried out (including timescale)
  4. Re-audit
  5. Report
  6. Undertake further actions to be carried out.

The frequency of the cycle and the timescale depends on:

  1. What breaches of regulations are identified
  2. What hazards are identified combined with an assessment of the risk of the hazards causing an accident (eg in this context a hazard is something that has the potential to cause harm and risk is a measure of the likelihood that harm from a particular hazard will occur).
  3. The number of actions identified.

Advising the Employer / Undertaking

The Employer/Undertaking should, when applicable, seek the advice of the DGSA concerning transporting dangerous goods. Especially when:

  • considering a different mode or containment systems not previously used
  • New types of dangerous goods are to be transported.

Note: DGSA’s should ensure that they do not give advice on modes of transport or classes unless they are suitably trained to give that advice. The DGSA should seek external advice if needed.

Preparing the Annual Report

The content of the annual report must record in reasonable detail all activities in respect of the carriage of dangerous goods during the period in question.

The following is a list of suggested topics for consideration for inclusion in the annual report:

  • the total tonnage of dangerous goods carried during the year
  • The different containment systems used
  • The tonnage carried by each transport mode
  • The classes of dangerous goods and percentage split by tonnage
  • The total number of accidents per transport mode and per containment system, including details of the previous year’s figures
  • A commentary on any common causes of accidents, eg. Staff errors, mechanical failures or defects in containment systems
  • The number of prosecutions and or prohibition notices or other formal warnings with a comparison to the previous year
  • The number of audits conducted with a comparison to the previous year
  • The names of people trained and a brief description of the training given, including training of the DGSA
  • A commentary on any reasons identified as to why the reporting years’ safety performance is better or worse than the previous year, and any actions implemented or proposed

The reports should be drawn up without undue delay (eg a maximum of 3 months following the end of year, although a specific length of time is not outlined in the ADR/RID Regulations).

The employer/undertaking must ensure that the annual reports are kept in a safe and secure place for at least the specified minimum time of five years.

The DGSA’s duties also involve monitoring the relevant procedures and practices of the employer/undertaking, in particular monitoring that:

  • compliance with legislation governing the identification of dangerous goods for transport is followed
  • Special requirements are taken into account when purchasing vehicle sales for the transport of dangerous goods
  • Equipment used in connection with the transport of dangerous goods is checked
  • Employee training is completed and relevant training records are maintained
  • Accident or incident emergency procedures are used during transport
  • An investigation into and, if appropriate, which occur during the transport of dangerous goods in relation to the employer’s/undertakings activities are completed
  • Appropriate measures to avoid the recurrence of accidents, incidents or serious infringements are implemented
  • Legal and special requirements relevant to the choice and use of subcontractors and third parties in relation to the transport of dangerous goos are followed
  • Employers/undertakings have detailed operational procedures and instructions in place
  • Measures to increase awareness of the risks inherent in the transport of dangerous goods are introduced
  • Procedures to verify that required documentation and safety equipment on board the transport unit are in place
  • Procedures to ensure compliance with legislation governing the loading and unloading of dangerous goods are implemented
  • When applicable, a security plan for High Consequence Dangerous Goods is in existence.

While the DGSA Regulations at present cover only surface transportation, the DGSA must be aware of other modes if applicable and how they interact wi5 the surface modes.

In Practice

The first task of a newly appointed DGSA is normally to prepare a survey of the employers’/undertakings activities connected with the transport of dangerous goods. This survey should include:

  • Details of the classes of dangerous goods transport, including loading and unloading operations
  • Details of the types of containment systems used, eg packages, bulk, tankers or tank containers
  • A list of which individuals have responsibility for which area of activity
  • An assessment of each individuals capacity to perform the required tasks
  • An assessment of any training needs, including immediate and long term needs
  • Details of the activities and / or tasks for which written procedures exist
  • Details of activities for which written procedures do not exist
  • Details of procedures that exist but which are considered inadequate and do not conform with legal requirements
  • Details of the ways in which existing activities and procedures are currently audited and managed

The survey should also identify goods which are packaged in Limited Quantities or Excepted Quantity packages and determine whether the quantities involved will exceed the ADR and RID threshold above which certain small load relaxations can no longer be applied.

The following activities should be carried out based on the initial survey:

  1. The employer/undertaking should allocate responsibilities to the DGSA
  2. A training action plan/matrix should be produced
  3. New procedures should be written to fill any identified gaps or replace any inadequate procedures, these should include auditing and management systems.

Legislation

DGSA’s are required to keep upto date with changes in legislation, guidelines and industrial good practice. Any necessary changes to procedures should be made available to all staff at all applicable locations.

To ensure uniformity of application and to prevent the use of out of date documents, it is suggested that a system of document control should be implemented.

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