International efforts pay off

By the time that this column is being read, the IMO’s provision for the mandatory training of shoreside personnel involved with packaged dangerous goods will have come into force. For those who might want to check on what is said, and where, attention should be directed to chapter 1.3 of volume 1 of the IMDG Code.

The provisions regarding such training previously used the words "should be trained", but now, in amendment 34, say instead "must be trained"; and, of course, amendment 34 came into mandatory force on 1 January 2010.

This is all part of a united international effort aimed at improving the knowledge and awareness of the international provisions for the safe transport of dangerous goods in packaged form by sea, and, thereby, reducing incidents involving lack of implementation of those provisions. The latest series of reports of inspections by maritime administrations considered by the IMO’s Dangerous Goods, Solid Cargoes and Containers Sub Committee (DSC) at its 14th meeting last September still showed a lamentable degree of non-compliance, especially with core subjects such as documentation and placarding and marking.

Now that the provision has reached the mandatory stage, it is time to consider the implications. Who is it aimed at, how are they to become aware of the provisions, how can such training be achieved, who is going to monitor and who is going to enforce?

Firstly, the IMDG Code concerns the sea mode and, therefore, we are considering the maritime chain. The term "shoreside personnel" covers two broad groups of people: those who work in the ports and terminals and those known as "cargo interests" in a related IMO publication, Safe Transportation of Dangerous Cargoes in Port Areas.

The latter includes all those who combine to cause the cargo to come to the port and ship for export, and includes shippers, consignors, packers, consolidators, forwarders and agents, and, in terms of numbers of persons, will account for many more people than the former group. Incidentally, training of those who work on board cargo ships that carry the cargo have had to be trained for some years under separate mandatory IMO provisions.

Raising awareness, monitoring and even enforcement are linked. With maritime administrations generally very stretched to deal with necessary issues dealing with the seafaring safety of ships and crews and, from observation, often suffering from shortage of resources, it will be the maritime chain that needs to address these aspects. Monitoring, raising awareness and "enforcement" in its widest sense is all within the maritime chain’s capabilities and, as it is the chain and the people who work in it who suffer the consequences if things go wrong, there is every inducement to act accordingly.

Accordingly, last year, the TT Club and ICHCA International, acting in concert, advised their respective members to develop a strategy on this subject. With regard to those within the port and terminal community, it consisted of reviewing the status of training of their affected personnel and, where necessary, increasing the amount and or level of training given. With IMO’s Recommendations on the Safe Transportation of Dangerous Cargoes in Port Areas having included provisions regarding such training for many years, and such recommendations having been reflected in national provisions, there should be no large problem complying with the new obligation. With regard to "cargo interests", they are the customers of ports, terminals and shipping lines and the suggested strategy consisted of the following steps:

n have a deliberate drive to inform all "cargo interests" of the new requirements. This should be achieved as soon as possible and linked to the 1 January date. This can be achieved by a simple leaflet or circular sent to all customers

n later in the year, ask whether such training has been achieved and if not, what steps are being taken to effect it

n ask for proof that such training has been given. It is likely that many organisations contacted this way may ask for advice on how or where to get such training. Large numbers may need to be trained and there may be difficulties getting numbers together and away from the workplace for one to three days, depending what the need is.

Both TT Club and ICHCA International anticipated such queries and investigated various possibilities before recommending the Exis Technologies online training package. This enables an individual to take the learning package without leaving the terminal. In fact, as the latter is an IMO distributor, some discount is possible when ordered through that organisation.

This is an important issue for the entire marine chain, and the effectiveness of the new IMO provision will rest upon how it is responded to. The action outlined above is, accordingly, recommended to all those readers who are similarly involved. If we want these measures to have effect, now is the time to act.