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.
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:
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!
Changes are coming to DG Regulations ! Are you ready for these?
“October 2021- South Africa’s transport month – and
there is much to celebrate.
Investment of billions of rands is pouring into our
industry, improving service delivery and creating jobs.
Members are rising to the challenge of matching the
best in the world. Express logistics is experiencing
rapid expansion and wider reach to accommodate
mushrooming volumes of urgent, important deliveries.” Garry Marshall
They put lives, equipment, and property at unnecessary risk. There has recently been a spate of incidents caused by undeclared, misdeclared or hidden Dangerous Goods which have caused a great deal of concern. These are clear and present risks.
Undeclared, misdeclared or hidden Dangerous Goods are difficult to detect once in the system.
Fortunately, in South Africa, we have a strong Civil Aviation Authority (SACAA) determined to work with the industry to combat this scourge. The SACAA is uncompromising about compliance and firm about recording any breaches, yet at the same time it offers encouragement and provides guidance to industry. It works on a partnership basis, not master and servant and has a highly positive impact on the security of our business.
Misdeclarations may occur accidentally because of ignorance or confusion regarding the regulations. This clearly indicates the need for education and training, more intensively or more frequently.
Less commonly, there may be an irresponsible attempt to circumvent Dangerous Goods regulations, procedures, and costs. Such unethical activity puts lives and property at risk and has no place in a responsible operation or in the air cargo industry.
Every one of our people must be alert, aware of the rules and authorised to call out any behaviour inconsistent with security and safety standards.
What about hidden Dangerous Goods? Paints, aerosols containing various products, glues, and adhesives, bleaching powders, cleaners – many common household items contain Dangerous Goods. The public may be unaware of this when handing them over for transport and it is the responsibility of our people to recognise and neutralise such unintended exposure at every stage of the express supply chain.
For the last several years the SACAA, and industry have been laying great stress on the need to put watertight measures in place to deal with hidden, misdeclared and undeclared Dangerous Goods. All of us must take seriously this danger presented by Dangerous Goods by remaining alert to the risks and up to date in our knowledge and procedures for mitigating them.
The recent incident of fire at HKIA initiated many discussions among air cargo industry safety professionals. Developing a work culture where individuals feel free to report incidents without the fear of punishments, avoiding blame and taking responsibility was at its core.
The following article provides insights from industry on this critical subject
Our #NationalTrainingSchedule for #AviationSecurity & #DangerousGoods #training for the 1st week of August is now available, book today to secure your seat. #caa #savelives #dgr #avsec #asat #cargo
Our National Training Schedule for our Screener & ASAT training for the 03rd to the 07th of July 2020. is below.
AVIATION SECURITY TRAINING SCHEDULE
3rd – 7th
AUGUST2020
Screener Cargo (Refresher)A SACAA accredited course that meets the security training requirements under Part 109 for persons implementing screening of cargo, mail, air carrier mail and materials, in-flight supplies and airport supplies.
09H00DBN
3rd – 7th
AUGUST2020
Screener Cargo (Refresher)A SACAA accredited course that meets the security training requirements under Part 109 for persons implementing screening of cargo, mail, air carrier mail and materials, in-flight supplies and airport supplies.
09H00CPT
3rd – 7th
AUGUST2020
Supervisor – Passenger (Refresher)A SACAA accredited course that meets the security training requirements under Part 109 for persons supervising Passenger and Baggage Screeners.
09H00JHB
5th
AUGUST2020
ASAT CargoA SACAA accredited course that meets the security training requirements under Part 109 for Aviation Security Awareness Training for Persons Implementing Security Controls other than Screening
09H00JHB
7th
AUGUST2020
ASAT RPASA SACAA accredited course that meets the security training requirements under Part 101 – Remotely Piloted Aircraft Systems of the Civil Aviation Regulations.
09H00JHB
DANGEROUS GOODS JHB TRAININGSCHEDULE
All Dangerous Goods Regulations Courses presented by Professional Aviation Services AS PER THE NATIONAL TRAINING SCHEDULE BELOW IS accredited by the SACAA.
3rd – 5th
AUGUST2020
DANGEROUS GOODS CAT 6 (REFRESHER)A SACAA accredited course that meet the training requirements for personnel listed in category 6 as per Table 1.5.A of the IATA DGR.
09H00JHB
3rd – 5th
AUGUST2020
DANGEROUS GOODS CAT 6 (REFRESHER)A SACAA accredited course that meet the training requirements for personnel listed in category 6 as per Table 1.5.A of the IATA DGR.
09H00PLZ
CONTACT US FOR BOOKINGS
Please use the below contact form to arrange for bookings, alternatively please use the details below the this form.
OR contact us on +27 11 397 1222 for any queries regarding your aviation security and dangerous goods training.
Below is our Screener & ASAT JHB training schedule for the 20th to the 24th of July 2020.
AVIATION SECURITY TRAINING SCHEDULE
20th – 24th
JULY2020
Screener Cargo (Refresher)A SACAA accredited course that meets the security training requirements under Part 109 for persons implementing screening of cargo, mail, air carrier mail and materials, in-flight supplies and airport supplies.
09H00BOKSBURG
22nd
JULY2020
ASAT CARGOAn SACAA accredited course that meets the security training requirements under Part 109 for Aviation Security Awareness Training for Persons Implementing Security Controls other than Screening.
DANGEROUS GOODS CAT 6 (REFRESHER)A SACAA accredited course that meet the training requirements for personnel listed in category 6 as per Table 1.5.A of the IATA DGR.
09H00BOKSBURG
20th – 21st
JULY2020
DANGEROUS GOODS CAT 5 (VIRTUAL CLASS)A SACAA accredited course that meet the training requirements for personnel listed in category 5 as per Table 1.5.A of the IATA DGR.
09H00BOKSBURG
23rd
JULY2020
DANGEROUS GOODS CAT 4A SACAA accredited course that meets the training requirements for personnel listed in category 4 as per Table 1.5.A of the IATA DGR Manual.
09H00BOKSBURG
23rd – 24th
JULY2020
DANGEROUS GOODS CAT 5 (virtual training)A SACAA accredited course that meet the training requirements for personnel listed in category 5 as per Table 1.5.A of the IATA DGR.
09H00BOKSBURG
24th
JULY2020
DANGEROUS GOODS CAT 10An SACAA accredited course that meets the training requirements for personnel listed in category 10 as per Table 1.5.A of the IATA DGR Manual.
09H00BOKSBURG
CONTACT US FOR BOOKINGS
Please use the below contact form to arrange for bookings, alternatively please use the details below the this form.
OR contact us on +27 11 397 1222 for any queries regarding your aviation security and dangerous goods training.
All the Dangerous Goods Regulations and Aviation Security Awareness Courses presented by Professional Aviation Services are accredited by the SACAA. Seats fill up fast, contact us today for bookings or click the below link for more information. #savelives #dgr #classroomtraining
Below is our training schedule for the first week of July 2020.
AVIATION SECURITY TRAININGSCHEDULE
01st
JULY2020
ASAT – CargoAn SACAA accredited course that meets the security training requirements under Part 109 for Aviation Security Awareness Training for Persons Implementing Security Controls other than Screening.
Dangerous Goods Category 8 – INITIALAn SACAA accredited course that meets the training requirements for personnel listed in category 8 as per Table 1.5.A of the IATA DGR Manual.
09h00Boksburg
01st
JULY2020
Dangerous Goods Category 8 –INITIALAn SACAA accredited course that meets the training requirements for personnel listed in category 8 as per Table 1.5.A of the IATA DGR Manual.
09h00Boksburg
01st – 2nd
JULY2020
Dangerous Goods Category 10 – VIRTUALAn SACAA accredited course that meets the training requirements for personnel listed in category 10 as per Table 1.5.A of the IATA DGR Manual.
TBCOnline
02nd
JULY2020
Dangerous Goods Category 4 – INITIALAn SACAA accredited course that meets the training requirements for personnel listed in category 4as per Table 1.5.A of the IATA DGR Manual.
09H00Boksburg
02nd
JULY2020
Dangerous Goods Category 8 – INITIALAn SACAA accredited course that meets the training requirements for personnel listed in category 8 as per Table 1.5.A of the IATA DGR Manual.
09H00Boksburg
03rd
JULY2020
Dangerous Goods Category 12 – INITIALAn SACAA accredited course that meets the training requirements for personnel listed in category 12 as per Table 1.5.A of the IATA DGR Manual.
09H00Boksburg
03rd
JULY2020
Dangerous Goods Category 8 – INITIALAn SACAA accredited course that meets the training requirements for personnel listed in category 8 as per Table 1.5.A of the IATA DGR Manual.
09H00Boksburg
CONTACT US FOR BOOKINGS
Please use the below contact form to arrange for bookings, alternatively please use the details below the this form.
OR contact us on +27 11 397 1222 for any queries regarding your aviation security and dangerous goods training.
Our E-Learning courses are mobile ready and includes but are not limited to Dangerous Goods Awareness, General Aviation Security and related topics. #DGR #aviation #lithiumbatteries
E-LEARNING BY PROFESSIONAL AVIATION SERVICES
The E-Learning interventions offered by Professional Aviation Services provides learners with industry leading on-demand training and development experiences that relate to real-word environments. We have tailored our e-learning solutions to suit the needs and requirements of our industry. Our E-learning courses are relevant, up to date and mobile ready.
Professional Aviation Services offers the following digital learning experiences:
DANGEROUS GOODS
The aim of the Dangerous Goods introductory training course is to provide appropriate training to all personnel aware of dangerous goods and the hazards they pose to aviation. This is an introductory course which is not accredited.
AVIATION SECURITY
Learners that have completed this SACAA Certified course will have a firm understanding of how to implement international best practices that relate the general safety and security of all visitors to an airport.
SAFE TRANSPORT OF LITHIUM BATTERIES
This course is designed to inform and educate people about the risks posed by the transport of lithium batteries on aircraft, and will equip staff with knowledge on how best to handle incidents.
The Workshops were supported by the SACAA with logistics support provided by Professional Aviation Services.
The focus of the Workshops was on new developments in the 61st Edition of the Dangerous Goods Regulations.
Details of the changes contained in the 61st edition of the IATA Dangerous Goods Regulations, checklist and other valuable information can be downloaded from IATA at:
Please feel free to contact the Professional Team should you need any help.
The introduction of Competency Based Training for Dangerous Goods
David Brennan, Switzerland-based Secretary of the IATA Dangerous Goods Board, panel member of the International Civil Aviation Organization (ICAO) and participant in the United Nations sub-Committee of experts on the transport of Dangerous Goods presented a summary of the background to the introduction of Competency Based Training.
The introduction of CBT will impact every single person, organisation and company engaged in the Dangerous Goods by Air industry. The changes are far reaching and will have a profound impact on your operations and the way you conduct, plan and develop your training programmes.
The new training regime will mean the re-examination of things that we have taken for granted, our old friend, Table1.5.a is to be removed. This Table has provided guidance on who need what training and has allowed the SACAA to exercise quality control on training provided to industry and on the Training Providers, this has ensured that industry has had the reassurance that training standards are being maintained, critical in the safety critical matter of Dangerous Goods training.
The theory around Competency Based Training is solid but many critical aspects such as course content, assessment and quality control remain to be adequately addressed in our opinion.
This from IATA:
The objective of competency-based training and assessment (CBTA) is to use the necessary tools to clearly establish the training needs for a specific job function and then ensure that employees acquire the level of knowledge and demonstrate the right skills to perform that function.
A great deal of engagement needs to take place before these changes are implemented with several CAA organisations around the world firmly opposing the changes.
The SACAA has not indicated what their stance on this matter will be, any changes would, in any event, be incorporated in our Regulations before they would become effective.
A comprehensive document, Appendix H to the 61st Edition of the Dangerous Goods regulations is available at:
We encourage you to study this document and very carefully asses the potential impact, good and bad, to your operations.
Industry and the SACAA
The Manager of Dangerous Goods at the SACAA Mr Bheki Ngiba made it clear in his address at the Workshop that the SACAA was committed to working with industry to solve Dangerous goods challenges and that they are available to advise, assist and facilitate when challenges arise.
Bheki was adamant that the proverbial “big Stick” was only taken out as a very last resort when all other options have been exhausted.
We encourage you to take the SACAA up on this offer, let’s work together to achieve safer skies for all.
African colleagues at the IATA Workshop
Mr Bheki Ngiba introduced our colleagues for the Civil Aviation Authority of Zimbabwe and the Civil Aviation Authority of the Democratic Republic of the Congo to the attendees. This is the first time that we have had the privilege of welcoming international guests to the IATA Workshops and we hope that this will continue in the future.
The Managing Director and CEO of Professional Mr Rob Garbett stimulated thought in his opening remarks to the IATA Workshop when he referred to “Dangerous People not Dangerous Goods” as being the challenge in our industry. This is true, an item is an item, it only becomes “Dangerous” when not packed and documented correctly, or when concealed in a shipment and not declared or when handled, packed and processed by a person who does not have adequate training, experience or access to resources.
Are your people “Dangerous”?
Managing safety risks posed by the carriage of lithium batteries by air
The 27th meeting of the DANGEROUS GOODS PANEL (DGP) of ICAO was held in Montreal from the 16th to 27th of September 2019.
At this meeting a discussion on the position developed by the Flight Operations Panel (FLTOPSP) on the transport of lithium batteries and the need for the operator to perform a safety risk assessment that considered the risks associated with the transport of lithium batteries took place.
The meeting agreed that operators needed to carry out appropriate safety risk management activities in order to determine whether they could ensure the safe carriage of lithium batteries and cells.
It was noted that the ICAO Technical Instructions did not contain any provisions related to an operator’s responsibility to conduct safety risk assessments.
This has very important implications for all in the supply chain as operators will rely on Ground Handling Organisations, Freight Forwarders and Shippers to be part of the safety risk assessment and will require that they have appropriate risk mitigation strategies in place.
This will be effective from November 2020. We will monitor developments.
DG Autocheck from IATA
David Brennan, Switzerland-based Secretary of the IATA Dangerous Goods Board, panel member of the International Civil Aviation Organization (ICAO) and participant in the United Nations sub-Committee of experts on the transport of Dangerous Goods presented the IATA DG AutoCheck solution designed to play a key role in the transformation of how industry deals with Dangerous Goods
At the 2019 IATA AGM, the IATA Board of Governors discussed the growing concern about the safety implications raised by the increase in the incidence of undeclared lithium battery shipments on commercial airlines.
To answer this need, IATA launched several new initiatives to address this growing safety risk, including a system for incident information sharing, a regulatory campaign to promote supply chain compliance and the use of the IATA Dangerous Goods (DG) AutoCheck solution.
The acceptance of dangerous goods shipments affects the timeliness of your operational processes. It also improves efficiency and also reduces human errors.
You can ensure you are applying all the provisions of the IATA Dangerous Goods Regulations for acceptance of dangerous goods by air and automatically check all state and operator variations. DG AutoCheck acceptance check validation tool applies all the provisions contained in the latest edition of the IATA Dangerous Goods Regulations (DGR) through an automated compliance solution.
DG AutoCheck:
Automates dangerous goods acceptance checks
Validates compliance of all rules for every consignment
Flags all issues identified
Provides confidence in the accuracy of the acceptance checks
Allows for analysis of the dangerous goods consignments processed for business intelligence
David Alexander (Johannesburg) and Nicole Alexander (Cape Town) discussed the challenges facing industry in dealing with the burgeoning eCommerce sector bearing in mind that eCommerce is growing at around 16% per year and that the major growth in eCommerce is the use of mobile devices to make purchases. A major challenge lies in the fact that eCommerce operations do not label consignments, so operators have no indication if shipments contain Dangerous Goods. The fact that Dangerous Goods can be introduced into the courier and express system by the general public who have no knowledge of Dangerous Goods or the dangers they pose is of concern.
Industry will need to engage with the major eCommerce role players to design systems and procedures to deal with Dangerous goods in this section of the supply chain. This will have to be an industry wide initiative as the dangers and challenges impact us all
Last word
Undeclared, misdeclared or hidden Dangerous Goods are a catastrophe waiting to happen. They put lives, equipment and property at unnecessary risk. There has recently been a spate of incidents caused by this unholy trio which have caused a great deal of concern. These are clear and present risks.
Fortunately, in the Republic, we have a strong South African Civil Aviation Authority (SACAA) determined to work with the industry to combat this scourge. The SACAA is uncompromising about compliance and firm about recording any breaches, yet at the same time it offers encouragement and provides guidance to members. It works on a partnership basis, not master and servant and has a highly positive impact on the security of our business.
Misdeclarations may occur accidentally because of ignorance or confusion regarding the regulations. This clearly indicates the need for education and training, more intensively or more frequently.
Less commonly, there may be an irresponsible attempt to circumvent Dangerous Goods regulations, procedures and costs. Such unethical activity puts lives and property at risk and has no place in a responsible industry like ours. That’s why every one of our people must be alert, aware of the rules and authorised to call out any behaviour inconsistent with security and safety standards.
What about hidden Dangerous Goods? Paints, aerosols containing various products, glues and adhesives, bleaching powders, cleaners – many common household items contain Dangerous Goods.
The public may be unaware of this when handing them over for transport. Thus, it is the responsibility of our people to recognise and neutralise such unintended exposure at every stage of the express supply chain.
For the last several years the SACAA, SAEPA and our industry have been laying great stress on the need to put watertight measures in place to deal with The Unholy Trio of hidden, misdeclared and undeclared Dangerous Goods. All of us must take seriously this danger presented by Dangerous Goods by remaining alert to the risks and up to date in our knowledge and procedures for mitigating them.
This article appeared in the October 2019 SAEPA Newsletter
