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Dangerous Goods Regulations amendments

Be prepared for the changes – by Elliot Molemi, Professional Aviation Services

There are new and overdue proposals to amend Part 92 Regulation of the Civil Aviation Regulations (Dangerous Goods regulations). In summary the proposals seek to give effect to ICAO’s requirement of competency-based training (CBTA) of which all member states must comply with by December 2022, we will discuss this in our next article in due time.

The other proposals which are the purpose of this article, is to strengthen the existing regulations on the conveyance of dangerous good by air. Some of the most significant amendment proposals are discussed below.

Applicability

The new regulations will see the introduction of measures now applying to other industry players other than operators and shippers. The affected industry players will now be:

      • operators (including foreign operators),
      • courier companies,
      • freight forwarders,
      • consolidators,
      • shippers,
      • mail companies,
      • packers of dangerous goods,
      • ground handlers of both passenger and cargo,
      • Remotely Piloted Aircraft Systems (RPAS),
      • ATOs, airports or aerodromes
      • and companies involved in testing packages to be used for transportation of dangerous goods by air.

Approval/Authorisation

All operators, packing companies and companies involved in testing of packages will now have to be approved by the SACAA to operate their business. The approval is subject to an application which must include the Dangerous Goods procedures manual (as directed by the Technical Instructions) and the Dangerous Goods training programme. It is not yet clear if a list of entities approved will be published, but logic dictates that this will be the case as it is practice with the publication of ATOs, ASTOs, Screener Organisations and Regulated Agents.

Responsible Person

All entities are now required to appoint a Dangerous Goods Responsible Person who will ensure compliance with the regulations, conduct risk assessments, quality control, reporting of accidents and incidents to the SACAA and maintaining the records. The appointed person must have a minimum of DG Cat 6, Risk Management and/or Safety Management qualification and must understand the regulatory and operational requirements.

Operational Requirements

In addition to the appointment of the responsible person, all entities including freight forwarders and courier companies must comply with the following:

      • Draft a Dangerous Goods operations manual and training programme to be approved by the SACAA.
      • Report accidents and incidents to the SACAA.
      • Conduct quality control.
      • Create security plans for High Consequence Dangerous Goods.

IATA Dangerous Goods Regulations (DGR)

Another notable amendment is the regulation that allows the usage of the current version of the IATA DGR as an operational document in place of the ICAO Technical Instructions (TI), this has long been an industry practice but was not in the regulations.

Instructor Certification

All Dangerous Goods instructors will now be certified by the CAA, the certification will be valid for 24 months. The requirements are like those of Part 109. A competent instructor will be certified if they meet the following requirements:

      • Train the trainer qualification
      • Assessor qualification
      • Dangerous Cat 6 certificate
      • A CV indicating experience in Dangerous Goods operations/training
      • Proof of affiliation with an approved ATO

The candidate instructors will undergo a theoretical and practical exam before being approved.

The date of promulgation of the new regulation is not known, I advise the industry to start implementing these new requirements as early as they can.

CBTA (Competency Based Training and Assessment) and changes to the DG regulations

 

Competency Based Training and Assessment is with us for all Dangerous Goods by Air training effective 1st January 2022 with the introduction of the 63rd Edition of the IATA Dangerous Goods Regulations. 

This presentation from the SACAA provides details: 

Dangerous Goods Training and CBTA 

This change in approach is excellent news for industry as it allows us to train our people in what they need to know about Dangerous Goods to do their job properly and keep us all safe in the air. It also avoids training people on things that they will never ever use. 

A lot of preparation and education, preparing new training programs for submission to the SACAA for approval and getting us all used to a new way of working, the good news is that the highly experienced team from Professional is here to assist, every step of the way! 

 

In other news …

Dangerous Goods CAT 6 and Infectious Substance training

Professional is the preferred provider of Dangerous Goods CAT 6 and Infectious Substances training to a number of air carriers, ground handlers, freight forwarders and other role players in the air cargo industry.  

As an IATA Accredited Training School our IATA recognised qualifications are accepted worldwide. 

Our new home in Centurion

Professional had operated for many years from our Head Office at Lanseria International Airport and from offices in Wingfield Park in Boksburg. 

 

We have now consolidated and combined these operations at a new Head Office complex in Centurion to be able to better serve our clients. 

Visit our new Training Centre

We have created a new Training Centre in the Isando Business Park. This training centre will continue to serve our many clients on the East Rand. This centre opened on the 1st October 2021, please feel free to stop by for a visit should you be in the area. 

Professional at the SAAFF Congress 

Professional was represented at the recent SAAFF Virtual Congress, it was a great pleasure to meet old friends and make new ones at this excellent event. SAAFF did a sterling job in presenting a very high-quality virtual event, definitely the way of the future. 

Customized training delivery

 

COVID has changed the way we do business and interact with our business partners and clients. Professional has adapted our training delivery options to provide complete flexibility to our clients in order for them to remain compliant and keep their operations safe and secure. 

We have the following options available: 

eLearning

Learners’ complete courses in their own time and at their own pace on our easy to use eLearning platform. This is particularly useful for people that need qualifications but who do not have the time to attend classroom training and who have access to a computer and an internet connection. 

 

Virtual Training

The ultimate hybrid learning experience with courses being presented via our custom Teams Virtual Classroom, this provides the very best mix of remote learning with interaction with an experienced Instructor and with other attendees. Ideal for people who want a classroom experience without possible exposure to COVID. 

 On demand client specific courses can be provided tailored to your specific needs. 

Classroom training 

Traditional, in person classroom training is available for all our courses. These can be offered at your premises (subject to SACAA approval) or at our Training Centre in Hulley Road Isando. This is the ideal option for warehouse personnel, drivers, security people as it allows for direct face-to-face interaction with our very experienced Instructors. 

e-Learning from Professional

We have enhanced and increased our eLearning offerings and we currently have the following courses available on our custom-built eLearning platform:

SACAA Approved Courses

      • Dangerous Goods (CAT 4,5,7,8,9,10,11 and 12)
      • General Aviation Security Awareness (ASAT)
      • Aviation Security Awareness (Cargo Mail Stores Supplies) (ASAT Cargo)
      • RPAS Aviation Security Awareness
      • Level 3 Aviation Security Manager – (Airports and Airlines)
      • Level 3 Aviation Security Manager – (Cargo)

General Courses

      • COVID-19 Awareness
      • Access Control
      • Digital Security Awareness
      • Lithium Batteries – The Safe Transport of Lithium Batteries by Air
      • Live Animal Regulations (AVI) Training
      • Temperature Control Regulations

These courses can be completed in your own time and at your own pace on our easy to use eLearning platform.

Please visit Professional eLearning to make your booking.

Virtual Training the Way Forward

Professional Aviation Services is currently an industry leading training provider in terms of delivering regulated courses for the transport of Dangerous Goods by Air as well as for Aviation Security, accredited by the South African Civil Aviation Authority. This includes RPAS Aviation Security Awareness Training for the drone industry.

With the recent introduction of our Virtual Platform we have now extended these training courses to a wider audience. 

Virtual training 

Professional Aviation Services virtual classroom courses provide real-time instructor-driven learning where participants can interact, communicate, view and discuss presentations, and engage with learning resources while working in groups, all in an online setting.

 During the course, the delegate will also engage with learning resources while working in groups or on a one-on- one online training environment. 

The benefits of Virtual Classroom Training 

  • Live interactive instructor- driven sessions 
  • Learn from the comfort of your own home or office 
  • Combination of structure and freedom 
  • Effective time management 
  • Expanded world view 
  • Synchronous discussions with classmates 
  • Immediate feedback on tests 
  • Sharpened digital skills 

NB – The courses not offered virtually are the Part 109 Passenger and Cargo Level 1 and 2 Screener and Supervisor Modules due to time spent conducting practical X Ray Image testing

Covid-19 and Training

 

by JJ Cilliers, Training Manager

At Professional Aviation Services, we take the Health & Safety of all our staff, learners and visitors very serious, and prior to opening our classroom-based training, implemented all the necessary COVID-19 protocols as per required regulations. 

  1. Completed risk analysis of our facility. 
  1. Sanitised our facility, and doing preventative sanitising every Friday. 
  1. Completed and implemented a ‘back to work plan’ 
  1. All above documentation together with a Covid-19 ready checklist was sent to the SACAA. 
  1. All our staff were issued with the necessary PPE 
  1. All staff received Covid-19 awareness training 
  1. Implemented a full screening process at our reception area, temperature of all staff, learners and visitors are checked and recorded upon entering and leaving our facility. 
  1. We follow a strict rule, ‘no mask no entry “ 
  1. Our classrooms are sanitised before and again after every class. 
  1. Each class has hand sanitisers available, and learners must sanitise when entering and leaving the classrooms. 
  1. During classes, strict social distancing is observed by our instructors and learners, we only allow 1 learner per desk, this ensures a distance of 2 meters between learners. 
  1.  Our breakaway area is sanitised before and after use. 
  1. No meals are served during the pandemic, and learners are required to bring their own stationary i.e. pens and writing pad, these items are not supplied, and no sharing allowed. Professional will provide the necessary course books.   
  1. All equipment used during any training intervention, is sanitised before and after use. 

In short, Professional Aviation Services, is ready to welcome all our learners back to our facility, but NEVER letting our guard down, or relaxing when it comes to the health & safety of our staff, learners and visitors. 

BE SAFE!!! 

Potential changes to the SACAA Aviation Security Regulations.

by Elliot Molemi, Compliance

There is a proposal by the SACAA to amend certain regulations to align them with the 17th amendment of ICAO’s Annex 17. 

The first amendment applicable to Aviation Security in general is the changing of the definition of Background Checks in Part 1 of the Civil Aviation Regulations.

The change will still achieve the result of only having suitable candidates employed in the functions of applying security controls or having unescorted access to security restricted areas.  

The main changes are in Part 108.02.1(1) which details the duties of a Regulated Agent.

The changes are a mixture of substitution of words in existing paragraphs and insertion of new paragraphs into the regulations. The changes are likely to: 

  • Replace “security controls” with “appropriate security controls” in paragraph (d). 
  • Insertion of “once security cleared/screened” in paragraph (k) 
  • Requiring that the Regulated Agent perform oversight/verification to subcontractors who are applying security measures on their behalf, and that they are in line with their Security Manual. 
  • Require that Regulated Agents perform random and unpredictable securing controls on cargo tendered as secure cargo from other Regulated Agents and Known Consignors. 
  • Require that Regulated Agents screen staff and visitors for explosives and explosive devices. 

Other amendments to the Part 108 regulations will require: 

  • That the Known Cargo area be security controlled at all times. 
  • That the air carrier must safeguard known cargo in their care until departure of the aircraft. 
  • That all Transfer & Transit Cargo that is received as unknown cargo be screened to the same standards as any originating cargo. 

Practical implications 

The practical implications of most of these changes are negligible as they are already in practice at most agents. I will only discuss three of these changes as they require a little more application than others. 

Verification of Security Companies and Screener Organisations

The Designated Official (DO) of a Regulated Agents must periodically verify that the contracted security company or screener organisation (ASSO) is performing their functions in line with the regulations and the approved security manual. This can be done by inspecting the procedures, documentation, and practical application by individuals. The DO will decide on the frequency of these checks. 

Random and Unpredictable Security Controls

Performing random and unpredictable security controls on cargo received as Known Cargo could be done by either one or a combination of the following methods: 

  • Screening of Known Cargo. 
  • Opening of cargo to verify their contents, where practical and permissible. 
  • Making random calls to non-account clients to verify their knowledge of the cargo, address, contacts, and existence of the company. 

Records of the random and unpredictable security controls will have to be kept and available to be inspected by the CAA. 

Screening for explosives for staff and visitors

The screening of staff, visitors and their belongings for explosives and explosive devices when entering the facility of a Regulated Agent is perhaps the trickiest. The reasoning for it is sound but the application might be costly. This regulation will require the use of an Explosive Trace Detectors on individuals and their belongings or Explosive Detection Dogs of the belongings or any other approved screening method that can detect explosives. The good thing about this regulation is that It gives room for this to be applied on a random basis.  

The next steps

These changes are still in process, Regulated Agents will have to amend their Security Manuals to detail how they are going to implement the changes.

As always, the SACAA will assist the industry in applying the changes by means of workshops and the provision of Technical Guidance Material where necessary. 

New Security courses available

    Professional Aviation Services is a PSIRA registered training school, certified to present grades E to A.   PSIRA number: 2016373, T1864 

1. GRADE E (PATROL OFFICER) 

Aim Of Course 

The purpose of this training is to ensure that new training Officers are introduced professionally in the Private Security Industry and know what is expected from them with regard to upholding the Law as Security Officers. 

2. GRADE D (ACCESS CONTROL) 

Aim Of Course 

The purpose of this module is to train Security Officer`s how to conduct Access Control at the egress point, also to ensure that they know and understand how the 3 ‘’D’’ principles of physical Security works in conjunction with Security Officer`s 

3. GRADE C (PROTECTION OF INFORMATION OFFICER) 

Aim Of Course 

The purpose of this module is to ensure that Security Officers with grade C are able to protect Classified information to civilians, also know how to conduct Emergency situation in their presence and to save lives in their designated areas and also be able can assess risk and deal with it professional. 

4. GRADE B (SUPERVISION) 

Aim Of Course 

This learning unit improves officers to an advance level of Supervision. Officers are equipped with the knowledge of Supervision also how to conduct On Job Training, Handling of Parade and the Hosting and lowering of Flags. 

5. GRADE A (MANAGEMENT) 

Aim Of Course 

This learning programme help the Security Officers on how to manage the site ,also how to gather evidence during accidents and incidents on site under his /her management, it is also encourages the importance of inter action on site and the benefit of it when is implemented professionally. 

eLearning Progress

COVID-19 has changed the world as we know it. Not only has it changed the way we do things in our personal lives but more importantly the way we do business. COVID-19 has impacted us all, we can no longer do everyday tasks the way we have become accustomed to – even now there are still some restrictions prohibiting certain everyday activities that we once took for granted. It is in situations such as the ones we currently face, that as a company we had to adapt to a new way of doing business while still providing the level of professionalism our clients have become accustomed to.  

With the approval of the SACAA, Professional Aviation Services has been diligently working on their eLearning platform to make more courses available in an eLearning format.

Several courses are already live and available, and we encourage you to explore our digital platform. The team at Professional Aviation Services is working tirelessly to make even more of our courses digital for both your safety and convenience.  

The team has developed and published the following courses; 

  • Dangerous Goods CAT 4  
  • Dangerous Goods Category 10, Category 5 and Category 8 will be available online shortly.  

The other courses that we will be introducing online are Level 3 Aviation Security Management (Airport and Carrier) and (Cargo) and Aviation Security Awareness Training for Cargo. 

We are aware of the demand for courses such as the RPAS (Remotely Piloted Air Systems) for the drone industry, this course is scheduled for development in the upcoming weeks. The team is hard at work to bring the convenience of eLearning directly to you to be accessed in the comfort of wherever you may find your new office to be during these trying times.  

For more information please contact us at info@professional.aero