New rules on DGR training

As of January 01, 2023, Dangerous Goods Rules (DGR) trainings have entered into a new training approach as Competency Based Training Assessment (CBTA).

For this reason, the previously used training categories have been removed and are no longer applicable. While the wording of the current training requirements is changed, the principle of “commensurate with responsibilities” and the goal of ensuring all employees perform their functions competently has not. The revisions simply emphasize this principle and goal by supporting a competency-based approach to training and assessment. They require a person to be trained and assessed to demonstrate their competence to perform the function(s) for which they are responsible.

A safe and efficient air transport system is dependent on a competent workforce.ICAO has recognized that this can be achieved through the implementation of a competency-based approach to training and assessment. The Technical Instructions for the Safe Transport of Dangerous Goods by Air (Doc 9284, “Technical Instructions”) require that employers ensure personnel are competent to perform any function for which they are responsible prior to performing it. A competency-based approach to training and assessment is an effective way to ensure this requirement is met.

Act of August 5, 2022 on the transport of dangerous goods by air

In Poland, a new act regulating transport of dangerous goods by air has been recently created – Act of August 5, 2022 on the transport of dangerous goods by air. Additionally, to facilitate the training approach change, Civil Aviation Authority of Poland provides guidance on dangerous goods training programmes in Guidelines No. 9 of the President of the Civil Aviation Authority of June 13, 2022 on training in the processes of transporting dangerous goods by air based on a competency approach.

Ensuring personnel are able to perform their functions competently is critical to any organization. A competent workforce reduces the costs caused by poor performance or miscommunication of job expectations. The consequences of employing an incompetent dangerous goods workforce can be especially damaging, as this could result in costs and delays in shipment, and even more critically, it could result in the introduction of safety risks. As an example, identifying, classifying, packing, marking, labelling and documenting dangerous goods for transport are critical to the safe transport of dangerous goods by air. The operator depends on these functions being performed competently by those preparing and offering a consignment for transport so that the operator in turn will be aware of the hazards posed and can take the necessary steps to mitigate the risk to the aircraft and its occupants. If personnel performing these functions are not trained to perform them competently, unknown risks may be introduced into air transport. Accepting dangerous goods for air transport requires an operator to verify that dangerous goods are properly prepared for transport through the use of a checklist. If personnel accepting dangerous goods are not trained to competently perform this function, they may accept improperly prepared shipments of dangerous goods into air transport thereby putting the aircraft and its occupants at risk. Alternatively, they may unnecessarily reject properly prepared shipments resulting in delays of shipments and increased costs to the shipper and the operator.

A competency-based approach to training and assessment ensures that trainees know what tasks they are expected to perform competently, and evaluators know what performance to assess.

The Technical Instructions state that personnel must be trained commensurate with the functions for which they are responsible. These responsibilities are determined by the specific functions the personnel perform and not by their job titles. Concentrating on functions and responsibilities rather than a job title or job description ensures that a person is competent to perform the function in compliance with the Technical Instructions.

The depth of training each person receives should be appropriate to the functions performed. This could range from a familiarization level to an expert level for certain personnel.

To ensure the compliance with the legal requirements on safe transport of dangerous goods by air in force and to be trained to perform all the related functions competently, please review the list below with the corresponding new courses offered by Avsec.pl based on competency-based training and assessment.

• Function 1

  • Personnel responsible for preparation of dangerous goods consignments.
  • Training and assessment for personnel preparing dangerous goods consignments for transport has been tailored to address those classes, divisions or even UN numbers that they prepare for transport. Training and assessment addresses the specific tasks personnel perform to ensure that the personnel assgined to prepare dangrous doogs consignments have relevant knowledge to competently perform these functions.

• Function 2

  • Persons responsible for processing or accepting goods presented as general cargo.
  • Personnel responsible for processing goods presented as general cargo should be competent to perform tasks aimed at preventing undeclared dangerous goods from being loaded on an aircraft. They may work for freight forwarders, ground handling agents or operators. Personnel needs to have relevant knowledge to competently perform these tasks.

• Function 3

  • Personnel responsible for processing or accepting dangerous goods consignments.
  • Personnel responsible for processing or accepting dangerous goods consignments shall be able to correctly review and verify dangerous goods transport document, airway bill and undetand State/operator variations. Additionally, requirements for such personnel include recognition of marks, labels and verification of package type and package conditions, including State/operator variations. Training addresses the specific tasks regarding safety data colleaction.

• Function 4

  • Persons responsible for handling cargo in a warehouse, loading and unloading unit load devices and  loading and unloading aircraft cargo compartments.
  • The following are tasks personnel responsible for handling cargo in a warehouse, loading and unloading unit load devices, and loading and unloading passenger baggage and aircraft cargo compartments typically perform and for which training and assessment is therefore required: Managing cargo pre-loading, Transporting cargo/baggage and Collecting safety data.

• Function 5

  • Persons responsible for accepting passenger and crew baggage, managing aircraft boarding areas and other tasks involving  direct passenger contact at an airport.
  • The following are tasks personnel responsible for accepting passenger and crew baggage, managing aircraft boarding areas, and other functions involving direct passenger contact at an airport typically perform and for which training and assessment is therefore required: Accepting passenger and crew baggage and Collecting safety data

• Function 6

  • Personnel responsible for the planning of aircraft loading.
  • Managing cargo pre-loading is the primary task personnel responsible for planning of aircraft loading (passengers, baggage, mail and cargo) would typically perform and for which training and assessment is therefore required.

• Function 7

  • Flight crew.
  • Transporting cargo/baggage, including detection of presence of dangerous goods not permitted in baggage, NOTOC interpretation, application of procedures in the event of an emergency and safety data collection are the primly topics required for Function 7.

• Function 8

  • Flight operations officers and flight dispatchers.
  • Managing dangerous goods pre- and during flight, which includes NOTOC interpretation, application of procedures in the event of an emergency are the tasks flight operations officers and flight dispatchers would typically perform and for which training and assessment is therefore required.

• Function 9

  • Cabin crew.
  • Operator requirements application, passenger baggage requirements verification and pilot-in-command advisory procedures are essential when accepting passenger and crew baggage. Moreover, detection of presence of dangerous goods not permitted in baggage NOTOC interpretation, application of procedures in the event and safety data collection are also covered during this training.

• Function 10

  • Personnel responsible for the screening of passengers and crew and their baggage, cargo and mail.
  • The following are tasks that personnel responsible for the screening of passengers and crew and their baggage, cargo and mail would typically perform and for which training and assessment is therefore required: Check packages for indications of undeclared dangerous goods and Identify forbidden dangerous goods.