Radharamanan Panicker, the Managing Partner of Dangerous Goods Management India, discusses key considerations when transporting dangerous goods as a forwarder, ground handler, or airline. He describes how as a full-service provider in hazardous material transportation, their expertise and experience in handling hazardous materials in real-world situations allows them to bring practical reality to the training.
How critical is complete knowledge of dangerous goods when transporting them by air?
Dangerous goods are substances or articles that pose a hazard to health, safety, property, or the environment and are listed on the ICAO TI and IATA DGR lists of dangerous goods. A UN expert committee has classified the entire universe of dangerous goods into nine hazard classes, with each hazard class exhibiting different hazards during transportation.
Most dangerous goods, like other cargo, are mostly transported on passenger aircraft, which increases the risk when transporting such goods because passenger safety is at stake. Furthermore, due to the inherent characteristics of air travel, air transport is particularly vulnerable to any hazard manifesting during flight, as the aircraft is flying at more than 30,000 feet, where the temperature is nearly (-) 50 degrees Celsius.
An accident while transporting dangerous goods can have catastrophic consequences. Though laws and recommendations for the transport of dangerous goods have been in place for a long time, their effectiveness is dependent on those involved in their transport adhering to these recommendations and guidelines in order to avoid unnecessary risk. It has been established that, despite the risk, dangerous goods can be transported safely if they are correctly identified and classified, packaged, marked and labelled appropriately, and documented.
It means that people can identify the risk associated with the type of hazard being handled and dealt with, thereby avoiding accidental mishandling. All of this is possible if everyone involved in the transport of dangerous goods is well-versed with the regulation’s requirements and follow them correctly. This is only possible if they are rigorously trained in accordance with their responsibilities.
What are the most important factors to consider when transporting dangerous goods as a forwarder, ground handler, or airline?
Dangerous goods become dangerous when they are released from their containment system, i.e., packaging. It’s like a bad genie escaping from a bottle. It is capable of wreaking havoc. The same is true for dangerous goods. Good, proper, and certified packaging is essential for the safe transportation of dangerous goods.
Most dangerous goods transported by air require what is known as a combination package (i.e., at least two layers of packaging; each layer has a limit on the quantity allowed per package, which must be adhered to). The shipper must follow the requirements of the combination package. Forwarders now train two or three employees in CAT 3 training. However, they must also train other operations personnel in CAT4/5.
Ground handlers and airline personnel are not responsible or authorised to classify or identify dangerous goods. As a result, they must refrain from advising shippers and forwarders on these matters. They must accept the DG shipment using the standard checklist, and if they discover any errors in compliance on the part of the shipper/forwarder, they must reject the shipment with proper justification.
Is there any training or certification required to transport hazardous materials? Are there a sufficient number of teaching institutes in India to provide a comprehensive knowledge base on dangerous goods?
To begin with, all shippers who need to ship dangerous goods must be trained in CAT1 of the Dangerous Goods Regulation, which includes identification, classification, packaging, marking, labelling, and documentation. When I say shippers, I mean all those in an organisation who are in charge of managing the transport of dangerous goods. Is this a sufficient requirement? Unlike in Europe or the United States, India currently does not have a requirement for a safety advisor.
As a result, obtaining a DGR training certificate for CAT1 is considered to be the equivalent of obtaining a full specialisation or certification. However, shippers must do more. Classification and identification of non-listed (in the Regulation’s list of Dangerous Goods) DG substances, for example, is a thorough exercise that includes testing the material, collecting data, comparing it to the classification criteria, and then classifying the product in terms of primary and secondary hazards, if any. Then comes the identification process, which includes providing a proper shipping name and UN number.
There are more than 13 institutes in India that have been approved by the Director General of Civil Aviation (DGCA) to provide regulation training. This is a good figure.
What role does your organisation play in providing knowledge about dangerous goods and their transportation?
My company, Dangerous Goods Management India Private Limited, has established a training division called DGM India Academy of Logistics. This academy was founded and approved by the DGCA in 2006, and it is also an IATA authorised training facility. As a full-service provider in dangerous goods transportation, our current expertise and experience in handling dangerous goods in real-world situations enable us to bring practical reality to the training. Year after year, we update our training manual and incorporate new elements into the training methodology to keep training interesting—a drab subject otherwise.
We installed a Learning Management System this year, through which we will provide regular updates and knowledge upgrades to our students, connecting them throughout their entire learning cycle. The system is being developed, and we hope to have it ready for deployment by December 22.
We signed an MOU with ACAAI last year to train their members. As a result, we began DG training in Delhi, Ahmedabad, and Kolkata, though Mumbai remains our main base.
We trained over 2,500 students until September 2022, covering 150 initial batches and 75 recurring batches of the larger categories of 1/3/6, which are six or three-day courses. Aside from that, we have trained over 2,500 people in the cargo and ground handling sectors over the course of one or two days. Training is a serious business for us at DGM.
Dangerous Goods Management is now involved in the air and ocean freight forwarding of dangerous goods cargo, as well as compliance services such as packing, marking, labelling, and documentation work. We have a Euro15 million international risk insurance cover for this compliance work. We also offer clients consulting and auditing services in the area of dangerous goods regulation and management.
What do you expect from the government in terms of smoothing the process of transporting dangerous goods?
The following are the expectations from the government.
- Get the chemical code implemented as soon as possible so that the shipper will be forced to classify their products and identify them correctly with the correct safety data sheet.
- Create an inter-ministerial task force that can deal with a common aspect of dangerous goods transportation across different modes of transport, such as packaging and package testing. Today we have IIP providing dangerous goods packaging certificates for different modes of transport, as if the requirements are different. Package testing is the same for all modes of transport, though different modes may have different types of packing requirements. It is hilarious to note that IIP certificates contain words like “Only for air mode” or “Only for ocean mode”, whereas abroad the testing certificate is issued without any such words. Also, their certificates show the UN number of dangerous goods that can be carried in that tested package. This number is given by the shipper. This is again ridiculous as the testing is not done for any particular UN number. It is generic testing for leakage, stacking, hydraulic pressure, and dropping.
- In the case of training for air cargo, with the training regime kicking in from January 1, 2023, the government must clearly specify what the training needs are for each participant and make it clear that external guidelines will not override the Indian requirement. They must also establish the training guidelines for DG instructors, which must be Indian. Today we have to spend an unnecessarily high amount to get our instructors trained through IATA when better and cost-effective options are available, such as the Train the Trainer program of MEPSC under the National Skill Development Corporation or the government’s own Personal Department training in instructional design and such training.
