Amsa Imgd Code

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IMDG CODE

PROPOSED TRAINING REQUIREMENTSFROM 01 JAN 2010


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Introduction


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IMDG Code Training Requirements

With the mandatoryadoption of the 2008

edition of the IMDGCode on the 1st of

January 2010 training

will be mandatory forshore based personnel

engaged in the transport

of dangerous goods bysea.


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The training requirements are containedchapter 1.3 of the IMDG code.

Training for sea going personnel is alreadymandatory by virtue of the requirements of theSTCW Convention, so these requirements do

not relate to this segment of the industry.


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Section 1.3.1.1 of the code outlines themandatory requirement:

Shore based personnel engaged in thetransport of dangerous goods intended to betransported by sea shall receive training in

the contents of the dangerous goodsprovisions commensurate with theirresponsibilities..


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Not all of Chapter 1.3 is Mandatory withsections 1.3.1.4 to 1.3.1.7 remaining

recommendatory..

however, they do provide guidance as tothe nature of training that should be provided..


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Chapter 1.3 has three main training elements:

1. General awareness training (mandatory)2. Role specific training (mandatory)

3. Safety Training (recommendatory)

It is reasonable to accept that safety training

will addressed both as part of normal OH&S

training provided and by general awarenesstraining so AMSA will not add any additionalregulatory requirements for this element.


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Mandatory Training Requirements


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The two mandatory training requirements applya range of shore based personnel involved in

the shipment of Dangerous goods by sea,namely those that:

classify dangerous goods and identify

Proper Shipping Names of dangerousgoods;

pack dangerous goods;

mark, label or placard dangerousgoods;

load/unload CTUs;


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prepare transport documents

for dangerous goods;

offer dangerous goods for transport;

accept dangerous goods for transport;

handle dangerous goods in transport; prepare dangerous goods

loading/stowage plans;

load/unload dangerous goodsinto/from ships;

carry dangerous goods in transport;


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enforce or survey or inspect for

compliance with applicable rules and

regulations; or

are otherwise involved in the transport

of dangerous goods as determined by

the competent authority

It is an eye watering list . but the scope of

training can be tailored to the individual rolesas indicated in section 1.3.1.1 of the IMDGCode.


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To comply with the mandatory elements of

Chapter 1.3 the training systems need to

achieve a number of outcomes:

All Supervisors must have general

awareness training and be appropriately

trained in relation to their role;

Staff (as identified above) must have

general awareness training and beappropriately trained in relation to their

role;


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Where staff are not trained they must be

under the supervision of someone who is

trained pending completion of training.

Staff and their employers are to keep

records of training undertaken and theseare to be available upon request.

Refresher training will be required for role

specific training (AMSA is currentlyconsidering a five year cycle for this)


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What is General Awareness Training?


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General awareness training is intended to be

an overview of the requirement that relate to

the carriage of dangerous goods.

It should be noted that the general awareness

training requirements of chapter 1.3 of theIMDG Code would be the same as those

provide under regulation 1.3 of the Model

Regulations adopted with ADG7.. soWhere training has been provided in

accordance with this it


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.. where training has been provided in

accordance with regulation 1.3 (or relevant

state legislation adopting regulation 1.3) thiswill be accepted as being the same as general

awareness training provided employers and

employees have a record of this training.

Similarly..


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Similarly where staff have received OH&S work

place training which provides the overview

required this will is also acceptable as generalawareness training but ..

.employers must ensure all the elementsdescribed in the IMDG code are covered and

employers and employees have a record of this

training.AMSA does not envisage requiring additional

training in both these scenarios.


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So what does General Awareness Traininginclude:

A description of the classes ofdangerous goods;

An overview of labelling, marking andplacarding requirements: and

An overview of packing, stowage,segregation and compatibility

provisions. A description of the purpose and

content of dangerous goods transport

documents


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And finally a description of available

emergency response documents

A first glance it may seem daunting list but it

must be remembered this is simply an overview

and greater detail need only be provided whereit is considered necessary by the individuals

role.

That detail will be provided by function specific

training.


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Role Specific Training


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Under section 1.3.1.1 of the IMDG code it will

be the employer who decides what training will

be provided but.

.. AMSA may undertake audits to determine

the effectiveness of such training.

This begs the question as to how the employer

can determine what training is required for a

given role.


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For role specific training guidance is provided

in the recommendatory sections 1.3.1.5 and

1.3.1.6 of the IMDG Code.

These two tables match training needs with

particular functions to assist employers (andtraining providers, where relevant) in ensuring

training is commensurate with responsibilities.

If we look at table 1.3.1.6 we can see how thisinformation is provided.


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This does not mean that AMSA will leave the

process of selecting appropriate training

entirely in the hands of the employer

It is envisaged that for a number of specific

functions the training course employed willneed to be approved by AMSA.

On this note it is time to look at AMSAs role.


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How will AMSA apply this?


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The requirements for training will be adopted

through changes to Marine Orders Part 41. It is

envisaged these changes will:

Require mandatory training for shore basedpersonal as identified by the IMDG Code and

set a period for refresher training for functionspecific training;

Make provision for AMSA to audit the

provision of training; Allow the Manager, Ship Inspections to

accept other training as equivalent to theserequirements; but .


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Will also mandate acceptance by AMSA oftraining courses to be undertaken by

individuals who will responsible for specifictasks/functions.

This requirement will be applicable to

persons who will be responsible for:

packing dangerous goods;

marking, labelling or placarding dangerous

goods;

preparing transport documentation and

signing declarations (shippers and container

packing declarations)


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Where acceptance by AMSA is required this

will be granted by the Manager Ship

Inspections.

While this arrangement is not dissimilar to

training requirements established by CASA it isaccepted that some time will be required to

have course accepted.

It is also noted that many in the industry have,or are in the process of receiving training with

course that cannot be approved until the

regulations are in place.


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To resolve this issue AMSA is considering

implementing training requirements in a

staged approach, for example:

1. By the 1st of January 2010 the trainingrequirements as detailed in chapter 1.3 of the

IMDG code will need to be implemented , butwithout AMSA acceptance of courses.

2. By the 1st of January 2011 individuals undertakingthose function that require accepted training musthave received training accepted by AMSA.


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Where to from here?


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As you may have gathered from the

presentation we are still finalising the detail of

what will be required.

In this regard input is most welcome, however if

you want to make comment you will need to beprompt.

Comments and suggestions may be to


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Comments to:

[email protected]


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Any Questions Please

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Amsa Imgd Code