MY TAKE ON THE COMPLIANCE BLITZ
24% non-compliance rate for road transportation of dangerous goods resulting from compliance enforcement blitz.
I read with great concern the results of the compliance blitz that resulted from over 9,200 inspections in Canada, the United States and Mexico. The North-American wide blitz covered ground transportation of dangerous goods shipments from August 12th through August 16th. Inspectors identified 683 out of service conditions. A total of 15,197 packages containing dangerous goods were inspected resulting in 181 violations of which 66 were for leaking containers. To my disappointment 204 violations were noted for improper loading and securement. A total of 1,156 shipping documents violations were recorded. 171 were marking violations and 432 were for placarding violations. An astonishing total of 2,200 violations were recorded, which is 23.86% of shipments inspected. Regulations have been in place in Canada since 1985 with a requirement for all persons involved in the handling, offering for transport and transportation of dangerous goods to be properly (i.e. competently) trained. So if everyone is supposed to be properly and competently trained there would be no violations of shipping documents, all loads would be properly secured marked and labeled. Although somewhat complex due to quantity thresholds, placarding violations shouldn’t exist when the shipper and the driver are properly and competently trained. So what is going on here?
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”. Once the Standard is finalized and published, Transport Canada will propose an amendment to Part 6 of the Transportation of Dangerous Goods Regulations, which would allow the Standard to be incorporated by reference. Industry is pushing back on the prescriptive elements of the training standard, which includes a minimum number of training hours, written test and the development of benchmarks to determine competencies. Although I personally do not favor these prescriptive standards, I’m struggling with justifying my position in the face of the compliance enforcement blitz results. The vast majority of the violations should and could have been avoided with adequate training to ensure that those persons involved in the dangerous goods shipping cycle are competently trained. After all is said and done, we the public travelling on the roads and more importantly the first responders are entirely reliant on the competently trained persons to ensure the safe transportation of dangerous goods by all modes of transport. The regulations were put in place to ensure that an effective communication system is in place to protect first responders by use of classification, marking, placarding, shipping documents and emergency response. The communication system is failing!
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