It's all about the 'right' training for DG handling
Dangerous goods (DG) are known as a threat to the aviation industry if they are not packed and handled correctly. This report talks about the new CBTA procedure, the causes of DG incidents, and possible solutions.
More than 1.25 million dangerous goods shipments are delivered by air each year. With the volume of air cargo expected to increase, so will the quantity of dangerous goods shipments, notably those carrying lithium batteries.
Consumer desire for electronic gadgets like tablets and tiny personal mobility devices like e-bikes is a major driver of this rise. As a result, there are new market entrants, which necessitates training, process improvement, and the deployment of new technology to handle dangerous goods.
Growth brings many new shippers into air cargo supply chains, which creates new risk. Incidents of undeclared or mis-declared cargo are rapidly becoming a serious danger.
In June this year, International Air Transport Association (IATA) encouraged the government to assist enhance the safe transport of lithium batteries by developing and adopting worldwide standards for screening, fire testing, and incident information sharing. IATA has made a number of significant adjustments and amendments to the IATA Dangerous Goods Regulations (DGR) handbook in its 64th edition. Compliance with this new version becomes mandatory on January 1, 2023. Aside from addressing the IATA modifications, the 64th version of the DGR manual also covers all amendments made in the ICAO Technical Instructions (edition 2023-24).
"CBTA is a blend of classroom instruction aimed directly at the individual's function vs assessing them while they're on the job physically executing their job and handling dangerous goods consignments"
James Wyatt, General Manager, aeroconcept
This report discusses why there is a need for Competency-Based Training and Assessment (CBTA) to handle dangerous items, solutions for reducing incidents when handling dangerous goods, and the need for the right product packaging.
Dangerous goods regulations awareness = Less mishaps
As with many products shipped by air, effective standards, globally implemented, are needed to ensure safety. The challenge now is the rapid increase in the global demand of lithium batteries. The DG market is expanding at a rate of 30% each year.
Training is an important component in helping to prevent occurrences, and laws must be explicit. The individuals who are trained, must be updated with the regulations as it changes every year. Training is not only a one-time event followed by recurrent training every 20 to 24 months but it must be maintained up to date with regulatory changes on a constant basis.
"The industry will move to competency-based training and assessment beginning next year and I believe that more individuals will be aware of the dangerous use regulations. As an alternative to traditional training, competency-based training focuses on the training requirements of individuals depending on their role. The individual will be taught to be able to do their role rather than simply having information. If shippers are taught and qualified to fulfill their tasks such as packaging and marking laboring paperwork, the industry will be able to avoid incidents," Eric Tan, Manager, Training and Development, HazPak, has 20 years of experience in the aviation industry and joined HazPak (a dangerous goods packing company) in November 2021 to set up dangerous goods training academy where he obtained the IATA CBTA Accreditation to conduct Dangerous Goods CBTA Training.
The purpose of CBTA is to provide specialised training for a skilled workforce. It is a methodical approach based on three principles like identifying the core abilities and skills to be attained; determining the most effective method of acquiring these competencies; and developing methods for valid and accurate assessment measurement.
"It's all about safety and compliance. We must concentrate on informing the general public and new businesses about the criteria for shipping dangerous goods by air, even if the air cargo sector is quite proactive and pushes numerous safety programmes. In my opinion, governments, state authorities, and the Civil Aviation Authorities all need to improve their assessment and understanding in these areas. If it is discovered that a consignment was not correctly declared for air transport and the investigation concludes that it was due to the shipper not properly preparing, classifying, and presenting the shipment for air transport, they should be prosecuted by the authority because this, in my opinion, is gross negligence that is linked to flight safety," said James Wyatt, General Manager, aeroconcept. Wyatt was the IATA's head of dangerous goods products in 2016 and managed the regulatory publications, both digital and print.
"We don't believe that anybody would consciously or deliberately mis-declare DGR goods, but shipper ignorance of the correct procedures and packaging cannot be totally ruled out, especially with the recent growth of eCommerce"
Wilson Kwong, Chief Executive, Hactl
"If I want to transport a lithium battery, for example, I can quickly register an account online and have a courier come to pick up my item the next day. Am I really aware of the regulations? This is challenging. However, even when firms register accounts, there are now specific controls in place that require them to demonstrate a particular degree of competence and sign statements, so some awareness there. But, overall, I believe that governments and regulatory authorities must be further embedded in the process," added Wyatt.
Hong Kong Air Cargo Terminals Limited (Hactl) has become the first cargo terminal operator in Hong Kong to achieve IATA's new CBTA Center Certification.
Following an agreement by the ICAO Dangerous Goods Panel in September 2019, IATA Dangerous Goods training has been evolving from traditional learning to the new, skills-based competency-based training and assessment format.
"Recognising the importance of proper staff training for air cargo handling, Hactl has been performing its own training in-house since 1976. DGR is a particularly important aspect of our work, and our high-quality DGR training, established for many years, resulted in us being appointed as an IATA Accredited Training School (ATS) in 2013 - offering training both for our own staff and those of third parties including airlines, freight forwarders, industry organisations and educational institutions. Hactl operates a separate dedicated zone for DGR traffic, which now includes lithium battery shipments, of course. This zone is staffed by personnel with specialist training in handling such goods, who are fully-qualified to check DGR shipments and their packaging. In the event of any non-compliance whatsoever, cargo is automatically rejected at the reception stage," Wilson Kwong, Chief Executive, Hactl.
Is lack of training the cause for DG accidents?
According to FAA records, at least 375 incidents of smoke, heat, fire, or explosion involving lithium batteries in aviation cargo or hold luggage were reported between January 2006 and April 1, this year.
In September, IATA, Labelmaster (a software, products, and services that assist customers in remaining compliant with all dangerous goods rules, mitigating risk, and maintaining seamless, safe operations) announced the results of their seventh annual 2022 Global Dangerous Goods Confidence Outlook. The survey results emphasised the need for improved process consistency, increased automation, and more accurate data to support the safe and secure transportation of DG.
"Global supply chain disruptions have put even more pressure on those professionals and companies responsible for shipping goods safely and compliantly. While there are many areas of improvement over the last year, the survey demonstrated widespread awareness of the need to improve DG processes, training, technology and infrastructure," said Robert Finn, Vice President, Labelmaster in the announcement.
What is the most common reason for dangerous goods mishandling? Is it a lack of training or attention since it is not a fun element of the training process?
"I wouldn't say that a lack of training is the cause of accidents; rather, it is a lack of the 'right' training, because typical training focuses on learning and categorises individuals. Then they train these individuals in accordance with the requirements. As a result, their training is not always function-specific. And, in most cases, we can tell that the instruction is widespread. So, after the training, the personnel are really pushed into the world, into the operations. Yes, there isn't time for this person to practise and establish his ability to execute the job before being assigned to it. So, as I usually say, the problem isn't so much a lack of training as it is a lack of the right training to train the individual to execute the role," said Tan.
The risk increases in direct proportion to the number of shippers entering the air freight supply chain. Undeclared cargo mishaps are rapidly becoming a major concern. When exporting them, there are other processes and packing standards to follow. However, such action may be costly, and several exporters mislabeled or concealed batteries to avoid the requirements.
The most prevalent causes of DGR events include chemical spills caused by improper handling or packaging, as well as fires in lithium battery shipments. The former is highly dangerous, but they are also easily discovered and dealt with prior to aircraft loading. Batteries are safe if delivered uncharged; nevertheless, batteries that are charged (which is the majority) may overheat if collided with. This can result in an extremely hot fire that spreads fast to other batteries in the shipment and constitutes a considerable risk if taken inside an aircraft.
"We don't believe that anybody would consciously or deliberately mis-declare DGR goods, now that the risks and consequences are so well known. But shipper ignorance of the correct procedures and packaging cannot be totally ruled out, especially with the recent growth of eCommerce and the number of new traders involved in this business, many of whom sell products with batteries, or ship batteries in bulk. For that reason, Hactl has proactively taken training and guidance in correct practice to agents and shippers, to better prepare them and to avoid potential problems. Prevention is always better than a cure. As a result of its stringent procedures, Hactl has not suffered any accidents with lithium batteries to date.The key as always is absolute compliance with IATA DGR regulations, the new CEIV li-batt certification, and IATA Lithium Battery Shipping Regulations (LBSR). Any agent, shipper or handler who complies with these standards and practices is ensuring total safety in the battery supply chain," said Kwong.
DG packaging standards are unique
The right packaging of a dangerous commodity is essential to aviation safety. If you choose poor packing, you might seriously injure a transportation worker, harm the environment, or cause catastrophic damage to an aircraft.
The most suitable hazard categorization of a product and its physical qualities are used to determine the proper dangerous goods packaging. Corrosive materials, for example, cannot be shipped in metal shipments because they aggressively react with metal and eventually damage the box.
"It's all about raising awareness. Making people aware of what neglect is and the consequences it might have. And, once again, the follow-up and regulatory enforcement, for example, if a governmental entity issues a stringent fine, then that corporation is less likely to take any shortcuts in the future. As soon as that happens, people in that country become acutely aware of the dangers, the possible fines, and everything else on the horizon. And clearly, this is something that brings attention to the situation, which in turn makes them compliant. That's where the industry has to be," said Wyatt.
Packaging standards differ according to the kind, class, and amount of dangerous items being sent. Packaging is frequently examined and certified to fulfil the criteria of regulations for dangerous goods shipping by air.
"I wouldn't say that a lack of training is the cause of accidents; rather, it is a lack of the 'right' training, because typical training focuses on learning and categorises individuals"
Eric Tan, Manager, Training and Development, HazPak
"Shippers and freight forwarders should always check that their DGR shipments and accompanying documents comply with the IATA Dangerous Good Regulation requirements, which are the definitive standard. Any handler has the right in law to deny carriage of improperly-packaged or incorrectly-documented goods and to force the shipper to take them back and re-pack them. In addition to correct individual shipment packing, fire retardant pallet covers are now considered best practice but are not yet mandated," said Kwong.
Benefits of the Competency-Based Training and Assessment
The volume of shipments is growing as a result of eCommerce, and the commodity driving eCommerce in general is lithium batteries. Lithium batteries have always been a trending topic, and this is where smaller eCommerce businesses tend to send that sort of item.
"The new Competency Based Training and Assessment concept which comes into effect on January 1, 2023 places a strong emphasis on the individual's function. If I'm preparing a dangerous goods consignment, loading cargo and baggage onto an aircraft, or checking in passengers for a flight, the training that the person receives is now directly targeted at the function that they perform.
From the instructor's standpoint, classroom training will require a better understanding of the individual's total competency in order to deliver a report back to the employer. When returning to the company where the trainee works, the employer has a complete overview of how capable the employee is. Just because I passed my classroom exam with a perfect score does not indicate I'm competent; proficiency is judged on the job," said Wyatt.
"This provides a higher level of detail and quality for the individual, as well as that level of transparency for the employer, as they are able to see that their operational team is competent. It's a much deeper, overall transparent view on each individual to be able to say, are they really competent in performing a certain function at all times? So it's a blend of classroom instruction aimed directly at the individual's function vs assessing them while they're on the job physically executing their job and handling dangerous goods consignments," Wyatt added.
Dangerous goods are frequently transported by air all around the world. To protect the safety of the aircraft and its passengers, all required safety precautions must be taken with dangerous commodities. The number of accidents should reduce once the CBTA system is implemented in January 2023, since employees and shippers will have a better understanding of dangerous goods training.