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Dangerous Goods Safety Adviser (DGSA) 

Guidance for undertakings

Guidance for DGSAs

Guidance for undertakings

What is a DGSA?

A Dangerous Goods Safety Advisor (DGSA) is a person certified to provide advice to undertakings whose activities include the consignment, carriage, or the related packing, loading, filling or unloading of dangerous goods, to monitor compliance with legal requirements and to ensure the preparation of an annual report.

Who needs to appoint a DGSA?

Undertakings involved in the consignment or carriage of dangerous goods by road, and related activities, must appoint a vocationally qualified safety adviser. A DGSA’s function is to advise the undertaking on health, safety and environmental matters in connection with the carriage of dangerous goods.

Relevant undertakings include those who:

  • consign dangerous goods,
  • are engaged in the related packing, filling, loading or unloading of dangerous goods,
  • are operators of road vehicles used for the carriage of dangerous goods,
  • load/unload dangerous goods in transit to their final destination (including temporary storage), such as freight forwarders or warehouses - this category also covers undertakings at ports and airports that load/unload dangerous goods on or off road vehicles.

Are there exemptions from appointing a DGSA?

Yes, there are instances where you may not be required to appoint a DGSA, for example, where the dangerous goods handled by your undertaking are minimal, low risk or infrequently consigned.

The assessment of whether or not you are required to legally appoint a DGSA should be carried out by a competent person and should be documented. Your particular circumstances should be reviewed periodically to ensure that the initial assumptions and criteria are still valid and applicable over time.  

Examples of activities which are exempt from appointing a DGSA:

  • Activities concerning the carriage of dangerous goods in vehicles under the responsibility of the Defence Forces or armed forces of a Contracting Party to the ADR;
  • Activities wholly performed within the perimeter of an enclosed area with restricted public access, for example, dangerous goods moved within a storage facility or the activity of moving dangerous goods for use within a facility;
  • Activities where a vehicle is being used to transfer dangerous goods between private premises and another vehicle situated in the immediate vicinity or between one part of a private premises and another part in the immediate vicinity even when the premises are separated by a public road;
  • Activities which concern quantities in each transport unit not exceeding those referred to in:

ADR 1.1.3.6 (small load exemption, see section 5.2 of our guide),

ADR 1.7.1.4 (certain radioactive materials),

ADR 2.2.62.1.5 (exempt infectious substances),

ADR 3.3 (special provisions),

ADR 3.4 (packaged goods in limited quantities, see section 5.4 of our guide),

ADR 3.5 (packaged goods in excepted quantities, see section 5.5 of our guide).

  • Activities which meet the following criteria for national carriage:

Your main or secondary activity is not the carriage by road, or the related packing, filling, loading or unloading of dangerous goods.

You are only occasionally involved in the transport of dangerous goods, for example, in the region of only one transport operation per month.

  • A construction company, who may occasionally carry dangerous goods from one site to another or collect dangerous goods (for example, 1500L of fuel in drums or jerricans) from a supplier and carry the goods to a construction site. In this case, the carriage of the dangerous goods would not be regarded as a main or secondary activity. However, routinely distributing fuel supplies to multiple sites would be considered a secondary activity.
  • Consignees receiving dangerous goods where the responsibility for unloading lies with the carrier/vehicle driver, for example, retail forecourts receiving fuel from road tankers.
  • Distribution of dangerous goods within the load limits specified under ADR 1.1.3.6.3 “small load” exemption. This exemption is frequently availed of by couriers handling small packages containing dangerous goods.
  • An undertaking who subcontracts their legal responsibilities to a third party, for example, a carrier who subcontracts carrier duties to a third party transport company.

Note all instances where ADR responsibilities are transferred to third parties must be dealt with in a “contract for carriage”.

Examples of activities where the appointment of a DGSA would be required:

  • Manufacturers or distribution centres handing over dangerous goods for carriage;
  • Producers of hazardous waste in significant quantities;
  • The activities of ‘carriers’ of dangerous goods such as logistics companies, freight forwarders, vehicle/fleet operators and courier companies. Such undertakings must consider that their main or secondary activity is the carriage of dangerous goods;
  • A subcontractor engaged to pack dangerous goods on behalf of the manufacturer;
  • Fuel oil tanker operators;
  • Roofing contractor distributing LPG to various work sites;
  • Fuel distributers carrying LPG cylinders and or kerosene in containers.

To note, the carriage of dangerous goods in tanks and in bulk always creates significant risk and thus will always require the appointment of a DGSA.

It is important to remember that even if you do not need to formally appoint a DGSA, specific requirements under the regulations still apply, for example, the use of the correct packaging and labelling, provision of the correct documentation when applicable. You are thus likely to require support and guidance from time to time, to assist you in maintaining complicance with the relevant legislation. The level of support is best provided by a DGSA or a health and safety professional with competence in this area.

Who can be appointed as a DGSA?

A DGSA may be the head of an undertaking, an employee or an external consultant, provided that the appointed person holds a current vocational training certificate. A formal appointment of a DGSA must be in writing.

Some DGSAs may be experienced in various different modes of transport (road, sea or air) and experience of the particular requirements of your industry sector is advised.  

What training and qualifications are required for DGSAs?

A DGSA must have a vocational training certificate. This can only be obtained by passing an examination approved by the competent authority. In Ireland, the Chartered Institute of Logistics and Transport (CILT) has been appointed by the HSA as the examination body for DGSAs for the carriage of dangerous goods by road. 

Vocational training certificates are issued by CILT to candidates who have successfully completed the approved examination.

A DGSA certificate is valid for 5 years and specifies the mode of transport. 

Persons holding a current DGSA certificate from any Contracting Party to the ADR may act for an undertaking in any other Contracting Party for the classes of dangerous goods covered by their certificate.

The Health and Safety Authority does not publish a list of qualified DGSAs.

For more information on how to obtain DGSA certification, please refer to the CILT website.

DGSAs must maintain training and competentence on an ongoing basis, in areas such as legislation, multimodal transport where applicable, accident investigation techniques and procedures for the monitoring of activities.

The ADR is amended every two years. DGSAs are required to inform themselves of the changes and advise their clients accordingly. Official amendments to the ADR are made available on the UNECE website on a biennial basis.

How many safety advisers do I need?

If you have multiple sites or your business is particularly complex or an employee acting as DGSA has an existing role and does not have the time necessary to fulfil the DGSA role in full, you may need to appoint more than one DGSA.

You will need to consider factors such as:

  • the extent of the DGSA role in relation to your business,
  • the allocation of time and resources to fulfil the role, and
  • the potential delegation of tasks to competent individuals other than the DGSA(s).

If more than one DGSA is appointed, you must ensure that all responsibilities are clearly defined and allocated in full between the appointed DGSAs so as to ensure compliance with all relevant requirements of ADR 1.8.3.3 . It is recommended to clarify such roles in writing identifying relevant duties that each DGSA will be responsible for.

Guidance for DGSAs

What are the duties of a DGSA?

The duties of a DGSA are listed in ADR 1.8.3.3 and largely cover:

  • monitoring compliance with the requirements governing the carriage of dangerous goods and advising the undertaking;
  • monitoring the practices and procedures of the undertaking regarding the activities associated with the transport of dangerous goods;
  • preparing an annual report on the activities of the undertaking relating to the carriage of dangerous goods.

They include the following: 

Classification of dangerous goods

You must advise on the classification of dangerous goods as appropriate, including hazardous waste, in accordance with ADR Chapter 2.2. You should provide the undertaking as and when required, with a written copy of all test results and the mechanism by which the classification process was carried out for each of the dangerous goods addressed. In certain circumstances (for example, wastes), it may be necessary to test samples to determine the correct classification. ADR Part 2 specifies the classification criteria and details certain test methods. To note, testing where required must be carried out in accordance with the ADR and the UN Manual of Tests and Criteria.

Packaging and tank provisions

You should provide written advice to the undertaking regarding the choice of suitable means of containment of dangerous goods. Such advice must give adequate detail to ensure the purchase and appropriate use of packaging, tanks, containers and vehicles for the relevant dangerous goods. Where appropriate you should provide written advice on all relevant packaging and tank provisions in accordance with ADR Part 4 and for vehicles ADR Part 9.

You should ensure the undertaking holds as appropriate all packaging type approval certification and conditions of use if prepared by a manufacturer or supplier. Conditions of use documentation should advise on operating procedures concerning the use of UN approved packaging. For example, when filling an Intermediate Bulk Container (IBC), you should ensure that it is of the correct design type and within inspection date, it is not filled beyond any filling limit, it is marked and labelled appropriately, and closures are sealed prior to loading.

Vehicles and tanks and certain types of packaging require ongoing certification and testing. These requirements must be identified and covered by appropriate procedures to ensure ongoing compliance such as verification checks on gas cylinders, plastics containers, IBCs, large packaging and tanks prior to use to ensure they are in date, correct for the dangerous goods to be carried, marked and labelled appropriately.

Refer to ADR for the appropriate initial/type approval certification requirements and ongoing test and inspection requirements. An appropriate schedule of work should be drawn up identifying affected packaging, tanks and vehicles used by the undertaking to ensure this aspect of compliance is managed accordingly.

 

Consignment Procedures

You must provide written advice to the undertaking on the requirements for compliance with the procedures for proper consignment of dangerous goods. Such advice should, where applicable, include details of the following:

  • The appropriate use, marking and labelling of packages in accordance with ADR 5.2. Such advice should be provided in respect of each participant role that the undertaking fulfils, such as consignor, packer, loader and unloader. Duties of participants are detailed in ADR 1.4 and must form the basis of appropriate procedures and training requirements (see sections 3 and 6 of our guide).
  • The placarding and marking of containers, multiple element gas containers (MEGCs), tanks and vehicles in accordance with ADR 5.3.
  • The appropriate documentation as specified by ADR 5.4. Such documentation must be maintained at the appropriate location within the undertaking for reference and presentation to an inspector on request. Note transport documents and other information and documentation specified by ADR are to be held by both the consignor and carrier for a period of 3 months.
  • Loading, stowage, carriage and unloading of dangerous goods is in compliance with the best practice guidelines. It must be ensured that loads do not shift, fall or lead to a loss of containment or put at risk other road users (see the HSA website for further information on load securing).

Exemptions (see section 5 in our guide)

You should advise the undertaking on the proper application of any relevant exemptions, including clear written guidance in relation to the application of any such exemption.

Typically an undertaking may avail of exemptions related to:

  • the nature of the transport operation (ADR 1.1.3.1),
  • the carriage of gases (ADR 1.1.3.2),
  • the carriage of liquid fuels (ADR 1.1.3.3),
  • special provisions or dangerous goods packed in limited or excepted quantities (ADR Chapters 3.3 - 3.5),
  • empty uncleaned packaging (ADR 1.1.3.5),
  • small loads or packaged goods in limited quantities or excepted quantities.

National exemptions apply to the carriage of dangerous goods within the state only and are provided for in our national regulations (Part 8).

You should advise the undertaking on any applicable authorisations which may take the form of Competent Authority Exemptions, Approvals, Recognitions or Multilateral Agreements (MLAs).

Selection, purchasing and approval of vehicles

You may be required to advise on, review and monitor the procedures of the undertaking with respect to the selection and purchasing of vehicles meeting the requirements of ADR Part 9, or the provision and renewal of certificates of approval for vehicles. Certain vehicles (see ADR 9.1.2.1 - EX/II, EX/III, FL, AT and mobile explosives manufacturing units (MEMUs)) must be type approved and subject to initial inspection prior to service and thereafter annual inspections. For further information on vehicle certification and inspection requirements refer to the RSA web site. 

Safety Equipment and Transport Equipment (see sections 11 and 14 in our guide)

You must advise on, review and monitor procedures with respect to checking the safety equipment and transport equipment used in the carriage of dangerous goods by road.

All transport equipment must be subjected to regular general inspections and certain equipment requires testing, certification (type approval) and may be subject to periodic inspection in accordance with the requirements of ADR Parts 6 and 9. Equipment that requires certification includes packaging (including IBCs and large packagings), bulk containers, tanks and vehicles.

Under ADR Part 6, pressure receptacles and tanks require testing, certification and periodic inspection. Pressure receptacles and tanks for the carriage of class 2 gases and specific other dangerous goods are subject to the provisions of the Transportable Pressure Equipment Directive (TPED) and require conformity assessment and inspection by notified bodies. 

Training (see section 6 in our guide)

You must review and monitor the procedures for the provision of adequate training of personnel in accordance with ADR Chapter 1.3 and the retention and maintenance of appropriate training records. This includes general awareness training for staff involved in the consignment, packing, filling, loading, stowage, securing and unloading of dangerous goods, and function specific training, for example, creating transport documents, the securing of dangerous goods on vehicles by loaders/drivers, hazard awareness and safety training, and if applicable, security training (ADR 1.10.2). You must ensure that all training undertaken by staff is recorded, and that the undertaking is able to demonstrate maintenance of such training. You must also give advice and monitor requirements for driver training in accordance with ADR Chapter 8.2.

Emergency Procedures (see section 16 in our guide)

You must review and monitor the implementation of written emergency procedures in the event of an accident or incident during the carriage of dangerous goods by road, including loading and unloading operations.

Procedures should consider at a minimum:

  • incidents such as fires and explosions, road traffic accidents or loss of containment of dangerous goods;
  • foreseeable events such as breakdowns or a transport unit becoming immobilised for any reason;
  • how the requirements for supervising vehicles as detailed in ADR 8.4 are achieved and complied with, for example, it may be necessary to identify possible secure locations on a route where a vehicle may be safely parked overnight;
  • appropriate provision of equipment, services and training including vehicle and dangerous goods recovery at off site locations, emergency contacts for local authorities, recovery services (vehicles and chemical spill clean-up), environmental and remediation services.

Accident and incident investigation

You must review and monitor procedures for the investigation of accidents, incidents and infringements.

In the case of serious accidents or incidents (ADR 1.8.5), you must prepare a report according to the model in ADR 1.8.5.4.

You should request that the undertaking informs you of such an event in a timely fashion, to facilitate adequate investigation and the preparation of a report for the undertaking and if required, for submission to the regulatory authorities.

All accidents and incidents must be fully investigated and should conclude with recommendations to improve procedures, operational shortcomings or training requirements. It is the responsibility of the undertaking to take appropriate remedial action.

Prevention of accidents, incidents or serious infringements

You must review and monitor the implementation of written procedures and measures to avoid the recurrenc of accidents, incidents or serious infringements. Procedures must provide for the assessment of findings and recommendations following any incident and mechanisms to ensure remedial actions are implemented.

Where appropriate, you must review and monitor procedures required to ensure compliance with any special requirements of national and international legislation regarding the use of third parties or sub-contractors with respect to the carriage of dangerous goods by road.

You must review and monitor the undertaking’s mechanisms to ensure that personnel involved in the carriage, packing, filling, loading and unloading of dangerous goods are provided with detailed operating procedures (SOPs) and instructions to ensure compliance with ADR.

Where appropriate, you must review and monitor the preparation of the security plan in accordance with ADR 1.10.3.2 for dangerous goods designated as ‘high consequence dangerous goods’ (see section 15 in our guide).

Preparation of annual report

You must prepare an annual report on the activities of the undertaking. The annual report must record in reasonable detail all activities in respect of the carriage of dangerous goods during the period in question.

The annual report should achieve the following objectives:

  • Inform the management of the undertaking as to the extent of dangerous goods activities and standard of compliance achieved during the period.
  • Provide recommendations with respect to areas which need improvement or corrective action.
  • Facilitate inspection and investigation by the regulatory authorities in the performance of their statutory duties in an efficient and effective manner. Records of annual reports must be held by the undertaking for 5 years and be readily available for review by an inspector. Any supporting documentation must also be available.
  • Provide details of the activities of the DGSA.
  • Detail the activities of the undertaking in its role as a participant under the provisions of the ADR. An undertaking may fulfil the role of several participants during the reporting period, and also may share some participant obligations with another undertaking.

It is critical to capture all the relevant details in the report. Where an undertaking carries out spot checks, maintains checklists or carries out audits, the detail of these must be included in the report. It may be useful to use appendices for supporting data such as spreadsheets, tables or other required information. 

DGSA Annual Report Template

It is not mandatory to use this template but you may find it useful to ensure that you provide enough detail to achieve compliance.

  1. Company

Name:

Address:

Contact:                               Position: [Manager]

Phone Numbers:                 

email:                                    

Nature of Business:

 

  1. DGSA

Name: 

Date of Appointment:

Phone Number:

Certificate Number:

Mobile Number:

Expiry Date:

email:

Mode/Classes:

 

  1. Report

Period: Indicate period covered by the report

Copied to: List the Names and positions of all recipients

Additional Documentation: List associated documents/appendices

 

  1. Dangerous Goods

Give details of all dangerous goods activities in the last 12 months, including UN number, packing group, class and quantities. A spreadsheet as an appendix could be used and referenced here.

Highlight any exemptions used or third party contracts for carriage. Give details of sub-contractors used and confirmation of vetting with respect to ADR.

 

 

  1. Packaging Types

Provide details of packaging types used and confirmation of suitability (for example, UN approvals, certificates of conformity).

 

  1. Tanks/Tankers

Give details of the tank or tanker types managed or operated. Provide details of periodic inspections and leakproofness tests carried out over the last 12 months. Indicate expiry dates for all other tanks or tankers.  A suitable table could be used, see example below.

 

Ref No.

Tank Type and Tank Code

Expiry Date: periodic inspections

 

Expiry Date: Intermediate/ leakproofness tests

Comments

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  1. Fleet Details

Provide details of company vehicles used to transport dangerous goods.

Ref No.

Registration Number

Expiry Date:

DoE Test

Expiry Date:

ADR Vehicle Approval

Comments

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  1. Audits

Provide details of audits carried out. Indicate deficiencies and recommendations arising from these audits during the period of the report.

 

  1. Accidents

Provide details of accidents or incidents involving dangerous goods and, where relevant, incidents of the type mentioned in ADR 1.8.5 that occurred in the past 12 months.

 

  1. Training

Provide details of DGSA training (1.8.3), vehicle crew training (ADR 8.2), and training for others involved in the carriage of dangerous goods, according to ADR 1.3 (dangerous goods awareness, function specific and safety training) and security training in accordance with ADR 1.10.

 

  1. Security

Give details of activities carried out to meet the requirements of ADR 1.10 on security, including the preparation of “Security Plans” where relevant.

 

  1. Enforcement

Provide details of inspections/checks carried out by enforcement authorities and include details of all enforcement notices or fixed payment notices (FPNs), and identify any actions taken by the participants to address the non-compliance issues identified.

 

  1. Recommendations

List any recommendations

 

Signed:

 

Dated:

Provision of records for inspection

The provision and maintenance of adequate records is a core part of the management of the carriage of dangerous goods by road.

Any information captured in the annual report must be supported by relevant records, such as vocational training certification (DGSAs and drivers), audit records and completed inspection checklists and these records must be readily available for inspection by inspectors.

Where an undertaking operates multiple sites, records which are relevant to each specific site should be kept on location where possible, for example, site training records, audits and schedule of work identified by site audits. The annual report itself may be held centrally as it is primarily for the company management but elements of it or documents referenced by it which are specific to a particular site should be available to management and staff on any given site.

The above duties will require appropriate communication between you and the undertaking and may require significant resources. You or a trained appointee will likely be required to carry out spot checks, audits and review the various activities of the undertaking. It is the responsibility of the undertaking to address any matters requiring attention quickly and effectively.