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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.

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 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.

A version of this article was previously published in the South African Express Parcels Association newsletter.

Schedule for Dangerous Goods & Aviation Security Training (June/ July 2020 – Week 27)

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 TRAINING SCHEDULE

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.
09H00Boksburg

DANGEROUS GOODS TRAINING SCHEDULE

All Dangerous Goods Regulations Courses presented by Professional Aviation Services are accredited by the SACAA

30th
JUNE2020
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 4 as 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.

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

Airport services from Professional

Professional Aviation Services are specialists in all aspects of Aviation Security, Airport Compliance and Training. With a 40-year history in Aviation and specialising in providing unique solutions that solve your challenges, Professional Aviation Services is ideally placed to service and assist you in finding solutions for your various needs.

We are passionate about keeping Aviation safe and secure, for, ultimately, it is all about protecting people. From the personnel who are involved in the Aviation Industry, the people who fly as crew and passengers to the public who could be affected by an aviation incident.

We are the leading provider of AVSEC and related compliance solutions. Our services include air cargo compliance and screening services (cargo and airport) to the air freight and air carrier industry in South Africa.

We have a depth of expertise and experience in cargo security, and compliance with Part 108 of the Civil Aviation Regulations that is unmatched, Professional are pioneers of contracted compliance and Designated Official services in South Africa.

Professional Aviation Services are the Winners in the Aviation Training category of the inaugural Civil Aviation Industry Awards presented by the South African Civil Aviation Authority in 2018. Professional provide a comprehensive range of aviation security, dangerous goods and general aviation and security training.

Professional offers a suite of eManagement services including Airport Operations, Training Management and eLearning solutions that are available to our clients.