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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.

COVID-19 Products and Services To Support Companies

Professional Aviation Services offers a variety of products & services to support businesses during the COVID-19 Pandemic as the economy prepares to reopen.

Professional Aviation Services is offering a range of products and services during the COVID-19 Pandemic to assist your business.

OUR COVID-19 PRODUCTS AND SERVICES INCLUDE:

SERVICES

  • Risk Assessments
  • COVID-19 Compliance Audits
  • Drafting of OHS Policies
  • Drafting of COVID-19 Policies
  • Training Staff for COVID-19 Compliance

TRAINING

EQUIPMENT

  • Defogger Machine
  • Various Handheld Thermometers
  • HS Thermo Detet
  • Red Rhino Knapack Sprayer
  • Smartphone Screening Solution
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For more information contact daryl@professional.aero

Movement of Air Cargo

Some confusion exists in the market; what air cargo can be consigned and what cannot be consigned.

Loading platform of air freight to the aircraft

We have received the following clarification from the South African Civil Aviation Authority:

Dear Agents and Consignors,

It has come to our attention that there remains some confusion as to which cargo is permitted to operate. Please kindly be advised that the attached Directions permit the movement of air cargo. This is to clarify that air cargo in its entirety is permitted to fly both into and out of the country using the listed International Airports. 

With kind regards,

Andrew Dhlakama
Manager: Air Cargo Security
AvSec: Dangerous Goods and Cargo Security

Please refer to the Aviation Directives attached for further clarity,

Please feel free to approach the Team at Professional should you need any assistance

Thank you

IATA Dangerous Goods Workshops South Africa 2018

The agenda and speakers for the IATA Dangerous Goods Workshops on 31 January in Johannesburg and 1 February in Cape Town is set out below:

Dangerous Goods Workshops_2018_Agenda South Africa

Please make sure that you book early at (IATA Dangerous Goods Workshop Bookings) and make sure that you don’t miss out on the opportunity of meeting with the Dangerous Goods Experts from IATA

And remember the participation fee is USD125 and all will receive a free electronic (windows or mobile) copy of the DGR 59th 2018 edition valued at USD328.

Dangerous Goods Workshops_2018_Agenda South Africa

DG Workshop Invite_SAF

IATA Workshops South Africa 2018: Meet the IATA Expert Team

dgr

The IATA Dangerous Goods Workshops (31 January in Johannesburg and 1 February in Cape Town) offer the perfect opportunity to engage with experts from IATA on critical issues impacting on how we deal with Dangerous Goods by Air.

This is your chance to meet with Dave Brennan and James Wyatt of IATA and get clarity on any Dangerous Goods question you may have direct from the IATA experts!

Dave Brennan

David Brennan

Assistant Director Cargo Safety & Standards

International Air Transport Association

David has been with IATA since 2002 and is currently Assistant Director Cargo Safety & Standards.

David is responsible for coordinating the activities of the Cargo team who are jointly responsible for the IATA standards publications and products that address dangerous goods transported by air.  David is the Secretary of the IATA Dangerous Goods Board and the Panel member nominated by IATA to the International Civil Aviation Organization (ICAO) Dangerous Goods Panel. David also participates, on behalf of IATA, in the meetings of the United Nations Subcommittee of Experts on the Transport of Dangerous Goods.

Prior to joining IATA David worked for Ansett Australia for a period of 26 years holding a number of supervisory and management positions within the Operations Division, the last being Corporate Advisor Dangerous Goods Compliance. 

James Wyatt

James WYATT

Assistant Director, Dangerous Goods Publications

James joined IATA in 2016 as Assistant Director, Dangerous Goods Publications. James, a British national, has 17 years of cargo industry experience and prior to joining IATA he worked for Lufthansa Cargo, AeroLogic, Qatar Airways and DHL Express.

James has been involved with Dangerous goods throughout his career and prior to joining IATA he managed the Global Restricted Commodities program for DHL Express, including all of the airlines under the DHL umbrella. James represented DHL Express at the ICAO Dangerous Goods panel, through the Global Express Association and the IATA Dangerous Goods board.

Industry will have the opportunity of engaging with David and James on the changes contained in the 59th Edition of the IATA Dangerous Goods Regulations

The strategic change to Dangerous Goods training, is a matter of critical importance to every person and organisation that deals with Dangerous Goods. This is your chances of learning all about the changes, how these will impact your operations and how to prepare for the changes.

This will change how we think about Dangerous Goods education and training.

Summary of proposed Dangerous Goods training changes

Key highlights

  • An overview of the current regulatory framework and what changes will come in 2018 and beyond.
  • How these regulations align to the ICAO Technical Instructions, and
  • Regulatory compliance of the different entities in the supply chain giving you the opportunity to learn exactly what steps you need to take to keep the supply chain safe.

Participants will receive a free electronic (windows or mobile) copy of the DGR 59th 2018 edition.

Registration & more information
Please click here to register for the Workshop.

For more information

DG Workshop details

Interactive IATA Dangerous goods Workshops

DGR-59 Shipper Combo

Invitation to IATA Dangerous Goods Workshop
The International Air Transport is holding two interactive 1 day workshops which will include guest speakers from across the supply chain, learn about the essentials of shipping dangerous goods and lithium batteries by air.

Target Audience
The Workshop targets all stakeholders of the air cargo supply chain. It is of particular importance to shippers, freight forwarders and airlines in the industry.

Dates and Locations
Johannesburg, South Africa – 31 January 2018 Cape Town, South Africa – 1 February 2018

Key highlights
• An overview of the current regulatory framework and what changes will come in 2018 and beyond.
• How these regulations align to the ICAO Technical Instructions, and
• Regulatory compliance of the different entities in the supply chain giving you the opportunity to learn exactly what steps you need to take to keep the supply chain safe.

Participants will receive a free electronic (windows or mobile) copy of the DGR 59th 2018 edition.

Registration & more information
Please click here to register for the Workshop.

For more information, you can write to us at: igom-africa@iata.org

DG Workshop Invite_SAF

Screeners and the Screening Organisation

Screening and the Screening Organisation under Part 110 of the Civil Aviation Regulations 2011

This presentation contains everything you need to know about preparing yourself for the Part 110 requirements to ensure that all screening at your organisation is undertaken by a registered Screening Organisation.

Screeners and Screener Organisation (Complete) May 2017 V3

If you need any assistance feel free to contact us for assistance

The challenge of background checks

One of the more controversial aspects of our task as aviation/cargo security professionals is the question of background checks, commonly (and incorrectly) interpreted as being a criminal record check.

So what is a background check?

A background check as defined in the Civil Aviation Regulations of 2011 means:

“background check” means the checking of a person’s identity and previous experience, including any criminal history as part of the assessment of an individual’s suitability to implement a security control and/or for unescorted access to a security restricted area;

You will note from the above definition that the criminal record check is a very small part of the background check but we have elevated it in importance to being just about the only thing that we check when carrying out the background check required by Regulation.

And even when we do find a person with a criminal record the decision on the person’s suitability for employment in a security sensitive position is not straight forward or clear cut, there is no reason whatsoever that a person with a criminal record could not be a very valuable team member who would present no threat to aviation security.

Not so other aspects covered by a proper background check; things like:

  • employment record,
  • possible radical affiliations, pending investigations,
  • criminal affiliations,
  • serious financial difficulties,

all these aspects that could present a much bigger threat and which become clear on a thorough background check.

We make extensive use of pre-employment forensic interviews and polygraph tests combined with very thorough vetting of employment records before we employ people in security sensitive positions, perhaps not perfect but a process that has proven effective.


This is an international problem, this article is from the Sydney Morning Herald:

Alleged terrorist associates sacked from TNT air freight depot

The five men who were allegedly intending to head to Indonesia in a small boat. From left Musa Cerantonio, Paul Dacre, Shayden Thorne, Antonio Granata and Kadir Kaya.
The five men who were allegedly intending to head to Indonesia in a small boat. From left Musa Cerantonio, Paul Dacre, Shayden Thorne, Antonio Granata and Kadir Kaya.

What happened at TNT in Melbourne?

The personnel were subjected to a standard criminal record check which did not cause any alarm because the people concerned had never been convicted of a crime!

How could this have been prevented? 

A forensic interview and polygraph pre-employment would have helped.

We need to go beyond the standard “crim check” into the realm of proper, professional background checks especially for persons in security sensitive positions like screeners and persons applying security controls in respect of cargo and persons including all access control personnel.

Remember that the one of the most difficult to detect and combat threats to aviation security (and the general security of your company and its operations) is the “insider threat”, it is critical that you implement proper background check procedures to protect yourself and your company.

Upcoming changes

Changes to Part 110 of the Civil Aviation regulations currently awaiting signature by the Minister of Transport call for much more stringent recruiting policies and processes including much more intensive background checks for screeners.

This is a very positive development that we should all support.

How can we help?

Please feel free to call us should you require advice on the background check process.

Revised Regulations with regards to Aviation Security – what you need to know

UPDATE

The 14th Amendment to the Civil Aviation Regulations was published on the 28th October to be effective 30 days from date of publication, download the amendment here:

14th-amendment-to-the-civil-aviation-regulations-november-2016

The revisions to the Part 108, Part 109 and Part 110 Regulations and Technical Standards that have been in the works since 2012 passed the final benchmark on the 12th June 2015.

The Regulations will now go to the Minister for signature before becoming law and the Technical Standards will go to the Director of Civil Aviation for signature.


Here are some of the things that you need to know:

1. High Risk Cargo and the security measures relating to High Risk Cargo are clearly set out;

2. All Regulated Agents and Known Consignors to apply cyber security measures

3. Procedures for Transfer and Transit cargo set out;

4. Changes to Exempted Cargo, in particular that human remains are no longer exempt;

5. Regulated Agents no longer have to screen 10% of cargo from Known Consignors;

6. Known Consignors no longer function on the basis of a relationship with a Regulated Agent only, each Known Consignor now requires a Security Manual and is free to deal with any Regulated Agent;

7. Training for the personnel of Regulated Agents and Screeners is no longer under Part 108 all security training is now under Part 109;

8. Air Cargo Security Familiarisation Training as we knew it under Part 108 has been replaced by Aviation Security Awareness Training under Part 109 and the scope of people requiring training has been dramatically increased;

9. Screeners now require 10 days training plus 1 day X-Ray machine familiarisation training plus 10 days On The Job Training per screening method that they will use;

10. Screener Supervisors must be qualified Screeners before undergoing an additional 5 days of Supervisor training;

11. Security Managers, Designated Officials and Deputy Designated Officials require 5 days training.


These are some highlights, we are available if you need further details on any of the above and on the possible implications for your business.

The changes to Part 108 and security measures have long since been introduced into most security programs these should not cause any problems at all and should be welcomed as they are very good for cargo security.

Probably the most contentious issue from these Regulations will no doubt be the length of training for Screeners and Supervisors of Screeners. In the cargo world training required goes up dramatically.

We fully support these changes, remember that Screeners ensure your safety and the safety of all who fly, do you really want a poorly trained individual who has been given the minimum possible training screening the cargo under your seat?

We need to have world class training and certification, period. No debate, no if or buts, no excuses or debates about time and expense, this is a security issue not an economic debate.

Even the much vaunted TSA has challenges, they recently failed 97% of routine security tests.

We can do better.