Is certification for trainers on the horizon?

By Staff -- Logistics Management, 9/1/1998

The issue of training hazmat employees has become a "hot" topic worldwide. On June 3, 1996, the Council of the European Union (EU) approved Council Directive 96/35/EC, now referred to as the "DGSA Directive." The directive requires that all EU member states implement a common framework for the appointment and vocational qualification of Dangerous Goods Safety Advisors (DGSAs). The directive also makes it mandatory for every company that loads, unloads, or transports dangerous goods to employ a DGSA.

The common framework incorporates specific training curricula and requires an examination body within or approved by each competent authority to develop a written examination to test the DGSAs' qualifications. Only after successfully completing the recognized course of instruction and the written examination will the DGSAs be issued a Vocational Training Certificate (VTC), which will be recognized throughout the EU. The VTC includes a five-year validation with recurrent qualification requirements. Only those individuals in possession of a valid VTC will be permitted to practice their specialized trade throughout the European Community.

These provisions are scheduled to become effective Dec. 31, 1999. There may be some changes before then: Some EU member states are examining the need to extend the DGSA employment requirement to shippers that prepare dangerous goods for transport. Also under consideration are limits on the DGSAs' authority to oversee specific transportation modes or job functions based on the training and testing they complete.

You may want to read a bulletin on the subject of hazmat employee training, written by Alan Roberts, associate administrator of the Research and Special Programs Administration (RSPA), and published on the RSPA Homepage Hazmat Discussion for July 1998 (http://hazmat.gov/whatsnew.htm). In that bulletin, Roberts states that more than one-third of DOT's enforcement actions pertain to employers that fail to provide training or to maintain testing records. He cautions that "some hazmat employers rely on persons who hold themselves out to provide training without checking on their qualifications and references." He suggests that when employers encounter trainers' claims that they can provide "the quickest and lowest-priced training programs that include tests and certificates," they should check the credibility of those claims.

Roberts further cautions that employers need to know whether the training offered is general-awareness, function-specific, or safety training, and that they should determine whether or not the training topics meet their needs, based on the products they manufacture, sell, and/or distribute. He writes, "I strongly recommend you consider hazmat training as a critical element to the future of your business and not as something that management, including senior management, will look into during an enforcement proceeding or after an accident."

Check the Web and it becomes evident that there are indeed a growing number of self-ordained "experts" offering all kinds of training for which they guarantee "certification" upon completion, even when the training only takes a few hours to complete. (We've even heard of one training course that includes a "cocktail hour" for registrants!)

Historically, the U.S. DOT has been reluctant to implement a federally managed trainer-qualification system, but perhaps the time is ripe for a change of direction. In my opinion, those highly qualified trainers who deliver high-quality training through both in-house and public seminar programs would welcome a U.S. certification system similar to that currently under development in Europe.

John V. Currie's firm, Currie Associates Inc., provides hazardous-materials transportation safety and compliance audits, consulting services, customized training manuals, and public and in-house seminars. He may be contacted at 1118 Bay Road, Lake George, NY 12845. Phone: (518) 761-0668. Fax: (518) 792-7781. E-mail: currie@netheaven.com.