Govindarajan Bashyam, chief operating officer of Tirwin Management Services (P) Ltd., an India based dangerous goods management, training and consulting firm.
The regulations from its days of Restricted Articles Regulations (RAR) to today’s Dangerous Goods Regulations (DGR), have fine-tuned themselves and matured through adopting various changes considering the changing needs and the types of goods that need to be transported.
However, frequently reported lithium batteries incidents or the recent explosion of ammonium nitrate in Beirut or a fire and explosion of X-press Pearl container ship near Colombo, due to leakage of nitric acid, and other reported dangerous goods incidents around the world make one to wonder whether the established regulatory framework for carriage of dangerous goods has served its purpose.
Many believe that compliance is just the implementation of the print in the regulations to avoid penalties. Some feel and believe that until such time the authorities knock on the doors, there is nothing to worry about and even if they do, there are alternate ways to overcome the challenge.
Compliance is not to satisfy someone; rather it helps to protect our lives, community, assets, and our earth. Commitment to compliance is not an inhibitor but a culture that needs to be planted, raised, cherished, and passed on to the next generation.
For such a culture development, the cost of compliance must be a fraction of the cost of noncompliance. The reality is otherwise. While the service providers believe in surcharging for every service related to carriage of dangerous goods, the authorities rely on astronomical figures as penalties. Both do no good except enhancing the risk-taking ability of the end-users and encouraging them to cut the corners.
If someone in the industry is asked – ‘why should an organisation train its employees?’ the instant answer invariably could be – otherwise, authorities would levy heavy fines. When the need for dangerous goods regulations training is viewed as a necessity only to avoid penalties for noncompliance, then the training becomes more of a ritual and the efficacy of the training takes the back seat. Even some training organisations as part of their marketing strategy justify their price by comparing with penalties for not training the employees.
The International Civil Aviation Organisation (ICAO) is scheduled to implement a Competency-Based Approach to Dangerous Goods Training and Assessment (CBTA) effective 2023. ICAO believes that the new approach would target specific training needs and pave the way for continuous learning and performance improvement. The focus is on gearing the entire training towards learning through integration of Knowledge, Skills, and Attitudes (KSA).
The intent of the new approach is to replace the current understanding of passing a test to gain a certificate with performance-oriented training wherein apart from the knowledge and skills, the attitudes would play a lead role. Attitude is the basis for developing a healthy compliance culture. Hopefully, this initiative is a game changer in developing compliance culture.