Background

Important Update on 23 Aug 2022

HAFFA Recommendations

CAD - Dangerous Goods Advisory Circulars

Important Update on 23 Aug 2022

• [IMPORTANT UPDATE] Dangerous Goods Advisory Circular DGAC 1/2022: Introduction to Competency-based Approach to Dangerous Goods Training and Assessment (CBTA) (for Employers)   on 23 Aug 2022
• [重要更新]危險品通告第1/2022號：能力為本危險品培訓及評核簡介(僱主適用)
• Effective date: 01 Jan 2023  |  生效日期：2023 年 1 月 1 日
• Updated version of Related Frequently Asked Questions  | 相關的常見問題之更新版本
• Highlighted content below would explain most of the issues 以下突出顯示的內容將解明大部分問題 

Further to News 29 dated 25 July 2022 regarding the collection of questions/views on the subject Advisory Circular, we have consolidated all questions/comments received from Members and sent to CAD accordingly. HAFFA held a virtual meeting with CAD DG office in early August 2022.  Through the meeting, CAD further answered the questions from HAFFA and per HAFFA request agreed that the FAQs of DG CBTA would be further reviewed and refined.  CAD also accepted our invitation to conduct a CBTA webinar and to give most updated requirements of the ICAO TI in year 2023-2024 to the freight logistics industry.  It is targeted to organize it around November 2022.  We will inform Members once the details are confirmed.

We are delighted to inform Members of the updated version of FAQs which our Members’ questions are being addressed and replied.  Please find below the highlighted content that explain clearly the issues.

Background:

Competency-based Training and Assessment (CBTA) for Transport of Dangerous Goods by Air, DG training requirements for employees of shippers, freight forwarders, aircraft operators, etc. have been completely revised from the current categorization approach to a competency-based approach, which have been given legal effect in laws and will become mandatory from 01 Jan 2023. 

CAD has recently published the DGAC 1/2022 to provide further information on the requirement and kindly find below the important key points from the DGAC 1/2022:

1. Employers shall ensure that DG training and assessment provided to employees meet this new requirement commencing from 1 Jan 2023.
2. As a transitional arrangement, training and assessment completed and certificates that are issued before 1 Jan 2023 with a validity period beyond 1 Jan 2023 will continue to be valid until they expire.
3. Employer must maintain all records of training and assessment for their employees whose job functions involve the transport of cargo by air. These include training needs analysis (see Attachment II), a summary of training and assessment records and the relevant training certificates as applicable (see Attachment III).
4. Training and assessment records must be retained by the employer for a minimum period of 36 months from the most recent training and assessment completion month and must be made available to the CAD upon request.
5. The requirement for personnel to undergo recurrent training and assessment within 24 months of previous training cycle remains unchanged under the CBTA framework.
6. Employers who do not establish and maintain their own DG training programme for their employees may seek outsourced training and assessment offered by third party training providers.
7. For the avoidance of doubt, if the role of an employee has changed such that previous training is no longer suitable for the new job functions and responsibilities, an initial training and assessment under the CBTA framework that commensurate with their new job functions and responsibilities have to be undertaken. 
8. It is recommended that before employers enrol their employees in a CAD-approved DG training programme, the compatibility of the training programme should be verified with the results of the training needs analysis of their employees. Such information can be found on the websites of the training providers, if any, or may be provided by the training providers upon enquiry.

• The CAD has produced a sample template to assist employers in formulating training needs analysis for their employees.

• The CAD has adapted an example of a training and assessment record under the CBTA framework with reference to ICAO’s list of well-defined roles.

Details of the DGAC 1/2022, Attachment I-III and FAQ can be downloaded from the following links:

Should there be any query regarding the subject circular, please contact the DG Office at 2910 6856 or 2910 6857.

HAFFA Recommendations:

Members (Employers) are kindly advised of the following:

1.  There will be NO MORE Categories of Personnel under IATA DGR Table 1.5A, i.e. NO MORE of Category 1 (Full DG), Category 3 (Full DG), Category 4 (DGA) and Category 5 (DGA) commencing from 1 Jan 2023.   All these categories will NOT be used anymore commencing 01 Jan 2023.

2. Instead, employers should do internal exercise by selecting the most appropriate role(s) for each of the employee based on:

(I)     table of task list (see p.2 of Attachment II for details)

(II)   FAQ Question 20 (see FAQs)

(III)  Example here:
(i)  Employee X (previously belonged to Category 3 personnel) may perform role (c).
(ii) Employee Y (previously belonged to Category 4 personnel) may perform role (b) and/or (d).
(iii) Employee Z (previously belonged to Category 5 personnel) may perform only role (d).

Below are the details of 4 roles (from role “a” to “d”):

Roles僱員角色

(a) Personnel responsible for preparation of DG consignments負責預備危險品貨物之員工

(b) Personnel responsible for processing or accepting goods presented as general cargo負責收運一般貨物之員工

(c) Personnel responsible for processing or accepting DG consignments負責收運危險品貨物之員工

(d) Personnel responsible for handling cargo in a warehouse and loading and unloading unit load devices負責在倉庫搬運貨物以及裝載和卸載集裝器之員工

3. It is highly recommended for you to select those CBTA training providers who have been approved by both the CAD and IATA.  Otherwise, if it is approved by CAD only, such certificate may not be accepted by the airlines of the destination; if it is approved by IATA only, such certificate may not be accepted by the CAD and the airlines of origin. Therefore, please pay attention to check the list of those approved CBTA training programmes under both CAD’s website and IATA's website from time to time.

4. It is noted the that the cost of applying IATA CBTA training programmes is more than the current IATA ATS (which will be NO longer existed in Year 2023), it is estimated that the training fee may be increased in general. 

Since certificates that are issued before 1 Jan 2023 with a validity period beyond 1 Jan 2023 will continue to be valid until they expire, Members are kindly recommended to arrange those staff whose certificates to be expired on or before 28 Feb 2023 to enroll the DG recurrent (3-day) training earlier in late Year 2022 accordingly (i.e. 3 months before the expiry of the certificates) or those staff who is planning to take DG initial (5-day) training to enroll the training under HAFFA earlier in late Year 2022.  If you are not sure, please take out your training certificate and give us a call asking when would be a right time to enroll, our colleague will help you to understand and mark your business diary so you don’t forget to enroll this year.

5. Please note HAFFA is still running the DG Initial and Recurrent Training until December 2022.

6. HAFFA will later coordinate with other approved CBTA Training Providers to offer various CBTA training courses to HAFFA Members.

7. On the other hand, there is no change to other HAFFA trainings such as DGA, DGA Exam, RAR, RACSF and VTP for Airfreight in year 2023, which we shall keep on running these courses.

8. In addition to better prepare for complying the new requirements in year 2023, Members are also encouraged to share the above information to all your shippers for their advance preparation.  

CAD - Dangerous Goods Advisory Circulars

• Advisory Circular DGAC 1/2022  ^{(6 Jun 2022)} 

• Advisory Circular DGAC 2/2022  ^{(6 Jun 2022)}
  

Application for Competency-based Dangerous Goods Training Programmes Approval (for Training Organizations or Employers Establishing Dangerous Goods Training Programme for Their Own Employees)
申請開辦能力為本危險品培訓課程 (培訓機構或為僱員自設危險品培訓課程的僱主適用

English Version: DGAC 2/2022, Attachment I, Attachment II and FAQ.

繁體中文版：危險品通告第2/2022號、附件 I (只有英文版)、附件 II (只有英文版) 和 常⾒問題

简体中文版：危险品通告第2/2022号、附件 I (只有英文版)、附件 II (只有英文版) 和 常⾒问题