The Road Transport Provisions

Transcription

1 Are you required to appoint a Dangerous Goods Safety Adviser? Guidance on European Communities (Safety Advisers for the Transport of Dangerous Goods by Road and Rail) Regulations, 2001 The Road Transport Provisions

2 Background to Regulations and Guidance: Any person or undertaking involved in the transport of dangerous goods by road and rail, subject to some limited exemptions, is required to appoint a Dangerous Goods Safety Adviser by virtue of the European Communities (Safety Advisers for the Transport of Dangerous Goods by Road and Rail) Regulations 2001, S.I. No. 6 of 2001, which came into force on 17 th January 2001 The Regulations implement Council Directive 96/35/EC on the appointment and vocational qualification of safety advisers for the transport of dangerous goods by road and rail and the associated Council Directive 2000/18/EC on minimum examination requirements for safety advisers for the transport of dangerous goods by road and rail. Safety advisers must hold a Community-type Vocational Training Certificate for the mode of transport in which he or she is involved. In relation to the transport of dangerous goods by road, this can only be obtained by passing an examination approved by the Health and Safety Authority, the national Competent Authority for this mode of transport, who issues the certificate. This guidance deals only with the transport of dangerous goods by road. The Minister for Public Enterprise is the competent authority in the State in relation to the transport of dangerous goods by rail. Do I need to appoint a dangerous goods safety adviser? (Reg. 4 and Schedule 1): As an undertaking involved in the transport of dangerous goods by road, the European Communities (Safety Advisers for the Transport of Dangerous Goods by Road and Rail) Regulations, 2001 require you, subject to some limited exemptions, to appoint vocationally qualified safety adviser or advisers, depending on the size of your undertaking. Their function is to advise you on health, safety and environmental matters in connection with the transport of dangerous goods. The requirement came into force on 17 th January 2001and applies from that date onwards. Dangerous goods are as defined in Article 2 of Council Directive No. 94/55/EC of 21 November 1994, as amended (Reg. 2) and reflecting the European Agreement on the International Carriage of Dangerous Goods by Road (ADR) The undertakings affected are those: 1. who consign dangerous goods for transport and who are involved in loading the means of transport; 2. who are operators of road vehicles; and 2

3 3. who load or unload dangerous goods while they are in transit to their final destination, such as freight forwarders or warehouses. This category also covers undertakings at ports and airports that load/unload dangerous goods onto/off road vehicles, but does not include consignees who only unload at the final destination (e.g. petrol station operators or supermarkets). It is important to note that the use of the word "transport" in the context of both the Regulations and the guidance includes the associated loading and unloading of dangerous goods. Are there Exemptions? (Reg. 5) ADO I NEED TO APPOINT There are some exemptions from the requirement to appoint safety advisers as follows, 1. those activities which concern the transport of dangerous goods in means of transport that belong to the Defence Forces or are under their responsibility, 2. those activities which concern quantities in such transport units smaller than those defined in marginals and of Annex B to the European Agreement on the International Carriage of Dangerous Goods by Road (ADR) (these are outlined in Schedule 1 attached), or 3. you are also not required to appoint a dangerous goods safety adviser or advisers if you meet all three of the following criteria: (i) (ii) (iii) your main or secondary activity is not the transport of dangerous goods, i.e. where work associated with the transport of dangerous goods is only a minor function of your business. For example, occasional deliveries of small amounts of dangerous goods by a small undertaking would not be regarded as being its main or secondary activity (whereas a large undertaking whose main delivery activity is concerned with dangerous goods would be regarded as having the transport of dangerous goods as a main or secondary activity); and you are only occasionally involved in the transport of dangerous goods(e.g. in the region of one or two such transport movements per week); and the transport of dangerous goods does not create a significant risk to the health and safety of persons and the environment. You will need to consider both the type of goods and the amounts being carried. For example, it can be generally expected that transport of the following will not create significant risks; (a) all Transport Category 4 goods (see table in Appendix 1), and 3

4 (b) individual loads of Transport Category 3 and 2 goods, with the exception of Class 1 goods, in the region of three times the relevant quantity thresholds in the third column of the Table in Appendix 1 (i.e kg. or litres for Category 3 goods and 900 kg. or litres for Category 2 goods) but which are not carried in excess of a total of 50 tonnes per year. Goods in Transport Categories 0 and 1 are considered to create a significant risk if carried in excess of the level in the third column of the Table in Appendix 1. Where mixed loads of Categories 2 and 3 are concerned the calculated value method for mixed loads in Appendix 1 may be used subject to an overall total calculated value of 3000 not being exceeded. This value will be based on the use of the multipliers in Column 4 of the Table. For the purpose of this exemption the quantity of Category 2 substances in a mixed load must however be less than a calculated value of 2700 [derived by multiplying the total quantity of the Category 2 load allowed by indent (b) above in by a factor of three]. Also in the case of Category 2 goods being carried in amounts in excess of the quantity of 300 kg. or litres specified in the third column of the Table in Appendix 1, the packages should not exceed a unit content of 50kg./litres. In this context the content of a package means, for articles, gross mass in kilograms, for solids, liquefied gases refrigerated liquefied gases and gases dissolved under pressure, net mass in kilograms, for liquids and compressed gases, nominal capacity of receptacle in litres. This exemption does not apply to dangerous goods carried in tanks or in bulk which should always be considered to pose a significant risk. Notwithstanding the assessment criteria outlined above it remains the duty of an undertaking to appoint a safety adviser if it's own risk assessment leads to the belief of the existence of significant risk. 0It is important to remember also that even if you do not need to appoint dangerous goods safety advisers, your other duties under legislation concerned with the carriage of dangerous goods by road will still apply. Who can I appoint as Safety Advisers? (Reg. 6) You can appoint whoever you wish - an existing employee, yourself, or a consultant - provided they hold a current vocational training certificate (VTC) obtained by 4

5 passing the approved examinations valid both for the mode of transport (i.e. road in the case of Health and Safety Authority approval) and for the Class (i.e. type) of dangerous goods being transported. The examination regime is administered in Ireland by the Chartered Institute of Transport in Ireland, 1 Fitzwilliam Place, Dublin 2 (Telephone / for examination syllabus and application form). An outline of the current Irish examination regime is contained in Appendix 2, which also reflects on candidate and subject choice. Advisers will need to pass a further examination every five years [Reg. 7(11)] in order to remain qualified. This further examination, because of the pace of change of National legislation and the ADR, will be the examination for first time candidates at the time of taking the examination. The new VTC will be dated to come into effect on the expiry date of the original VTC where the examination is passed before such expiry. What do Safety Advisers need to do? (Reg. 6 and Schedule1): Your adviser (or advisers) will need to: provide you with advice on all aspects of the transport of dangerous goods related to the relevant activities of the undertaking ; monitor compliance, by all appropriate means and by all appropriate action, with the legal requirements on the safe transport of dangerous goods and related health and safety practices and procedures (including the preparation of accident reports) in line with functions listed in Appendix 3; ensure the preparation of an annual report, not later than 3 months after the end of each calendar year, on your activities concerning the transport of dangerous goods. Such reports are primarily internal documents and so the format and content can vary from undertaking to undertaking. As a minimum, however, the contents should summarise the results/conclusions of the safety advisers monitoring activities (including accidents), with a view to assisting compliance with the transport of dangerous goods legal requirements. You will need to keep any such reports for five years, and make them available to enforcement agencies on request. It is important when appointing or assigning a Safety Adviser that you ensure that the Adviser is clear about his or her responsibilities and is satisfied in terms of (i) (ii) what is expected to be done (i.e. range of functions) how it is to be done (e.g. directly or by delegation) 5

6 (iii) (iv) where it is to be done (e.g. multiple sites) and the resources available being adequate. This should entail, as appropriate, a preliminary evaluation by the Safety Adviser(s) of the activities of the undertaking involving the loading, transport and unloading of dangerous goods. This evaluation should cover the state of compliance with the relevant legislation and outline what may be necessary in terms of; advising the undertaking on the transport of dangerous goods; ensuring a system is in place for monitoring compliance with the rules governing the transport of dangerous goods; ensuring a system is in place to monitoring the practices and procedures of the undertaking relating to those activities; and ensuring an annual report to the undertaking is prepared on those activities of the undertaking. A Safety Adviser may be satisfied following the evaluation that there are already certain suitable monitoring systems in place, albeit the Adviser is not directly involved. The Adviser's involvement could then, in respect of those systems, be one of auditing the systems at frequencies dictated by the result of the initial evaluation. Any persons involved in activities related to the safe transport of dangerous goods, in support or otherwise of an Adviser, must be adequately trained. The preparation of the Annual Report may also in certain situations reflect substantive preparation by the undertaking but always with final clearance and submission to the undertaking by the Safety Adviser(s). It is important that a Safety Adviser keeps you informed, preferably in writing, of any issues arising as a consequence of the carrying out of his or her functions which necessitate appropriate action being taken by you to address the issues, and where necessary, to rectify any problems. Ongoing unresolved problems should be highlighted in the Annual Report while at the same time recognising the potential, where significant concern arises, of either party approaching the Health and Safety Authority directly. WHO CAN I APPOINT ASAFETY ADVISERS AND WHAT DO THEY NEED TO DO? How many Safety Advisers do I need? (Reg. 4): The regulations leave it open to you to decide how many safety advisers you need to appoint. In deciding the appropriate number you will need to consider and make provision for issues such as:- the time, information and facilities the safety adviser(s) will need to fulfil their functions and duties, how many operating sites they will need to cover, and 6

7 whether they will prepare reports and carry out monitoring themselves or simply ensure others do these things. It is also left open to you to co-operate with other undertakings in appointing the same safety adviser(s) - this may be particularly useful on sites where more than one undertaking is involved in the transport, loading or unloading of dangerous goods, such as at ports and airports. However if you appoint more than one adviser you will have to, as with the appointment of just one adviser, ensure that the time available for any safety adviser and the means at his or her disposal to fulfil his or her functions are adequate having regard to those functions. make arrangements for ensuring adequate co-operation between the advisers (e.g., who will be responsible for writing the annual report or investigating accidents etc.) ensure that the number of individuals appointed by you is sufficient to ensure that their functions can be carried out effectively. Whether you appoint one or more Advisers it must be recognised, in the context of a Safety Adviser maintaining competency in respect of fulfilling his or her functions, that ongoing relevant training will be necessary in such areas as legislation, the ADR, accident investigation techniques, monitoring techniques etc. SAFE Accident Reports (Reg. 9): Your dangerous goods safety adviser or advisers are required to prepare and give you a report on each accident which affects the health and safety of any person, or causes damage to the environment or property, and which occurs during the transport of dangerous goods by the undertaking that has appointed him/her. This can be deemed to exclude accidents which have no implications for the dangerous goods being carried, such as a driver spraining an ankle while getting out of the cab or minor road traffic accidents. Such reports are primarily internal documents, and without prejudice to any other reporting legal requirement [e.g. Part X of the Safety Health and Welfare at Work (General Application) Regulations 1993], do not have to be sent to the Health and Safety Authority, but need to be kept by you for five years. 7

8 The report format and content can therefore vary from undertaking to undertaking. For minor incidents your existing incident recording arrangements may be sufficient but will need the safety adviser's overview and will need to reflect remedial action both recommended and taken. However, more serious incidents will warrant a fuller report giving, as a minimum, details and causes of the incident, any legal implications, and the actions needed to prevent a recurrence. This implies that safety advisers must be made aware by you of all relevant accidents if they are to fulfil Regulation 9 duties. What powers has the Competent Authority? The competent authority in the State for the purposes of the Regulations in relation to the transport of dangerous goods by road is the Health and Safety Authority whose duty it is to enforce the legislation in particular by; monitoring compliance through a programme of inspections, ensuring compliance, if necessary by recourse to the courts where fines of up to 1500 per offence and/or up to 3 months imprisonment can be applied, prohibiting the transport of dangerous goods by an undertaking where it fails to appoint a safety adviser and the transport of such goods by the undertaking may pose a serious risk to persons or property or the environment (Reg. 10). withdrawing or suspending for a stated or indefinite period a vocational training certificate where a safety adviser, without reasonable excuse, fails to comply with the functions of safety advisor under Regulation 6, or have an accident report prepared in accordance with Regulation 9. Reasonable excuse obviously includes situations where an undertaking has failed to provide a safety adviser with the necessary time, information, facilities, resources and authority to fulfil the functions assigned. Health and Safety Authority inspectors are provided with all the necessary powers by the Regulations (Reg. 10) for the purpose of ascertaining whether the Regulations are being complied with. Is there protection against deceit? (Reg. 10) There is provision under Regulation 10(14) to protect undertakings from persons who might falsely claim to be a qualified dangerous goods safety advisers or attempt to obtain certification by giving false or misleading information. 8

9 Appendix 1 Exemptions (Regulation 5). This schedule deals with the exemption from the duty to appoint a safety adviser for employers who transport limited quantities of dangerous goods in accordance with marginal 10, 010, or within the load limits specified in marginal 10, 011, of the ADR. Marginal 10, 010 Dangerous goods carried in packages Undertakings who only load, transport or unload certain dangerous goods in small quantities are exempted from having to appoint a Safety Adviser. In order to establish what the quantity limits are an undertaking must consult the ADR. Marginal of Annex B of ADR refers the undertaking to what are known as the limited quantity provisions of Annex A (i.e. marginals 2201a, 2301a, 2401a, 2471a, 2501a, 2551a, 2601a, 2801a and 2901a). In these marginals, the undertaking will find exemptions from the carriage requirements of ADR, which will apply to particular substances in the class, on condition that the substances are consigned in packages meeting certain criteria and in quantities not exceeding the stated values. If an undertaking is covered by the provisions laid down in these limited quantity marginals, it will be exempt from having to appoint a Safety Adviser. It is important to note that there are no exemptions provided under this marginal for class 1 (explosives), class 4.2 (spontaneously combustible substances), class 6.2 (infectious substances) and class 7 (radioactive materials). Consequently, undertakings involved in loading, transporting and unloading of these dangerous goods cannot claim exemption from appointing a Safety Adviser by virtue of this marginal. Marginal 10, 011 Packaged dangerous goods carried in transport units For some dangerous goods, an undertaking is exempted from appointing a Safety Adviser if the quantities of certain packaged dangerous goods, which are loaded, transported or unloaded from a transport unit, are below certain threshold limits. In order to establish which limits apply, reference is made to the ADR which uses a system whereby all dangerous goods are allocated to one of five transport categories, depending upon their level of danger; Category 0 is assigned to the most dangerous goods while Category 4 is assigned to the least dangerous. For each category, a maximum load limit is specified. This limit must not be exceeded if the exemption is to apply. The transport categories and the corresponding exemption limits, which apply, are given in Marginal 10, 011 of the ADR and are reproduced in the Table in this appendix. For certain extremely dangerous goods, such as Hydrogen Cyanide, there is no exemption while for other dangerous goods, such as motor vehicle components, there is a total exemption. It is important to note that there are no quantity exemptions for bulk or tank movements. Consequently, undertakings involved in loading, transporting and unloading dangerous goods in bulk or carried in tanks are required to appoint a Safety Adviser. 9

10 Transport category Substances/Articles Table 0 Class 1: 01, 11, 12, 24, 25, 33, 34, 44, 45 and 51 Class 4.2: Substances under (a) or packing group I of the Recommendations on the Transport of Dangerous Goods Class 4.3: 1-3 and Class 6.1: 1 and 2 Class 6.2: 1 and 2 Class 7: Material of Marginal 2704, Schedules 5-13 Class 9: 2 (b) and 3 As well as empty, uncleaned packagings, having contained substances of this transport category 1 Substances and articles under (a) or with packing group I of the Recommendations on the Transport of Dangerous Goods which are not in transport category 0 as well as substances and articles of the following classes, items or groups and letters: Class 1: 1-10 ª, 13-23, 26, 27, 29 and Class 2: T, TCª, TO, TF, TOC and TFC Class 4.1: 31 (b)-34 (b) and 41 (b)-50 (b) Class 5.2: 1 (b)-4 (b) and 11 (b)-20 (b) 2 Substances and articles under (b) or with packing group II of the Recommendations on the Transport of Dangerous Goods which are not in transport category 0, 1 or 4 as well as substances and articles of the following classes, items or groups and letters: Vehicle Multiplier maximum total quantity kg or litres Class 1: 35-43, 48 ª and 50 Class 2: F Class 6.1: Substances and articles defined under (c) Class 6.2: 3 3 Substances and articles under (c) or with packing group III of the Recommendations on the Transport of Dangerous Goods which are not in transport category 2 or 4 as well as substances and articles of the following classes, items or groups and letters: Class 2: A and O Class 9: 6 and 7 4 Class 1: 46 and 47 Class 4.1: 1 (b) and 2 (c) Class 4.2: 1 (c) Class 7: Material of marginal 2704, Schedules 1-4 Class 9: 8 (c) Unlimited --- As well as empty, uncleaned packagings, having contained dangerous substances other than those of transport category 0. ª For identification numbers 0081, 0082, 0084, 0241, 0331, 0332, 0482, 1005 and 1017, the maximum total quantity per transport unit shall be 50 kg. 10

11 In order to establish which quantity limits will apply to the load, an undertaking must first establish whether the load will consist of one or several different dangerous goods. Single substance load If the load only contains a single substance, for example, 4 x 50 litre drums of motor spirit, UN1203, which is a flammable liquid of Class 3, 3 (b): (i) (ii) the undertaking must first consult the second column in the table which addresses substances and articles under (b), since motor spirit is categorised as danger level (b) it will come under Transport Category 2 as it is not listed under Categories 0, 1 or 4; it is to be noted that substances categorised under danger level (b) generally come under Transport Category 2 (first column). The third column in the table will indicate the maximum total quantity, which must not be exceeded if an exemption is to be availed of; in this case, 300 kg or litres; Since the particular load in question only weighs 200 litres and the maximum permitted is 300 litres, the undertaking can claim an exemption from having to appoint a Safety Adviser. This exemption is dependent on all consignments being below the marginal 10,011 quantity limits. Multi-substance load from the same transport category If there are a number of substances being carried as part of one load, but they all fall under the same transport category, then the undertaking should repeat the procedure outlined steps 1 and 2 above. However, in this case the quantity of each substance being carried is simply added together to establish whether the total quantity exceeds the specified limit. For example, a load containing 300 kg of gallium, UN 2803, class 8, 65 (c) and 600 kg of batteries, wet, filled with acid, UN 2794, class 8, 81 (c): (i) (ii) (iii) the undertaking must first consult the second column in the table which addresses substances and articles under (c), since both gallium and wet batteries are categorised as danger level (c); it will be noted that substances categorised under danger level (c) generally come under Transport Category 3 (first column). The third column in the table will indicate the maximum total quantity, which must not be exceeded if an exemption is to be availed of; in this case, 1000 kg or litres; since the particular load in question only weighs 900 kg and the maximum permitted is 1000 kg, the undertaking can claim an exemption from having to appoint a Safety Adviser. 11

12 Multi-substance load comprising different transport categories In cases involving different substances from different transport categories the undertaking cannot simply consult column 3 of the table to establish the total quantity, which is permitted. Instead, a calculation involving a multiplier, which is shown in column 4 of the Table, is needed to establish the permitted quantity limits, which apply. For example, a load comprising 16 litres osmium tetroxide, UN 2471, class 6.1, 56 (a), 100 litres acetyl chloride, UN 1717, class 3, 25 (b) and 250 litres chromic acid solution, UN 1755, class 8, 17 (c): (i) (ii) (iii) (iv) (v) the undertaking must take each particular substance in the load separately and multiply the quantity to be carried by the multiplier given in column 4 to establish the calculated value for that part of the load. When this has been done for each part of the load, the calculated values for each separate part are added together to give an overall total. The value of this total must not exceed 1000 in any load if the undertaking is to be exempt from the requirement to appoint a Safety Adviser; the undertaking must first consult the second column in the table, which addresses substances and articles under (a), since osmium tetroxide is categorised as danger level (a), and therefore comes under transport category 1 as it is not listed under transport category 0. Consulting column 4 will indicate that the multiplier for transport category 1 is 50 so the quantity of 16 litres of osmium tetroxide is multiplied by 50 to give a calculated value of 800 for that part of the load; this procedure is then repeated for the remaining two substances comprising the load. The second column in the table, which addresses substances and articles under (b) is consulted, since acetyl chloride is categorised as danger level (b) transport category 2. Consulting column 4 will indicate that the multiplier for transport category 2 is 3 so the quantity of 100 litres of acetyl chloride is multiplied by 3 to give a calculated value of 300 for that part of the load; next, the second column in the table, which addresses substances and articles under (c), is consulted, since chromic acid solution is categorised as danger level (c) transport category 3. Consulting column 4 will indicate that the multiplier for transport category 3 is 1 so the quantity of 250 litres of chromic acid is multiplied by 1 to give a calculated value of 250 for that part of the load; finally, the calculated values for each of the elements of the load are added together: = 1350 Marginal sets a maximum calculated value of 1000 for the undertaking to be exempt from the requirements of the Safety Adviser Regulations. Since that value is exceeded in this case, the undertaking would have to appoint a Safety Adviser. 12

13 Appendix 2 THE IRISH DANGEROUS GOODS SAFETY ADVISER EXAMINATION REGIME To receive a Vocational Training Certificate and qualify as a DGSA, candidates must undertake and successfully complete an examination in three subjects structured in line with the requirements of Regulation 7 of the European Communities (Safety Advisers for the Transport of Dangerous Goods by Road and Rail) Regulations, 2001 as follows: A Core paper, a Road paper (the mode paper) and one of the Class papers as follows, CORE PAPER 1hr. 15mins ROAD PAPER 1hr. 45mins CLASS PAPERS 1hr. 45mins INCORPORATING A CASE STUDY QUESTION THAT DEMONSTRATES THE ABILITY TO CARRY OUT DGSA FUNCTIONS CLASS 1 CLASS 7 CLASS 2 MINERAL "GENERAL ALL OILS CHEMICAL CLASSES UN 1202, CLASSES" 1203, CLASSES 3,4,5,6,8,&9 Overall the subjects to be covered in the examination must reflect the requirements of SCHEDULE 2 of the Regulations. Generally, the Core paper is an overview of the regulations, identifying substances, packaging marks and labels. The Road paper concentrates on requirements such as those set out in Annex B of ADR, but there is no clear distinction between Annexes A and B, so questions could include Annex A subjects. The paper also includes case study whereby a candidate can demonstrate that he or she has the ability to carry out the functions of a safety adviser. The Class papers examine in more detail the concepts covered in the Core paper, but instead of simply identifying substances involved in a transport operation, candidates must expect to be questioned in greater detail about the packaging, marking and labeling requirements, compliance thresholds/limited quantities, as well as some parts of the documentation requirements. Choosing the right candidate Clearly the selection of candidates is not a matter for the Examination Body or the Health and Safety Authority, but is the responsibility of each individual employer. However, the selection of the right candidate will avoid unnecessary expense and, for the individual, the stress of possibly struggling to come to terms with the examination and the prospect of failing to qualify. 13

14 Feedback from training providers suggests that a small but significant proportion of candidates who enroll for training have been selected by their employer without full consideration having been given to the requirements of the examinations. As a consequence these candidates struggle to achieve the DGSA qualification. It is therefore vital that all parties carefully study the examination syllabus so that they appreciate the standard of the examinations and the areas of the legislation which will be tested. The DGSA qualification is not a reworking of the Dangerous Goods Drivers Vocational Training Certificate examination - it is significantly more challenging. Sample examination booklets provided by the Examination Body should help you and your prospective candidates in deciding whether they have the skills and experience to tackle the examination. The DGSA examination requires, for example, knowledge of the duties of the consignor in terms of principles of classification of dangerous goods, package selection and labeling as well as carrier responsibilities such as documentation, vehicle marking and labeling, and safety equipment requirements. The amount of tuition and study required to fill knowledge and skills gaps can be considerable, particularly on top of the normal working day and for a candidate who has not undertaken a formal examination for some time. Careful selection of the right candidate will go a long way to ensuring success in the examination. Selecting the subjects As outlined above to qualify as a DGSA, candidates must undertake and successfully complete an examination in three subjects as follows: Core paper and Road paper (the mode paper) and one of the Class papers Candidates are required to qualify for the transport mode used by their business (in this case road transport) and for the classes of dangerous goods carried, however infrequently. Candidates should realise that the more classes they qualify for, the more versatile their qualification will be. Somebody who has passed the All Classes paper (along with the Core and Road mode papers) will be able to work in any road transport business handling all classes of dangerous goods. Similarly, they avoid the need for further qualifications should the nature of the dangerous goods carried change. A qualification in the more restricted papers [e.g. Class 1, Class 2, Class 3 (Mineral Oils) or Class 7] may limit the business or the development of the individual. The majority of the general principles covering the consignor and carrier responsibilities during the transport of dangerous goods are common to both the All Classes paper and the more specific Class papers. Therefore, although in the All Classes paper there are more types of dangerous goods to learn about, the basic principles involved are often the same. Every attempt is made by those setting the examinations to ensure that the degree of difficulty of the questions within each class paper is similar. In many cases the questions are drawn from a common question bank. 14

15 Appendix 3 FUNCTIONS OF SAFETY ADVISERS The functions of a safety adviser include in particular the following - (a) (b) (c) (d) monitoring compliance with the rules governing the transport of dangerous goods; advising the undertaking on the transport of dangerous goods; ensuring that an annual report to the undertaking is prepared on the activities of the undertaking concerning the transport of dangerous goods; monitoring the following practices and procedures relating to the activities of the undertaking which concern the transport of dangerous goods (i) the procedures for compliance with the rules governing the identification of dangerous goods being transported, (ii) the practice of the undertaking in taking into account, when purchasing means of transport, any special requirements in connection with the dangerous goods to be transported, (iii) the procedures for checking the equipment used in connection with the transport of dangerous goods, (iv) the proper training of the undertaking's employees and the maintenance of records of such training, (v) the implementation of proper emergency procedures in the event of any accident or incident that may affect safety during the transport of dangerous goods, (vi) the investigation of and, where appropriate, preparation of reports on serious accidents, incidents or serious infringements recorded during the transport of dangerous goods, (vii) the implementation of appropriate measures to avoid the recurrence of accidents, incidents or serious infringements, (viii) the account taken of the legal prescriptions and special requirements associated with the transport of dangerous goods in the choice and use of sub-contractors or third parties, (ix) verification that employees involved in the transport of dangerous goods have detailed operational procedures and instructions, (x) the introduction of measures to increase awareness of the risks inherent in the transport of dangerous goods, (xi) (xii) the implementation of verification procedures to ensure the presence, on board the means of transport, of the documents and safety equipment which must accompany transport and the compliance of such documents and equipment with health and safety regulations, and the implementation of verification procedures to ensure compliance with legislation governing loading and unloading of dangerous goods. 15