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Operators hauling hazardous goods must soon appoint a dangerous goods safety adviser to meet new ADR obligations. With the regulation predicted to cost industry £500m over 10 years, training the advisers is proving a lucrative lifeline for trainers starved of HGV applicants. Steve Banner reports on the rash of courses being set up to beat the January 2000 deadline.
The web of rules and regulations that govern road transport is becoming more complicated, and is drawing ever tighter. It takes a specialist to understand some of the more obscure areas of legislation, which is why the ADR regulations now state that any company hauling hazardous loads must appoint a qualified dangerous goods safety adviser (DGSA) by I January 2000.
The initials ADR denote the European Agreement Concerning the International Carriage of Dangerous Goods by Road, which is in force throughout the European Union and in some non-member countries (Norway and Switzerland, for example). The EU obliges its members to apply the ADR agreement to domestic as well as international journeys, and in the past four or five years the UK has progressively harmonised domestic hazchem legislation with the ADR rules.
The requirement to employ a DGSA applies to rail and inland waterway transport as well as to road, and has been prompted by European directive 96/35/EC. In the UK, advisers will have to pass a written examination set and administered by the Scottish Qualitictions Authority (SQA); acting country-wide on behalf of the Department of the Environment. Transport, and the Regions.
Valid for five years, the pass certificates will be recognised in all the countries of the EU. Holders will have to be reassessed before the certificate lapses if they wish to continue offering advice. There are three exams. All candidates have to pass a core paper, then a second paper on whichever mode of transport they work in (road, rail or inland waterway).
The third paper addresses the class of dangerous goods they work in, This could be Class 1 (explosives), Class 2 (gases), class 3 (UN 1202, 1203, 1223, which relate to oil), or Class 7 (radioac.tives).
Examinees can cover all these classes if they wish, depending on the nature of their jobs. They don't have to take all the exams at one sitting, but they do have to pass them all within 12 months to qualify.
The first were held in October this year, and more are being held this month at centres— there are about 15 —all over Britain. They will now be conducted in January, March, May, July, September and November.
Take all three exams at a single sitting and you will pay £170 in total. Taking the subjects singly at intervals of, say, two or three months, will cost you £60 an exam.
Training providers are busy setting up DGSA courses. `MG Nexus, for example, which offers training to third parties, will be offering a five-day course at its site at Batley, West Yorkshire. Kent Metro will start training in January. Training costs industry-wide vary from £500-i600 to as much as £2,000, according to TDG Nexus consultant Alan Walker. "L500 to £600 is reasonable," he believes.
'The training needed to pass these examinations is demanding, but any young person coming into the transport industry should consider becoming a DGSA," he says. "They'll be the sighted ones in a world of blind people."
Five-day courses
Starting on 16 November, FP Training Services of Great Bookham, Surrey, is holding five-day courses in Manchester and in Kegworth, Leicestershire, as well as at its head office. The course costs £500.
"We send out the course notes well in advance, then go through the syllabus in more detail when the candidates arrive," explains director Eddie Pargeter. At the time of writing, however, he had yet to see a question paper, and says it is proving difficult to obtain the necessary reference books—they cost around £200 in total—from The Stationery Office.
However, there are sources other than The Stationery Office, including HSE Books.
'Another problem is that the exams are only going to be held six times a year, and they're held two weeks before the Certificate of Professional Competence exam," Pargeter says. That could pose difficulties if candidates are studying for both and trying to earn a liv ing at the same time.
"What's more, those exam centres are going to be busy" says Pargeter. "I would estimate that 10,000 people will need to take the exams, it could be as high as 15,000." It's an "open-book" exam, which means that candidates can take the necessary reference books into the examination room. Pargeter reckons that makes sense, because in the real world DGSAs are going to look up information rather than learn it by heart.
EP Training Services is also setting up a home learning course, which costs £175.
Pargeter believes independent training providers have plenty of capacity to provide DGSA training to those who want it, and that the syllabus covers all the knowledge an adviser is likely to require. Not everyone is keen on the DGSA legislation, however.
Light touch
"The UK didn't want it," says Steve Walker, principal inspector at the Health & Safety Executive's policy section. "We are going to implement it, but with as light a touch as we can.
"Under general UK health and safety legislation, companies already have a duty to employ competent management, and we feel that the DGSA obligation is overbureaucratic and too formal. We calculate that it will cost British industry 1300mI:500m over the next 10 years, but will bring only about C3Orn-worth of health and safety savings," The regulations as originally proposed said DGSA training had to consist of 50-minute lessons with a 50-minute break between them. "Fortunately we were able to oppose that successfully, and there seems to be plenty of training available," says Walker. "I'm confident the training industry will rise to the challenge."
Gary Thrush, administrator at Friendberry, another transport training specialist, points out that a firm's nominated DGSA doesn't have to be an employee. He can be an independent consultant, for example. "You don't have to have a guy on site," he says.
EP Training Services is considering setting up a DGSA consultancy service aimed at small to medium-sized operators, and is researching the insurance requirements. Professional indemnity cover, for example, would undoubtedly be required to insure the DGSA against the consequences of being sued for giving the wrong advice.
Thrush fears that, as with training drivers to ADR requirements, everyone will leave it until the last moment. "They've got less than 14 months to do it in, and [think there's going to be absolute pandemonium at the finish," he says. "It could turn into a fiasco."
"We've got 10 people booked on our first course, and I too suspect that we'll see a mad rush in the last few months before the deadline:' Pargeter says,
The ADR regulations now also demand training for warehousemen, forklift truck drivers and anybody else in a haulage depot—even the security man on the gate— who has anything to do with the handling of
hazardous cargo. "Steam cleaners will have to go through it, not to mention the man who sweeps the yard, and I certainly don't decry that," says TDG'S Alan Walker.
The requirement comes in on 1 January 1999, but a transitional period means it doesn't come fully into force until 1 July 1999.
"The employees affected have to be given training according to responsibilities and duties," says Steve Walker; and a tot of it is basic. "With a forklift truck driver, for example, he has to understand that he should avoid putting the tines of his fork lift through the drum he is loading, and avoid dropping the drum too," Walker observes. "In effect, it codifies the sensible practices most employees pursue anyway."
Refresher course
The training can be conducted in-house, says Thrush, and the DGSA will probably have a role to play. A driver's ADR certificate has to be updated every five years, which involves taking a refresher course and a City & Guilds exam to ensure that any legislative changes have been taken on board.
"You condo the necessary training and take the exam between 12 months and six weeks of the expiry of your current certificate," Gary Thrush says. "Leave it later than six weeks and you have to do the full training course and exam all over again."
The refresher course is three days—costing from £125 to £330—but the full course can last for seven days if you have to transport explosivff, or radioactive material. "Most ADR drivers' certificates will come up for renewal next year, and we'll be running two refresher courses a month," says Eddie Pargeter.
EP Training Services charges £152 for a refresher. The three days include the exam. "Originally it was two days including the exam, but that was really hard work, so it was stretched to three," Pargeter says. "It's hard
going getting it done in three days too, but c to 95% of the candidates pass."
"With domestic and ADR regulations heir harmonised, tanker placards changing and tl fire extinguisher regulations changing to there have been a lot of changes over the pa five years," Thrush remarks. Next year tl way shipping containers are marked will alt
Pargeter is increasingly concentrating c ADR, CPC, and forklift training. "The denialfor HGV driver training is virtually non-exi tent, and we're down to just two trucks," I says. "When they come up for replaceme: we'll have to think seriously about whether v want to continue in that line of business,"
CASE HISTORY: TRAINING THE MILITARY
• Not only do drivers have to be examined under ADR regulations, their !Aides hive to be inspected too. Vehicle Inspectorate Training Services trains technicians to carry out these inspections, and has recently been doing so on behalf of the Ministry of Defence.
Although military vehicles are exempt from certain ADR provisions under British legislation, the 1.1oD always attempts to comply with local requirements when it is operating them abroad. Germany now requires all military trucks carrying dangerous goads to be tested, and VITS has been training personnel from the Equipment Support Branch, Royal Electrical Mechanical Engineers and the RAF.
"We tailored the course specifically to the needs of the MoD, covering a combination of ADR and standard HGV testing," says VITS trainer Mike Westerman (pictured). 'We trained 111 warrant officers who are Incorporated Engineers, plus a lieutenant-colonel who is a chartered engineer:'
• Contact the VI on 0006 6/7199.
SHORT HISTORY
e Ws move to harmonise its domestic hazardous goods transportation legislation with ADR began in 1994 with altered consignor regulations. They brought in new and expanded ckaging, classification, marking and labelling obligations. These were further revised a couple of years later with the introduction of the Carriage of Dangerous Goods (Classification, Packaging & Labelling) and Use of Transportable Pressure eceptacles Regulations 1996. At about the same time the Carriage of Dangerous Goods by Road Regulations 1996 came into force, replacing Britain's 1991 packaged goods and road tanker regulations. More journeys were brought into scope, extra documents had to accompany the load, additional placards and fire-fighting equipment were riquired and new vehicle construction requirements were laid down. The subject is covered extensively and authoritatively in the 1998 issue of the Freight Transport Association's Yearbook of Road Transport Law and the af/Tolley's Haulage Handbook.
Maximum fines for breaking ADR and domestic hazardous goods
1 gulations range from up to F5,000 on conviction in a magistrate's urt to an unlimited fine on conviction in a Crown court. Copies of the European Agreement concerning the International rriage of Dangerous Goods by Road (ISBN 0-11-941518-6) cog 180. so useful is Guidance for road vehicle operators and others involved in e carriage of dangerous goods by road 715(6)161 (ISBN 0 1116 1?53 8) E12.50. HSE Books can be contacted The Stationery Office is
01781 88116
.171 813 9090 ADR: THE TRAINING PROVIDERS
• EP Training Services: 01312 450800
• Friendberry: 01981t 656310
• Kent Metro: 01634 669365
• TDG Nexus: 01924 /1201155
• Scottish Qualifications Authority: 011,118 7900 • Vehicle Inspectorate Training Services; 01106 622199