From 1 January 2023, all employers of personnel performing functions aimed at ensuring that dangerous goods are transported in accordance with the ICAO Technical Instructions (TI) must establish and maintain a dangerous goods training programme that includes a competency based approach to training and assessment (hereafter referred to as CBTA).
In the UK, this includes, but may not be limited to, the following entities:
- Operators approved to transport dangerous goods.
- Operators not approved to transport dangerous goods.
- Ground handling and cargo agents.
- Freight forwarders.
- Shippers of dangerous goods (unless otherwise stated in the TI).
The implementation of CBTA may be a significant change from traditional training and testing methods and the transition will need to be carefully managed to maintain a high standard of staff competence.
All employers are encouraged to familiarise themselves with the changes to the TI, the IATA Dangerous Goods Regulations (IATA DGRs) (if applicable) and other supporting material such as ICAO Doc 10147, Guidance on a Competency-based Approach to Dangerous Goods Training and Assessment, and begin implementing CBTA at the earliest opportunity.
Key considerations when implementing CBTA include:
- Training must include ‘general awareness/familiarisation training’, ‘function-specific training’ and ‘safety training’.
- Personnel who are assigned to new functions must be assessed to determine competence in respect of their new function.
- Other than for designated postal operators, the ‘Categories of Staff’ previously used to define the content of training courses, are no longer applicable (but may still be used as a guide).
- It is the employers responsibility to ensure that personnel are competent to perform any function for which they are responsible prior to performing any of these functions.
- Whilst third-party training providers may be used to conduct the training and/or competence assessment, the responsibility for ensuring that personnel are competent remains with the employer.
In accordance with UK Regulation (EU) No 965/2012 and the Air Navigation (Dangerous Goods) Regulations (AN(DG)Rs), as applicable, the following training will continue to require approval from the CAA and any substantive amendments made as a result of the implementation of CBTA from 1 January 2023 will need to be submitted in advance of the effective date:
- Training programmes for any United Kingdom operator approved to transport dangerous goods.
- Training programmes for any United Kingdom operator holding an Air Operator Certificate (AOC) issued by the CAA that is not approved to transport dangerous goods.
- Training programmes for personnel performing dangerous goods acceptance functions (previously Category 6 staff).
- Any training provided by an approved training provider, in accordance with CAP 483, Training in the Safe Transport of Dangerous Goods.
Amendments to training programmes for operators should be submitted to firstname.lastname@example.org and the assigned Inspecting Officer (Dangerous Goods)/Flight Operations Inspector.