The German Dangerous Goods Safety Advisor Act (Gefahrgutbeauftragten - Verordnung, GbV), Council Directives 96/35/EC and 2000/18/EC - and the EU Framework Directives for ADR and RID respectively - required Member States to implement legislation to ensure that certain undertakings which transport dangerous goods by road, rail and inland waterway, including the transport related activities of loading and unloading, appoint dangerous goods safety advisers (DGSAs).
In Germany, the GbV requires that companies which process, ship, load or pack dangerous goods are generally under the obligation to appoint a DGSA. Certain exemptions are applicable, for example where dangerous goods are exclusively shipped as limited quantities.
DGSAs need to have obtained a vocational training certificate (VTC), after undergoing training and successfully completing a written examination approved by the Competent Authority of a Member State. VTCs are mutually recognized in all EU Member States and in any non-EU States which are signatories to RID or ADR.
In Germany, such VTC is required for each mode of transport used or covered by the company. VTC’s are issued after successful completion of a test by the German Chambers of Industry and Commerce (Industrie- und Handelskammern, IHK’s); a prerequisite for undertaking the test is vocational training with a recognized training provider such as LOGAR.
Although the requirement to appoint a DGSA for the air transport mode has been dropped effective September 1st, 2011, the related corporate responsibilities of course remain and must be assigned to respective personnel within the organization.
It is not always feasible to appoint the DGSA internally, e.g. to assign this task to an employee.
Typically, it is impossible to carry out the DGSA’s assignments as an auxiliary task.
A particular issue for employees which are involved in the shipping or processing of dangerous goods for themselves is, that in accordance with the requirements of the German GbV act such employees would be required to supervise and monitor themselves - a legal construction which is generally not in compliance with applicable German law.
An external DGSA which is not employed by the company often has a more unbiased view on matters at hand and operational procedures in place. Furthermore, the general expenses for the DGSA such as trainings, refresher trainings, business publications etc. are in such case part of the external DGSA’s fees.
In certain cases such eternal DGSA will have less issues in covering an additional mode of transport on short notice or resolve particular problems through bring in external subject matter knowledge.
If you would like to benefit from LOGAR’s 25 year experience in all transport modes, give us a call or drop us a line. We would be pleased to make you a tailored offer for taking over your DGSA related duties, including the creation of the DGSA’s annual report.
Needless to say that LOGAR’s portfolio of services does include the coaching of internal DGSA’s, the support of DGSA’s in regard to particular subject matters or corporate projects or for single modes of transport.
Whatever your requirements may be, challenge us. Tell us about your problem, and we will explain how LOGAR will assist you in doing better and more efficient business.
LOGAR prizes itself for solutions which are adapted to customers needs - we’d be happy to demonstrate the benefits of partnering with LOGAR.