As Rob Symes states: “DGSAs are not chemists.” He is a chemist, as well as managing director of The Hazchem Network, the UK’s only ADR pallet network. With a background ranging across the chemical industry, Symes was also HSEQ director for chemical specialist 3PL HW Coates for many years, so has first-hand experience of what is needed for the safe storage and transport of hazardous substances.
“There’s a bit of a misconception that as soon as someone passes their DGSA course, they’re suddenly an expert on all things chemical,” he says. “That’s not the case – ADR is written specifically so people don’t have to be chemists.” That’s why ADR uses UN numbers rather than chemical names. “If there’s an emergency on the road, a driver ringing 999 can read out a four-digit number much more easily than an unpronounceable 30-letter chemical name.” (Those numbers were digitally removed in the image above.)
This is an important place to start, as is the type of operation the DGSA is looking after. From an active fleet management perspective, the main role a DGSA might have is in ensuring the correct fire extinguishers and other ADR equipment is fitted to new vehicles, and remains serviceable throughout its working life.
“If you go into tankers, or when you’re talking about explosives, then the DGSA would need to ensure the vehicle has the right specifications,” Symes says. “But from the point of view of maintenance and defects, that’s just the standard compliance of running vehicles, which would be more the transport manager’s role.”
Operators within The Hazchem Network all need their own DGSA, but how they choose to meet that requirement varies from business to business. Some will use an external consultant, where others might train an existing member of staff who can then combine the role with their existing responsibilities.
A good example of the latter approach can be found at Hazchem Network founder member, Lancashire operator Bowker Group. Having started his career as a junior transport planner, Keith Baron moved on to become transport manager at Bowker’s head office, before specialising in health and safety. Today, he has the dual role of health and safety manager and DGSA, having also qualified as an ADR driver along the way.
HYBRID ROLE
“Direct DGSA responsibilities take up approximately 15% of my time,” Baron states. “In that role, I help ensure our customers’ compliance, which involves overseeing paperwork to ensure it is correct, and verify the compliance of ADR vehicles and driver personal protective equipment.” Additionally, following legislative changes, Baron also provides external DGSA consultancy to Bowker’s chemical customers. This includes conducting the required annual audits and preparing the all-important DGSA’s annual report.
As an internal DGSA, Baron has a direct influence on the maintenance of equipment, scheduled inspections and additional safety checks. “I work closely with the group fleet engineer and driver trainers to ensure that the equipment is compliant for the transportation of ADR materials,” he says, “and that all necessary safety checks are kept up to date.”
But his reach goes far further into the operation than just those responsibilities. He reports directly to director Bill Bowker, compiling monthly reports and providing insights and recommendations based on their contents. “I’m responsible both for the advice I provide, and whether it is followed,” he says.
Because Baron also manages Bowker’s health and safety, he is able to use all his relevant knowledge to shape procedure where the safe handling and transportation of hazardous materials is concerned; for example, the company now requires two straps to be used when securing IBC containers. This means continuous professional development is a must. “I am an active member of professional organisations such as the British Association of Dangerous Goods Professionals, and the Chemical Business Association’s logistics committee,” Baron adds. “I’m also part of the CBA’s dangerous goods forum, where I collaborate with like-minded professionals to share best practices and stay informed about regulatory changes.”
EXTERNAL EXPERT
For DGSA consultant Dave Wood, the job is very different. He currently looks after 50 clients on a consultancy basis, as well as teaching ADR courses. DGSA work takes up over 70% of his time. “The way I do it, clients pay me up front for the year, which entitles them to ask as many questions as they like,” Wood says. “The company’s mandatory DGSA report is also included in that fee.” This is a fairly standard way of operating.
“DGSAs have three main responsibilities: monitoring, advising and preparation of an annual report,” Wood explains. “The regulations don’t specify what ‘monitoring and advising’ involves, and in a practical sense it’s quite difficult to do,” he says. “You could, for instance, have a policy of ringing up all your clients every month, but that becomes quite wasteful of time trying to get hold of people. I tend to throw the responsibility back on to the customer by telling them they have access to me by phone or email whenever they need advice or explanations.”
When it comes to legal liability around advice, DGSAs are not open to prosecution, nor are they answerable to the traffic commissioners in the same way as transport managers. “If my advice is incorrect, my client may have a claim against me under civil law, so I have my own public indemnity and public liability insurance,” Wood says. “Often, however, the advice is only as good as the questions asked and facts supplied. A lot of the answers I give start with ‘From the information you have given me…’, or I reply with a question aimed at clarifying the customer’s request.”
Wood’s clients range from one man with a van up to far bigger operations with multiple heavy vehicles. But whatever happens, he can only advise clients what to do – he can’t make them do it. The same goes for preventive maintenance inspection regimes. “My role is to tell them what’s needed; if they choose not to do it, that’s their problem, not mine,” Wood says. “That’s how ADR is written.”
That last bit is key when it comes to understanding this subject: ADR is designed to be very simple.
“For example, when it comes to things like buying vehicles, you can’t just put any chemical in any tanker,” Wood points out. “Each chemical product requires a certain type of tanker as specified in ADR.” That means that you can’t put propane in a petrol tanker. “That one’s obvious, but it’s still specified, as is the fact that, for carriage in packages, you can’t put petrol directly in cardboard boxes! It really is that basic. The sheer number of packaging and tank codes for the various products are one of the reasons why the books are so thick!”
In other words, in its purest form, as practised by most external consultants like Wood, the DGSA role is not to know the answer to every question, but more to know where to find the answer.
If a company wished to start transporting a particular chemical, it would ask its DGSA what special measures need to be taken, and the DGSA would know where to access that information to pass it on. It would then be up to the company to follow that advice.