Last reviewed 24 October 2017
This article by Andrew Shylan of AJS HAZ Training will also help transport managers, who may not need the services of a Dangerous Goods Safety Adviser (DGSA) to comply with vehicle crew training for the carriage of dangerous goods.
There have been several serious incidents involving drivers and their hazardous loads this year (as two examples, see news.bbc.co.uk and www.grimsbytelegraph.co.uk). There are also a number of instances when vehicles that have been stopped during roadside checks by the enforcement agencies have revealed that the driver’s dangerous goods credentials indicate inadequate training or no training to deal with an incident or emergency during the transport operation.
The aim of this article is for transport managers employing drivers in the carriage of dangerous goods to comply with national and international legislation on the training and security requirements for their drivers and other members of the vehicle crew.
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (amended 2011) require all carriage of dangerous goods to be in accordance with the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR).
ADR Chapter 1.3 covers the training of the main and other participants mentioned in safety obligations (Chapter 1.4), this covers the carriers, consignors, loaders and fillers among others, the training of drivers and vehicle crew are covered separately in Chapter 8.2.
Carriers, consignors and consignees who require the services of a DGSA will note in Chapter 126.96.36.199 that the undertakings DGSA duties include “the proper training of the undertaking employees, including on the changes to the regulations and the maintenance of the undertakings training records”.
It is important to note that no vehicle transporting dangerous goods may carry passengers (untrained members of the crew).
Within Great Britain and Northern Ireland, the roadside enforcement is carried out by the police, DVSA or the Department for Transport (DfT) and they produce a comprehensive list of the Carriage of Dangerous Goods — Prohibition Notices issued to carriers and organisations, this list can be found at www.hse.gov.uk.
The list is somewhat revealing about the number of vehicles that are found with problems with fire extinguishers, drivers’ PPE, documents and even vehicle placarding that have failed to meet the legal requirements. There are a number of vehicles where the driver is found to have insufficient training, no training or cannot produce their training certificates. Some would say that many if not all the other areas of non-compliance would be addressed by the correct training of the vehicle crew in their areas of responsibilities.
Vehicle crew training
So what type of training is required for all crew members?
Drivers of vehicles where loads exceed the ADR and DfT Approved Derogations and Transitional Provisions 2012 (ADTP) load threshold limit or tankers will require all crew to be trained and the driver to hold an in date training certificate for the UN classes of dangerous goods being carried.
Vehicles not exceeding the threshold limits will require the crew to be trained but the driver will not have to be in possession of an ADR driver training certificate. This is more commonly called awareness/s or adequate training to the dangers being carried.
ADR training certificates can be obtained by drivers or vehicle crew from many training providers and consortiums. They must sit and pass the Scottish Qualifications Authority (SQA) Drivers ADR exam at the end of their course.
The exam is based on the modules sat by the driver and is multi-choice questioning and can be taken online at some training centres with an instant result, otherwise the driver waits four to six weeks for his new ADR training certificate.
The driver training is modular and there are over 30 initial training courses of different modules and a number of refresher and specialist courses for certain UN classes.
The courses can be tailored to the needs of the carrier and driver with additional modules taken at any time after the initial course. The certificate has to be renewed every five years for the driver to be compliant and the certificate must be carried at all times by the driver when transporting dangerous goods as proof of training.
Candidates sitting the SQA ADR training do not need to hold a UK driving licence, EU or non-EU driving licences are valid and they can take the training even if they do not hold any driving licence.
The training will normally be the core module and will then specialise for packages and bulk or tanker module and the addition UN classes are then added as required. The SQA drivers training certificate being JAUPT approved can earn a driver between 7–28 hours of CPC training depending on the course and course length.
For vehicle crew not requiring to hold an ADR training certificate, Chapter 8.2.3 of ADR states that the persons shall receive training appropriate with their responsibilities and duties according to Chapter 1.3. This training shall cover the following.
General awareness training
Each person shall be trained in order to be familiar with the general provisions of dangerous goods transport requirements.
Such training shall include a description of the classes of dangerous goods; labelling, marking, placarding and packaging, segregation and compatibility requirements: a description of the purpose and content of the dangerous goods transport document; and a description of available emergency response documents.
Personnel shall be trained commensurate directly with their duties and responsibilities as the driver or vehicle crew.
The vehicle crew shall be trained in the hazards and dangers presented by the dangerous goods during loading, unloading and handling commensurate with the degree of risk of injury or exposure during carriage.
The training shall be periodically supplemented by refresher training to take into account the changes in the regulations; the regulations update every two years so refresher training ideally should be bi-annually but a time period of five years should be considered the maximum.
Records of all training received shall be kept by the employer and made available to the employee or competent authority upon request.
Records of training shall be verified upon commencing a new employment.
Vehicle crew that are away from their home base transporting small loads on or below ADR threshold should be given proof of training as well as a Photo ID for roadside enforcement checks (if the vehicle crew are not required to carry the ADR training certificates).
All dangerous goods are subject to the general security provisions and the vehicle crew must carry a means of identification at all times. Drivers should be particularly instructed on the importance of the security of their vehicle and its load during the transport operation.
Dangerous goods may meet the provisions for High Consequence Dangerous Goods (HCDG) and the undertaking will require a prepared security plan. The background checks of all vehicle crew will be part of this security plan and the driver/vehicle crew will be trained on all security equipment fitted to the vehicle and its correct operation. Vehicle crew will receive updates on particular security risks on route, temporary storage and the procedures to follow to report security threats, breach of the security of the vehicle or a security incident.
It is vital for carriers of HCDG to verify new staff or agency staff prior to employment.
Before employing drivers and vehicle crew involved in the transport of dangerous goods in the UK and across Europe, transport managers must ensure that the drivers hold the correct qualifications and training certificates, proof of current training is held by the employer and the drivers have had adequate background checks carried out to ensure their suitability.
Having correct checks in place will reduce the risk of being issued a roadside “probation notice”, which would be costly and could ultimately affect your O-Licence.
DfT Security Requirements for Moving Dangerous Goods by Road and Rail, www.gov.uk.
Published in October 2017. Correct at the date of publication.