Do We Need a DGSA?

Due to a change in the law, you may need to appoint a Dangerous Goods Safety Adviser (DGSA). This post will give you the considerations you need, to make an informed decision.

Most companies involved in the carriage of dangerous goods by road are already legally required to appoint at least one DGSA.

This has been the case for a number of years. So what’s changing?

Within ADR 2019, a requirement was included for Consignors (the sender of goods) to appoint a Dangerous Goods Safety Adviser. This will become mandatory by the end of 2022.

What Types of Organisations May Come Into Scope?

Organisations who currently manufacture or consign (send) dangerous goods may come into scope of the requirement to appoint a DGSA. This includes fulfilment centres who work on behalf of manufacturers and distributors.

Any Exemptions to Appointing a DGSA?

ADR does contain exemptions from having a DGSA, and these may apply to your operation. Common examples are Limited Quantities and those utilising the Small Load exemption. If you’re unfamiliar with these terms, it basically means there’s a threshold to the amount of dangerous goods in any single package (Limited Quantities) and a threshold to what can be carried on a vehicle (Small Load).

Once these limits are exceeded, you’re deemed to be ‘fully regulated’. Which means you need to comply with all the relevant aspects of ADR, including the appointment of a DGSA.

I apologise for this next bit as it’s trotted-out so much it’s become cliched but, ‘ignorance is no defence’. And there’s really no excuse for not knowing, as most training companies and consultants would be happy to have a ‘no obligation’ discussion with you.

Dangerous Goods is an area of legislation where you sometimes need to know enough about the regulations to know when they might not apply. If you would like to discuss your particular operation, drop us a line at support@dgsaacademy.co.uk or give us a call on 0330 223 6727.

You are guaranteed a straight-forward discussion, in plain English, about whether you are in scope of the new requirements. And if so, what your options are.

Where Do I Get My DGSA Exemption Certificate?

As an organisation, you may review the scope and exemptions and decide your operation is exempt from the requirement to appoint a DGSA. Unfortunately, there is no ‘exemption certificate’ (I was being mischievous).

How it works is, if something did go horribly wrong, a representative of your company may have to stand in a court of law to defend why the exemption applied. This is not to say you wouldn’t be correct; it’s just the way it can play-out.

Can’t I Just Ask The Government?

You might be able to find someone at DfT, HSE that would be willing to engage with you on the specifics of your situation. In my experience though, government officials are very reluctant to offer advice on legal exemptions, particularly if your request is in writing (which you should always get).

You are likely to receive a tightly drawn (but very polite) response, which often ends with the phrase, ‘interpretation is a matter for the courts’ (or similar).

We’re Definitely Exempt, Can I Go Now?

If you’ve read this far, you probably send or carry some form of dangerous goods. Although you may feel secure in applying the exemption from appointing a DGSA, ADR does still contain general training obligations for your staff.

Training must be ‘appropriate to their responsibilities, so this includes forklift drivers, warehouse operatives and potentially staff in the office. And this applies even if you ‘only’ move Limited Quantities or under the small load exemption.

You Would Say That, You’re a DGSA Training Provider

They say, ‘never ask a barber if you need a haircut’, so definitely get a second opinion. You can go one step better and actually look at the source document.

You can download ADR for free (!!) from the UNECE website. Download both volumes (and the corrigendum). Look at Chapter 1.3 (in volume I). This details the ‘Training’ requirements.

One of the duties of a DGSA is to monitor the dangerous goods training of employees, making sure they’re kept updated on any changes, and ensuring that proper records are kept. You can, of course, manage it another way, but ADR 1.3 does often prompt useful questions as to ‘how’ it actually works within an organisation.

What Are the Options to Appointing a DGSA?

There’s primarily two ways to meet the requirement:

1: Train an employee to fulfil the role of the DGSA.

2. Appoint a consultant.

There’s pro’s/cons to each option, as there is with any hire vs buy decision. This blog post contains an outline business case for both.

Employees who fulfil the role of a DGSA often already have a principal job, such as Health and Safety, Transport or Warehouse Manager. Like any position, you do need to consider contingency. Particularly in today’s job market – your employee may get a better offer. It’s not unheard of for the sole DGSA to have been made redundant. It’s for these reasons that some organisations have a combination of internal/external provision.

How many DGSA’s are required, and who the business appoints, is left up to you.

Do We Just Put Someone On a Course?

Yes and No. You do enrol learners on to a course with a training provider. The exam, however, only takes place once a quarter. SQA is the awarding organisation, and they run the exams at ten locations throughout the UK, on the same day.

To qualify as a DGSA, you need to pass three exams: Core, All Classes and Road. The results are issued within 8 weeks.

You need to pass all three within 12 months to qualify as Dangerous Goods Safety Adviser (DGSA). If you fail even one of the exams, you need to take that exam again to qualify.

Go On Then, Tell Us What Makes DGSA Academy Different?

I’m glad you asked (I know you didn’t – I might be taking this alter-ego thing a bit too far)

Training provision is open market and there’s several credible providers. You should definitely look at their offer and get their prices. But, what sets us aside is this:

  • This is the only thing we do – we are dedicated to training for this one qualification
  • We run courses in Coventry and Online every quarter
  • Our Virtual Classroom is more than a Zoom call (sorry Zoom fans). It has:
    • Playlists
    • Whiteboards
    • Polls and Quizzes
    • Recorded sessions – available to all learners up until their exam
  • Comprehensive learning resources including mock exams
  • Post-course: every learner has a 60 minute 1:1 coaching session
  • Each learner has a personalised revision plan based on the results of their mock exams
  • If you choose our Complete Package, we even take care of exam bookings and administration.

Satisfaction Guarantee

So confident are we that our approach provides the best chance of success, we are the only provider to offer a satisfaction guarantee – should any of our learners not pass all of the exams, we will provide additional resources and another 1:1 coaching session, free of charge

Thanks for taking the time to read this post!

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