Both light and heavy vehicles must display operator registration.

Operators apply for registration in terms of Regulation 266. No details of substances are recorded.

Of primary concern in Dangerous Goods transport is the competency of the drivers. The responsibility for assuring a driver is adequately trained rests with the employer.

Both light and heavy vehicle drivers transporting Dangerous Goods require training in terms of Regulation 280/117(e) (Heavy) and SANS 10231-2006 (light) as well as the Occupational Health & Safety Act 85 of 1993 and its amendments.

Eddie Crane of EC Logistics, an accredited Dangerous Goods training facility with branches in Durban and Johannesburg, says many problems with non-accredited training providers are often picked up at municipal level when the driver goes to pick up his PrDP. “Drivers have to provide a registration number of the training provider to the licensing authorities. If this does not tally with the NDOT’s list of accredited training providers, they do not get their papers.”

Crane did say that this system is not infallible and the correct procedures are not always followed by the licensing authorities. He reiterates CAIA’s advice that fleet operators should ensure training institutions attended by their drivers are approved and up to date in terms of training materials.

Keith McMurray, one of South Africa’s leading Dangerous Goods transport consultants, suggests operators assess the training material used for driver training whether or not the provider is approved by TETA or accredited by the NDOT as many of the approved providers are offering unacceptable training material.

Further to this, Regulation 280 (2) stipulates:

“Each approved training body shall submit a syllabus for the training of the drivers referred to in sub-regulation (1) to the Shareholders Committee* for approval, and re-submit such syllabus for approval, within 90 days of relevant legislation or SABS specification influencing the training material have been amended.

Regulation 280 (3) is quite specific about what type of training should be provided:

“The syllabus for the training of drivers shall contain at least -

1. The interpretation and implementation of the instructions on a Tremcard;

2. General duties of the driver before proceeding on a route concerning, specifically but not limited to, the condition of the vehicle, the documents to be kept in the vehicle, instructions regarding the route to be taken, warning signs and warning devices to be displayed or stored in the vehicle, the correct type and number of fire extinguishers to be fitted to the vehicle and protective clothing to be used;

3. General behaviour expected of the driver on the route, among other things, planning for stops for deliveries or the checking of tyres and vehicle, and the procedure to be followed in the event of stops in the event of stops, period of driving allowed, action to be taken in the event of an incident occurring;

4. General procedure to be followed by the driver on reaching his or her destination; and

5. General procedure to be followed when loading or offloading Dangerous Goods.

Concern has also been expressed about Regulation 280 (5) which reads as follows: “An operator shall ensure that a driver undergoes theoretical and practical training at an approved training body for the specific class of Dangerous Goods that he or she shall be responsible for and practical training by an accredited body for the specific type of vehicle that he or she shall drive.”

According to Crane, Dangerous Goods driving permits are being issued without the drivers having undergone the specific training referred to in Regulation 280 (5). “Section five is often overlooked leaving many Dangerous Goods drivers with only the generic training under their belts,” he says. Crane says the reason for this is that some training bodies do not have the required sector specific training manuals to carry out the necessary training so it is simply not covered. As the regulation stipulates, it is the responsibility of the operator to ensure this training is provided not the NDOT or the licensing issuing authority.

This placard is illegal due to the fact it is out of date and of the incorrect format.

Driver’s documents

In addition to a professional driving permit, DG drivers are required to carry a transport emergency card and document known as the Dangerous Goods declaration. The Dangerous Goods declaration must contain details of the consignor, consignee, the operator and the correct name of the product. The operator is also required to inform the emergency services situated along the routes which he will travel, what will be transported and the quantities so that appropriate measures will be taken to deal with an emergency.

On the matter of documents to be held by the driver during the course of his duties, Chapter VIII of the National Road Traffic Act: Transportation of Dangerous Goods and substances by road, stipulates the following:

Regulation 281 (1): The driver of a vehicle referred to in regulation 274(1) shall ensure that such Tremcards and manifests as are required in terms of this Chapter, and which pertain to the Dangerous Goods carried on such vehicle, are held in the designated space in the cab of that vehicle at such time as Dangerous Goods are being transported in such vehicle.

Incident reporting

In accordance with SANS 10231 “Transportation of Dangerous Goods Operation” – 2006, all accidents involving Dangerous Goods vehicles must be reported to the NDOT within 30 days.

SANS 10231 describes an incident as an unplanned event during the transport or storage of Dangerous Goods including leakage, spillage, fire or other unplanned occurrence.

Operators are obliged to inform the emergency services and the police if any incident involving their vehicles has taken place. If any injury, fire, explosion or spillage has occurred, the operator must also prepare an incident report in accordance with annex D and submit it to the relevant government department within 30 days.

The fax number for reporting Dangerous Goods incidents at the NDOT is (012) 309 3721. The reporting form as per SANS 10231 Annex D must be used.

In 1994, The Chemical and Allied Industries Association (CAIA) launched its Responsible Care programme in South Africa to respond to public concerns about the manufacture, storage, transport, use and disposal of chemicals.

A report released by CAIA in May last year states that traffic disruptions due to spillages of hazardous goods on national routes, such as the N3, are due to a complex set of conditions, including large volumes of Dangerous Goods, poor maintenance of infrastructure or vehicles, poor management, packaging, congestion, training, compliance and enforcement issues.

Delays in emergency response services are likewise due to several factors, as identified by an N3 task team and reported in Occupational Risk Management in 2008.

CAIA appeals to transport operators to ensure Dangerous Goods vehicles display the correct placards and include the required documentation in the designated area (designated space), before leaving their premises. Further to this, the CAIA has expressed concern that many operators are taking short cuts with the transportation of Dangerous Goods. The Association lists the following areas that require urgent attention:

1. The principles of effective driver and journey management are not always correctly implemented by DG operators.

2. Limited involvement and lack of cooperation of the National Department of Transport at industry level.

3. Driver health.

4. Lack of knowledge of Dangerous Goods legislation and AARTO (Administrative Adjudication of Road Traffic Offences.)

5. Driver training has become a casualty of the recession resulting in obsolete training material being used by certain approved providers. Training certificates are obtainable without appropriate training.

6. Shortage of qualified and experienced drivers as well as a professional driving qualification in South Africa.

7. Very little is being done to research and address driver behaviour in spite of the fact that around 90% of incidents (road accidents) are attributed to human error.

Footnote: TruckWatch would like to acknowledge and thank Dangerous Goods specialist, Keith McMurray, the Chemical and Allied Industries Association, and EC Logistics for their valuable input into this article.