In the recently conducted survey on misdeclaration of dangerous goods 67% respondents said the reason as “ignorance of provisions of IMDG Code” while 33% said “willful default”.

IMDG Code says “The successful application of regulations concerning the transport of dangerous goods and the achievement of their objectives are greatly dependent on the appreciation by all persons concerned of the risks involved and on a detailed understanding of the regulations.”

How to ensure that all concerned have detailed understanding of the regulations? The code says, “This can only be achieved by properly planned and maintained initial and retraining programmes for all persons concerned with the transport of dangerous goods.”

Let us look at the “ignorance” part leading to misdeclaration or non-declaration of dangerous goods before asking ourselves how effective the training is, outreach of training, quality of training, knowledge and ability of trainers in preparing lessons and delivering same.

Are the shoreside personnel in blissful ignorance?

Organic search terms related to dangerous goods in some of the search engines shows a different view.  There may be some who remain in blissful ignorance, but many are actively looking up for information.

Below a sample data of search engine search terms

Below a sample data of search terms within www.shashikallada.com

Who is looking up for dangerous goods information?

There will be two groups looking up for information

1. Those who are already trained
2. Those who are not trained

In the above two groups both having access to IMDG Code & those not having to access to IMDG Code are looking for information which can assist them for compliance.

Training

The onus of providing training is with the entity who employs personnel to handle dangerous goods and entity must determine who must be trained and what level of training is required for the job involved. This training must be provided or verified upon employment in a position involving dangerous goods transport.

Mandatory training of shoreside personnel came into force from 1^st January 2010. The requirement is initial training & refresher training whenever new amendment is coming into force or any change in business practices.

Many organizations have put in place a well-planned system of training and retraining of their staff on a regular basis, many organizations have not. There is no statistical evidence of what number of people in the shoreside are actually involved in dangerous goods transport, in what functions they are involved and what percentage of them have received training.

As many countries do not have any governmental body verifying whether shoreside personnel are trained or not the effectiveness of this is very questionable.

Being trained and being an expert

After working for more than a decade out at sea and receiving formal training in IMDG Code, in my early days of working in shoreside dangerous goods department, I used to have many doubts and confusions with properties of dangerous goods but a gentleman at Physical and Theoretical Chemistry Laboratory at Oxford University was kind enough to help me whenever I needed clarification. I still find certain provisions of the Code difficult to understand and seek help from others to get right interpretation.

We all know a 2 day or full week training in IMDG Code only sets the foundation for understanding the Code, navigating through the provisions, interpreting the rules and applying same. Unless a person continuously applies the skills learnt during the training and put that into practice there will not be much improvement in compliance.

Additionally, every person who receives training will have more questions and doubts post training than she/he had before receiving training. Who they can approach with their questions and doubts?  Where they can get additional assistance for reaching conclusions for applying the Code?

Being trained and being an expert are entirely two different levels. Personnel should have expertise in interpreting and applying the Code and they should have access to other experts and resources beyond IMDG Code when needed for consultation.

In 2009 while discussing about complete revision of part 7 of IMDG Code my ex colleague said, “We need people to grow up to such a knowledge level even to challenge the IMDG Code when they find certain provisions does not make sense anymore”.

In the next article I will be discussing about the early stages of origin of training, the effectiveness of training, outreach of training, quality of training, knowledge and ability of trainers in preparing lessons and delivering same, post training situation of individuals in industry and what are certain shortcomings at dangerous goods departments of carriers.

I invite readers to submit their views and suggestion for improving safety in dangerous goods transport. Write your views below or mail me at shashi@shashikallada.com