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.
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,
- 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.
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.
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.
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.
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.