Synopsis of 2021 Change Document by Transportation Development Group LLC Transportation Development Group has attached a comprehensive list from IATA on the changes to their 2021 collection of airline industry rules called The DGR. While IATA has no legal authority to regulate anything, their trade group incorporates all the ICAO Dangerous Goods Technical Instructions in the IATA DGR. Since the ICAO rules are legally binding in most places, the IATA rules do allow you to comply with airline guidelines and the legal requirements of the competent authority and ICAO.
So whats notable for freight forwarders and logistics companies in 2021? Lets take a look at some of the more notable changes.
1.5Training Requirements. Subsection 1.5 as shown in Appendix I in the 61st edition has been adopted to implement a competency-based approach to dangerous goods training and assessment. Subsection 1.5 from the 61st edition has been moved to Attachment A of Appendix H as there is a 2-year transition period until 31 December 2022, during which time the training provisions from the 61st edition may continue to be used.
Note to WCA members, this is a much longer discussion than can be covered here. The gist of CBTA (Competency-Based Training and Assessment) is this: in the past, the major focus on training has been on the delivery (video-training, classroom, online, etc) and length of training but not as much on the immediate results and the post-training results. So you could send your employees to a 2 day seminar and have them pass a perfunctory test, but does that allow you, as the employer, to deem them fully competent for their job-function?
Furthermore, maybe at the end of a two-day class they can pass an exam but these key elements are often overlooked:
These are considerations under the new CBTA scheme that employers must consider. Its not JUST about passing an exam, its about the employer knowing, for certain, that the employee (after training) is fully competent in their job function.
- Does the exam that the employee passed accurately and totally reflect the employees DG job function?
- A month after they pass the test and theyre working on the job day-to-day, are they still competent? Were they ever competent for their job function?
IATA is changing their Table 1.5 which has been a table of industry job-functions for decades. It will be much more involved. We will provide MORE detail on this to WCA members as the end of the year approaches. There will be a phase-in period in 2021 with mandatory adoption in 2022.
But how mandatory this is depends upon the country in which you operate. In the United States for example, it wont be much of a change immediately.
1.7Dangerous Goods Security. New entries have been added to the indicative list of high consequence dangerous goods shown in Table 1.7.A. If you are a freight forwarder handling High-Consequence DG you need to know about this as there may be additional governmental security requirements that apply to you.
4.2List of Dangerous Goods
The amendments to the List of Dangerous Goods include:
The new entry for UN3363 will be in addition to DG in Apparatus and DG in Machinery. There is very little shipping consequence in the choice of proper shipping names as the packing requirements are the same, but this is now an additional option for shippers to more accurately declare their goods.
- addition of a new proper shipping name, Dangerous goods in articles to UN 3363;
- addition of a new UN number, UN 3549 for Medical waste, Category A, affecting animals and Medical waste, Category A, affecting humans;
- the packing instruction number for UN 3291, Biomedical waste, n.o.s., Clinical waste, unspecified, n.o.s., Medical waste, n.o.s. and Regulated medical waste, n.o.s. has been changed from PI 622 to be PI 621;
22.214.171.124.3The minimum dimensions of the lithium battery mark have been revised.
This change stems from a change in the UN model regulations in which industry was actively involved. The initial proposal was to revise the dimensions of the lithium battery mark and no longer allow the old mark. The Dangerous Goods Trainer Association, MDBTC, PRBA and others pointed out that we had just changed the format of the lithium battery mark in 2018 lets not completely disallow the old marks because of this new size requirement. Long story short the new mark is smaller and does not have to be rectangular as it does now; and most importantly you can still use old labels that represent the mark.
126.96.36.199.2, Step 7The requirements on how to describe multiple overpacks on the Shipper's Declaration have been revised, with an additional example provided (Figure 8.1.Q).
8.2.1The statement required on the air waybill when dangerous goods are offered on a Shipper's Declaration has been revised to align the language to the use of electronic documentation where the Shipper's Declaration is not attached but rather is associated. There is a two year transition period during which time either wording is acceptable.
All in all there are not too many significant changes in here and the impact on supply-chain partners will depend on their role and the types of commodities they handle.
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