ChemRegs Newsletter – May 2020
Dangerous Goods Training during the COVID-19 Pandemic
The COVID-19 outbreak has led to difficulties in obtaining or providing training in the transport of dangerous goods for the various modes as a result of containment measures such as physical distancing practices and closure of workspaces.
In our March Newsletter we reported that ADR contracting parties had signed Multilateral Agreement M324 to allow ADR driver training certificates and DGSA certificates that are due to expire between 1 March 2020 and 1 November 2020 to remain valid until 30 November 2020. These certificates can be renewed for five years if refresher training is completed and the examination passed before 1 December 2020. The new period of validity shall begin with the original date of expiry of the document to be renewed.
Additionally, the UK Civil Aviation Authority (CAA) has granted ORS4 No.1379: Covid-19 – Extension of the Validity Period for Recurrent Dangerous Goods Training.
The dangerous goods by air regulations require that “recurrent training must be provided within 24 months of previous training to ensure knowledge is current.”
The UK CAA extension exempts UK Shippers, Operators and Agents from this requirement as long as the following conditions are met:
- the validity period of any recurrent dangerous goods training programme due to expire before 31 October 2020 may be extended to the end of the validity period of this exemption (currently 22 November 2020)
- this exemption is only to be relied upon when normal revalidation facilities are unavailable due to Covid-19 precautions;
- any UK shipper and agent thereof, any UK aircraft operator and any agent thereof, and any agent for a non-UK aircraft operator shall ensure that personnel are aware of their safety obligations and remain competent to perform their duties.
Note – This exemption does not apply to initial dangerous goods training, which must be carried out in accordance with Regulation 13 of the Air Navigation (Dangerous Goods) Regulation.
In considering these exemptions, it is important to keep in mind the objective of dangerous goods training, which is to ensure personnel are competent to perform their dangerous goods functions.
While physical distancing practices or closure of work spaces may make classroom training prohibitive, other means of training or combination of training methods can be used to achieve help maintain competence until the certificates can be renewed. This includes online courses, webinars, virtual classrooms, and in-house on-the-job training.
Other News
Hand sanitisers and surface disinfectants
The HSE has published new guidance for employers who are providing hand sanitiser in their workplaces, and for existing and new manufacturers of hand sanitisers and surface disinfectants.
The guidance has information on how the HSE regulates these biocidal products and includes:
15th ATP to CLP Adopted
The European Commission has adopted the 15th ATP to the CLP Regulation.
The harmonised classification and labelling of hazardous substances (contained in Annex VI of the CLP Regulation) is updated through an “Adaptation to Technical Progress (ATP)” adopted yearly by the Commission, following the opinion of the Committee for Risk Assessment (RAC). Other changes to CLP may also be implemented through an ATP.
The 15th ATP will amend Table 3 of Annex VI to the CLP Regulation, by introducing new and revised entries for the harmonised classification and labelling of 60 substances and by deleting 2 entries. It also amends Notes J to N, Note P and Note R in Part 1 of Annex VI.
Although this has been adopted it will now be subject to a two months objection period by the European Parliament and Council of Ministers, before publication in the Official Journal of the European Union. Once published, it will enter into force on the twentieth day following that of its publication.
For more information on anything in this Newsletter, please contact us at info@chemregs.co.uk