IMDG CODE

PROPOSED TRAINING REQUIREMENTS FROM 01 JAN 2010

Introduction

IMDG Code Training Requirements With the mandatory adoption of the 2008 edition of the IMDG Code on the 1st of January 2010 training will be mandatory for shore based personnel engaged in the transport of dangerous goods by sea.

IMDG Code Training Requirements

The training requirements are contained chapter 1.3 of the IMDG code. Training for sea going personnel is already mandatory by virtue of the requirements of the STCW Convention, so these requirements do not relate to this segment of the industry.

IMDG Code Training Requirements

Section 1.3.1.1 of the code outlines the mandatory requirement: Shore based personnel engaged in the transport of dangerous goods intended to be transported by sea shall receive training in the contents of the dangerous goods provisions commensurate with their responsibilities..

IMDG Code Training Requirements

Not all of Chapter 1.3 is Mandatory with sections 1.3.1.4 to 1.3.1.7 remaining recommendatory..

however, they do provide guidance as to

the nature of training that should be provided..

IMDG Code Training Requirements Chapter 1.3 has three main training elements: 1. 2. 3. General awareness training (mandatory) Role specific training (mandatory) Safety Training (recommendatory)

It is reasonable to accept that safety training will addressed both as part of normal OH&S training provided and by general awareness training so AMSA will not add any additional regulatory requirements for this element.

Mandatory Training Requirements

IMDG Code Training Requirements The two mandatory training requirements apply a range of shore based personnel involved in the shipment of Dangerous goods by sea, namely those that: classify dangerous goods and identify Proper Shipping Names of dangerous goods; pack dangerous goods; mark, label or placard dangerous goods; load/unload CTUs;

IMDG Code Training Requirements 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; carry dangerous goods in transport;

IMDG Code Training Requirements enforce or survey or inspect for compliance with applicable rules and regulations; or are otherwise involved in the transport of dangerous goods as determined by the competent authority It is an eye watering list . but the scope of training can be tailored to the individual roles as indicated in section 1.3.1.1 of the IMDG Code.

IMDG Code Training Requirements To comply with the mandatory elements of Chapter 1.3 the training systems need to achieve a number of outcomes: All Supervisors must have general awareness training and be appropriately trained in relation to their role; Staff (as identified above) must have general awareness training and be appropriately trained in relation to their role;

IMDG Code Training Requirements Where staff are not trained they must be under the supervision of someone who is trained pending completion of training. Staff and their employers are to keep records of training undertaken and these are to be available upon request. Refresher training will be required for role specific training (AMSA is currently considering a five year cycle for this)

What is General Awareness Training?

IMDG Code Training Requirements General awareness training is intended to be an overview of the requirement that relate to the carriage of dangerous goods. It should be noted that the general awareness training requirements of chapter 1.3 of the IMDG Code would be the same as those provide under regulation 1.3 of the Model Regulations adopted with ADG7.. so Where training has accordance with this it been provided in

IMDG Code Training Requirements

.. where training has been provided in accordance with regulation 1.3 (or relevant state legislation adopting regulation 1.3) this will be accepted as being the same as general awareness training provided employers and employees have a record of this training. Similarly..

IMDG Code Training Requirements

Similarly where staff have received OH&S work place training which provides the overview required this will is also acceptable as general awareness training but .. .employers must ensure all the elements described in the IMDG code are covered and employers and employees have a record of this training. AMSA does not envisage requiring additional training in both these scenarios.

IMDG Code Training Requirements

So what does General Awareness Training include: A description of the classes of dangerous goods; An overview of labelling, marking and placarding requirements: and An overview of packing, stowage, segregation and compatibility provisions. A description of the purpose and content of dangerous goods transport documents

IMDG Code Training Requirements

And finally a description of available emergency response documents A first glance it may seem daunting list but it must be remembered this is simply an overview and greater detail need only be provided where it is considered necessary by the individuals role. That detail will be provided by function specific training.

Role Specific Training

IMDG Code Training Requirements

Under section 1.3.1.1 of the IMDG code it will be the employer who decides what training will be provided but. .. AMSA may undertake audits to determine the effectiveness of such training. This begs the question as to how the employer can determine what training is required for a given role.

IMDG Code Training Requirements

For role specific training guidance is provided in the recommendatory sections 1.3.1.5 and 1.3.1.6 of the IMDG Code. These two tables match training needs with particular functions to assist employers (and training providers, where relevant) in ensuring training is commensurate with responsibilities. If we look at table 1.3.1.6 we can see how this information is provided.

IMDG Code Training Requirements

IMDG Code Training Requirements

This does not mean that AMSA will leave the process of selecting appropriate training entirely in the hands of the employer It is envisaged that for a number of specific functions the training course employed will need to be approved by AMSA. On this note it is time to look at AMSAs role.

How will AMSA apply this?

IMDG Code Training Requirements

The requirements for training will be adopted through changes to Marine Orders Part 41. It is envisaged these changes will:
Require mandatory training for shore based personal as identified by the IMDG Code and set a period for refresher training for function specific training; Make provision for AMSA to audit the provision of training; Allow the Manager, Ship Inspections to accept other training as equivalent to these requirements; but .

IMDG Code Training Requirements

Will also mandate acceptance by AMSA of training courses to be undertaken by individuals who will responsible for specific tasks/functions.

This requirement will be applicable to persons who will be responsible for:

packing dangerous goods; marking, labelling or placarding dangerous goods; preparing transport documentation and signing declarations (shippers and container packing declarations)

IMDG Code Training Requirements

Where acceptance by AMSA is required this will be granted by the Manager Ship Inspections. While this arrangement is not dissimilar to training requirements established by CASA it is accepted that some time will be required to have course accepted. It is also noted that many in the industry have, or are in the process of receiving training with course that cannot be approved until the regulations are in place.

IMDG Code Training Requirements

To resolve this issue AMSA is considering implementing training requirements in a staged approach, for example:
1. By the 1st of January 2010 the training requirements as detailed in chapter 1.3 of the IMDG code will need to be implemented , but without AMSA acceptance of courses. By the 1st of January 2011 individuals undertaking those function that require accepted training must have received training accepted by AMSA.

2.

Where to from here?

IMDG Code Training Requirements

As you may have gathered from the presentation we are still finalising the detail of what will be required. In this regard input is most welcome, however if you want to make comment you will need to be prompt. Comments and suggestions may be to

IMDG Code Training Requirements

Comments to:

dangerousgoods@amsa.gov.au

Any Questions Please