The Canadian General Standard Board (CGSB) has released the first draft of the new National Standard of Canada CAN/CGSB-192.3 entitled “Transportation of Dangerous Goods Training, Assessment and Competency”.
CARS was included in the addressees of the advance copy of this consultation, asking to provide feedback on the proposed new standards within the 60 day Public Review Period. Following-up on this request, CARS sent out the proposed text of the new standard to its members asking them for feedback, so that a consolidated response could be sent to Transport Canada.
In order to meet the deadline for the submissions, CARS requested members to send their responses to the head office by 30 September 2019, to allow collation and consolidation of the responses to Transport Canada. It is interesting to note that the new standard proposes a more detailed direction for Part 6 of the Transportation of Dangerous Goods Regulations with respect to dangerous goods training. The long standing criticism of the existing text in Part 6 of the TDGR pertained to the training and qualification - citing ambiguity rather than clear guidance to employers and employees on this very important aspect of training. Such directions as "...
Training Certificate Requirements - (1) A person who handles, offers for transport or transports dangerous goods must (a) be adequately trained..." left a significant number of possibilities for the interpretation of "adequate training". By comparison, the International Civil Aviation Organization (ICAO) and the International Air Transportation Association (IATA) have had function specific definitions of what training was required by personnel filling those functions.
It is hoped that by providing constructive comments, the ambiguity of the current TDGR, Part 6 text could be meaningfully amended and defined to add much needed clarity to the national training standard, assessment and competency in training of personnel employed in the functional role of handling, offering for transportation and transporting dangerous goods .