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Established 1984 | Recognised by the HSE

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Dangerous Goods Safety Adviser (DGSA)

ADR road transport regulations 2009 (1.8.3)

Organisations which undertake the carriage or related packing, loading, filling or unloading of dangerous goods by road are required to appoint one or more DGSA to help prevent the risks inherent in such activities to workers, the public and the environment. The DGSA must hold a vocational training certificate, valid for transport by road, issued in the UK by the SQA on behalf of the DfT.

There is, however, exemption given to an undertaking where:

  • the quantities involved are below load quantity thresholds, limited quantities or excepted quantities, or
  • the main or secondary activities of which are not the carriage, loading, or unloading of dangerous goods but which occasionally engage in such activities, and these activities pose little danger or risk of pollution.


To quote the HSE guidance on this subject:

“Various questions of interpretation arise in connection with this exemption. Main or secondary activity should be interpreted as the main or secondary purpose of the business. Thus companies whose business is not the transport of dangerous goods per se but whose activities involve such transport will normally not require to appoint a DGSA. Examples include:

 

  • Construction companies taking dangerous goods to and from sites would not be regarded as having transport of dangerous goods as either a main or secondary activity
  • Repair organisations that occasionally recover vehicles which are still loaded with dangerous goods.  For routine services, it would be expected that the vehicles would be unloaded and, where applicable, cleaned and purged.

 

Delivery companies, freight forwarders etc. are not within this category as the carriage of dangerous goods is often their main or secondary activity.

The terms occasionally engage and little danger or risk of pollution pose practical difficulties of interpretation.  In so far as the limited quantities exemptions apply a risk assessment approach, it could be argued that carriage above those thresholds cannot qualify.

Occasionally should be interpreted as 1 to 2 journeys per month. If more frequent deliveries (e.g. by a contractor to a site) are required, this should not be regarded as occasional."



Radman Associates is well placed to provide a composite RPA and DGSA advisory service for those involved in the loading, carriage or unloading of radioactive packages and materials.  Advice is given on the requirements  of the Carriage of Dangerous Goods Regulations 2009 and an annual report summarises the client's current level of compliance.

Specifically, the DGSA’s duties are:

 

  • Monitoring compliance with the requirements governing the carriage of dangerous goods;
  • Advising on the carriage of dangerous goods;
  • Preparing an annual report to management on the organisation’s activities in the carriage of dangerous goods.  These reports must be retained for five years and be made available to the national authorities at their request

 

Need help?

To contact our team of HSE recognised Radiation Protection Advisors please email Admin or call 0845 226 7248.