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HAFFA DG Awareness Corner (Information including FAQs)

HAFFA DG Awareness Corner (Information including FAQs)

Updated: 05 Feb 2013

List of Effective CAD DG Advisory Circulars:

https://www.cad.gov.hk/english/DGAC.html (English) or https://www.cad.gov.hk/chinese/DGAC.html (Chinese)

List of CAD Dangerous Goods Awareness Training Circulars:

1.Dangerous Goods Advisory Circular (DGAC) – DGAC 5/2008

Applicability of Dangerous Goods Training Requirements to Staff of Vendors or Subcontractors of Freight Forwarders危險品培訓要求適用於貨運代理人供應商或分判商職員的範圍(English & Chinese)

2.Notice from the CAD Dangerous Goods Office – 17 October 2008

Dangerous Goods Training Requirement for Staff of Freight Forwarders貨運代理人員工的危險品培訓要求 (English & Chinese)

3.Notice from the CAD Dangerous Goods Office – 21 October 2008

2009-2010 ICAO Technical Instructions and 50th Edition IATA Dangerous Goods Regulations (2009)(English version only)

4.Dangerous Goods Advisory Circular (DGAC) – DGAC 3/2010

Training Requirement for Category 3, 4 and 5 Personnel of Freight Forwarders (English)

第3、4 及5 類貨運代理人(Freight Forwarders)員工之培訓要求 (Chinese)

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DG Training Requirement for Category 3, 4 and 5 Personnel of Freight Forwarders

Below are a few important points for Freight Forwarders (person working in the freight forwarding companies) to note and act accordingly:

A. Who should attend the training?

Category 3Personnel (C3P):

Personnel involved in processing DG, i.e. DIRECT checking of packaging, marking, labelling and documentation of DG.

Category 4 Personnel (C4P):

Personnel involved in processing general air cargo (OTHER THAN DG), i.e. DIRECT checking of packaging, marking, labelling and documentation (i.e. Master Airwaybill, House Airwaybill and Shipper’s declaration for DG) of cargo consignments.

Category 5 Personnel (C5P):

Personnel involved in actions other than processing, such as loading, transporting and storage of cargo consignments, which present the staff with an opportunity of having physical or close visual contact with the cargo consignments or perusal of their documentations.

Neither Category 4 nor Category 5 Personnel:

Forwarders’ staff with no opportunity to come into physical or close visual contact with cargo consignment is neither C4P nor C5P.

Forwarders’ staff with no opportunity to perusal of freight documents including Master Airwaybill, House Airwaybill and Shipper’s declaration for DG is neither C4P nor C5P.

Staff of the following departments LIKELY NOT BELONG TO C4P or C5P provided that they have NO ROLE to play which will make them coming into physical/visual contact with the cargo or perusal of the above documentations :

- I.T.

- Finance/Accounting

- Marketing

- Human Resources

- Office Administration

Subcontractors or Vendors with my company：

Freight forwarders thatstaff of freight forwarders’ vendors or subcontractors (e.g. trucking, logistics orwarehousing company), who perform a duty on behalf of the freight forwarderscommensurate with functions of Category 4 and 5 personnel, should also receivesimilar dangerous goods awareness training.

Staff of Vendors or Subcontractors belonging to the Category 4 Personnel:

i)Persons responsible for the checking of packaging, marking, labeling anddocumentation of export air cargo (other than dangerous goods)

Staff of Vendors or Subcontractors belonging to the Category 5 Personnel:

i)Checkers or drivers (if checkers are not used) responsible for delivering aircargo from the Shipper direct to the airline operator for acceptance

ii)Designated persons at the vendors’ or subcontractors’ warehouse, who areresponsible for checking every export air cargo shipment for hiddendangerous goods

iii)Designated persons who are responsible for supervising the build-up of unitload devices (ULD)

Sample Form of Deed of Indemnity (For Reference only):

To ensure compliance with the above requirements, it is advisable thatappropriate conditions be put into the contract between the freight forwardersand the vendors or subcontractors, to the effect that the latter will arrange theirCategory 4 and 5 personnel to receive such training(see DGAC 5/2008).

In addition, HAFFA has prepared a “Sample: Form of Deed of Indemnity” for HAFFA Members ONLY as a reference to consider signing with your Sub-contractor. It has been distributed via HAFFA Special Circular dated 15 Aug 2008 to all Members exclusively. Please check directly with your company who is assigned to receive HAFFA News. Members should read the Explanatory Notes and send to your subcontractor both CAD DGAC 5/2008 and Form of Deed of Indemnity if deemed appropriate. Please note HAFFA makes no recommendation for the adoption of the form or any part of it. Suitability and adequacy of the form or any part of it depend on individual circumstance and requirements. Before using any part of the form, Members are advised to seek your own professional legal advice with regard to the suitability. When concluding any new contract, Members may make suitable cross reference to this form of Deed. Alternatively, if considered appropriate, the relevant provisions can be set out in such contract.

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B. E

B.Effective date?

Category 3Personnel (C3P):

The effective date was 01 Nov 2006.

Category 4 Personnel (C4P):

The effective date is 01 Jul 2009.

Category 5 Personnel (C5P):

The effective date is 01 Jul 2009.

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C. What kind of DG / DGA training course should I take and where can I find the relevant enrolment information?course should I take and where can I find the relevant enrolment information?

Category 3Personnel (C3P):

Qualified Category 3 Personnel (C3P) should successfully completed the IATA Full DG training course, i.e. the current Basic DG 5-days or Refresher DG 3-days, and in this case, such personnel is NOT required to attend the DG training for Category 4 & 5 personnel (we called it DGA training).

Individual participant (HAFFA Members):

You may visit our website at https://www.haffa.com.hk/edu.htmlfor details.

Individual participant (NON-HAFFA Members):

Please visit the CAD's website at https://www.cad.gov.hk/english/DGAC.html and under the DGAC table, click the bullet point "Dangerous Goods Training Recognised as Fulfilling the Training Requirement for Shippers and Freight Forwarders" in order to get the contact information of the DG training providers.

In-house training:

HAFFA can help interested Members to contact training provider(s) for arrangement of establishing an in-house training programme, which requires a minimum of 15 participants per class.

Category 4 Personnel (C4P):

Qualified Category 4 Personnel (C4P) should successfully completed the DG Awareness (DGA) training course, i.e. the current 1-day IATA DG training for C4P and C5P or 1-day DG training for C4P and C5P which is recognized by HKCAD.

HAFFA has responded to Members’ need by establishing a DGA Self-Study Scheme (SSS) which includes “an Examination” or “a Tutorial to be followed by an examination” at a reasonable fee. DGA Self-Study Manual (English and Chinese) is also prepared by HAFFA for self-study purpose. This SSS is already approved by the HKCAD.

Individual participant (HAFFA Members):

You may visit our website at https://www.haffa.com.hk/portal/Course/Detail.aspx?id=56 for details of the DGA training courses or DGA SSS.

Individual participant (NON-HAFFA Members):

For HAFFA Self Study Scheme, please visit our website at https://www.haffa.com.hk/portal/Course/Detail.aspx?id=56 for details.

For 1-day DGA Classroom Training, since it is ONLY offered to HAFFA Members, non-HAFFA Members may visit the CAD's website at https://www.cad.gov.hk/english/DGAC.html and under the DGAC table, click the bullet point "Dangerous Goods Training Recognised as Fulfilling the Training Requirement for Shippers and Freight Forwarders" in order to get the contact information of the DG training providers.

In-house Classroom training:

HAFFA can help interested Members to contact training provider(s) for arrangement of establishing in-house training programme, which requires a minimum of 15 participants per class.

In-house Self Study Exam/Tutorial:

HAFFA can help interested Members/Non-Members to arrange for in-house self study exam/tutorial, which requires a minimum of 16 participants per class.

Category 5 Personnel (C5P):

Qualified Category 5 Personnel (C5P) should successfully completed the DG Awareness (DGA) training course, i.e. the current 1-day DG training for C4P and C5P or half-day DG training for C5P which is recognized by either IATA or HKCAD.

Individual participant (HAFFA Members):

You may visit our website at https://www.haffa.com.hk/portal/Course/Detail.aspx?id=56 for details of the DGA training courses or DGA SSS.

Individual participant (NON-HAFFA Members):

For HAFFA Self Study Scheme, please visit our website at https://www.haffa.com.hk/portal/Course/Detail.aspx?id=56 for details.

For 1-day/half-day DGA Classroom Training, since it is ONLY offered to HAFFA Members, non-HAFFA Members may visit the CAD's website at https://www.cad.gov.hk/english/DGAC.html and under the DGAC table, click the bullet point "Dangerous Goods Training Recognised as Fulfilling the Training Requirement for Shippers and Freight Forwarders" in order to get the contact information of the DG training providers.

In-house Classroom training:

HAFFA can help interested Members to contact training provider(s) for arrangement of establishing in-house training programme, which requires a minimum of 15 participants per class.

In-house Self Study Exam/Tutorial:

HAFFA can help interested Members/Non-Members to arrange for in-house self study exam/tutorial, which requires a minimum of 16 participants per class.

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D. How long should I take the DG training of refreshing nature (refresher course)? ***Updated on 30 Dec 2008***

Category 3Personnel (C3P):

Refresher course must be taken every 24 months from the date of last examination/training so as to keep DG knowledge up-to-date.

Starting in year 2009, there is a new provision for a 3-month “window” that allows for recurrent training conducted within the final 3 months of the 24-month period to be considered to have been completed on the expiry date of the 24-month period. E.g. a person who completed a course on 30 June 2007 needs to complete a revalidation by 30 June 2009. However, the revalidation may be taken between 1 April and 30 June 2009 for the revalidation to be considered to have been completed on 30 June 2009. The next revalidation date will then be 30 June 2011.

Category 4 Personnel (C4P):

Refresher course must be taken every 24 months from the date of last examination/training so as to keep DGA knowledge up-to-date.

Category 5 Personnel (C5P):

Refresher course must be taken every 24 months from the date of last examination/training so as to keep DGA knowledge up-to-date.

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E. As a freight forwarder, how many staff of my company will be

E. As a freight forwarder, how many staff of my company will be involved in the relevant DG training?

Category 3Personnel (C3P):

There is no requirement on the number of staff per company attending a C3P course, which is different from the current training requirement of being an IATA cargo agent or a HAFFA Member (i.e. 2 staff holding DG training certificates).

However under the CAD circular, C3P refers to the Personnel involved in processing DG, that means, it is not limited to 2 staff per company, if there are more than 2 staff involved in processing DG, all of themare required to take the IATA Full DG training course.

Category 4 Personnel (C4P):

There is no requirement on the number of staff per company attending a C4P course, however, under the CAD Circular, C4P refers to all the Personnel involved in processing general air cargo (OTHER THAN DG), i.e. DIRECT CHECKING of packaging, marking, labelling and documentation (i.e. Master Airwaybill, House Airwaybill and Shipper’s declaration for DG) of cargo consignments. (For Chinese details, read DGAC 1/2006)

1.Staff of the following departments ARE BELONG TO C4P provided that they are involving in DIRECT CHECKING of packaging, marking, labeling and documentation of cargo consignments:

a)Operations

b)Documentation

2.Staff of the following departments LIKELY BELONG TO C4P provided that they have A ROLE to play which will make them coming into physical/visual contact with the cargo or perusal of their documentations (i.e. Master Airwaybill, House Airwaybill and Shipper’s declaration for DG):

a)Sales:

For staff of Sales SOMETIMES having a need to come into visual contact with the cargo during meeting with their customers, CAD believed they need DGA training. When the Sales could see the cargo consignments, then he/she is having a chance to determine whether the consignments are having DG labels, DG marking and/or whether UN packaging has been used no matter whether they have been declared as DG or general cargo by the shipper (for example). But this determination could only be done when the Sales are DGA trained.

b)Customer Services:

For staff of Customer Services SOMETIMES having a need to peruse documents like Master Airwaybill, House Airwaybill and Shipper’s declaration for DG during their daily operations, CAD believed they need DGA training.

c)Management:

Same as “Sales” or “Customer Services” above.

Category 5 Personnel (C5P):

There is no requirement on the number of staff per company attending a C5P course, however, C5P refers to the Personnel involved in actions other than processing, such as loading, transporting and storage of cargo consignments, which present the staff with an opportunity of having physical or close visual contact with the cargo consignments or perusal of their documentations. (For Chinese details, read DGAC 1/2006)

Staff of the following job titles ARE BELONG TO C5P provided that they are involving in loading, transportation and storage of cargo consignments:

- Warehouse operators

- Drivers

- Delivery men

- Checkers

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F. How long should my company keep the relevant DG(A) training record? DG(A) training record? ***Updated on 30 Dec 2008***

Starting in year 2009, there is a new provision that a minimum period of 36 months following the last training date has now been specified for retention of dangerous goods training records.

To facilitate your training record keeping, HAFFA has prepared the Sample form of internal training records (Bilingual version) [Member Only] as a reference:

l To better monitor your internal progress of DGA training

l To better prepare your internal training records for possible inspection by the CAD

l You may consider modifying the format and content of the sample so as to accommodate your unique procedures of administration and operations

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G. In case we (freight forwarder) would like to organize the DGA training course by ourselves, how can we proceed?ed?

1.For any in-house training programme, you need to obtain an official approval from the CAD.

(Please refer to p.3-4 of the CAD DG Advisory noticeDGAC 1/2006).

Your application should include all of the following information:-

(i) Syllabus of training programme and course material used;

(ii) Background of training organization;

(iii) Training facilities and venue;

(iv) Qualification and experience of instructor;

(v) Training timetable; and

(vi) Examination arrangement.

2.Your DGA instructors must have adequate instructional skills and have successfully completed a dangerous goods training programme in the Category 6 of Table 1.5A of IATA DG Regulations. He/she must have delivered dangerous goods training programme/courses at least every 24 months, or in the absence of this obtained recurrent training certificate.

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H. How would CAD audit the training record and what is the penalty? what is the penalty?

All relevant training records or certificates shall be made available upon inspection carried out by authorized officers from the CAD.

Kindly note that freight forwarders who fail to comply with the new regulations (i.e. C3P, C4P and C5P to obtain the relevant training certificate before the above-mentioned implementation date) commit an offence and shall be liable to a fine of $25,000 and to imprisonment for 6 months.

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I. Enquiry

For any enquiry on the content of DGAC, please contact Safety Officers (Dangerous Goods) of the HKCAD at tel: 2182 1221 or 2182 1214.

For enquiry on the HAFFA DGA training courses, you may contact the HAFFA Secretariat at 2796 3121.