icao dangerous goods inspector’s workshop

ICAO Dangerous Goods Inspector’s WorkshopGM 4 - Dangerous Goods Audits and Inspections

Slide 1Revision 05 – March 2008

Topics of Chapter 04• 4.1 Introduction• 4.2 Purposes • 4.3 Inspection Procedures• 4.4 Summary of Inspection Procedures• 4.5 How to plan an inspection• 4.6 Results of inspections• 4.7 Frequency of inspections

ICAO Dangerous Goods Inspector’s WorkshopGM-04 – Guidance Manual – Chapter 4 - Dangerous Goods Audits and Inspections


Topics of Chapter 04

4.1Introduction



4.1 Introduction• 4.1.1 For the purposes of this manual

and to align with the terminology used in ICAO Annex 18 “The Safe Transport of Dangerous Goods”, “inspections” should be regarded as synonymous with “audits”.




4.2Purposes



4.2 Purposes• 4.2.1 As required by

Annex 18 to the Chicago Convention, each contracting State shall establish inspection procedures with a view to achieving compliance with its dangerous goods regulations.



T he Safe Transport ofDangerous Goods by A ir

A nnex 18 to the Convention onInternational C ivil Aviation

This edition incorporates all amendmentsadopted by the Council prior to 8 M arch 2001and supersedes, on 1 November 2001, a ll previouseditions of Annex 18.

For inform ation regarding the applicability of the Standards and Recom mended Practices,see Forew ord and the relevant clauses ineach Chapter.

International C ivil Aviation O rgan ization

International Standardsand Recomm ended Practices

Third EditionJuly 2001

4.2 Purposes11.1 Inspection systems• Each Contracting State shall establish

inspection, surveillance and enforcement procedures with a view to achieving compliance with its dangerous goods regulations.

• …Source: ICAO Annex 18, 11.1



4.2 Purposes11.1 Inspection systems• …• Note.— It is envisaged that these

procedures would include provisions for the inspection of both documents and cargo and operators’ practices as well as providing a method for the investigation of alleged violations (see 11.3).

Source: ICAO Annex 18, 11.1



4.2 Purposes• 4.2.2 The aim of the inspection is to

assess the suitability of the organisation and procedures established by the operator and of the facilities provided for the handling of dangerous goods, taking into account the nature and scale of the operation.



4.2 Purposes• If the operator uses a handling agent,

the liaison between them needs to be checked to confirm that each knows what is expected of them by the other.



FreightForwarder Cargo

Mail &ExpressParcels

CompanyMaterial(COMAT)

AircraftOn Ground

(AOG)

AircraftEquipment

CateringAnd

Duty Free

PassengersCarry-onBaggage

CrewCarry-onBaggage

EmployeesCarry-onBaggage

CargoAcceptance

Staff

LoadingStaff

SecurityPAX

Check-inStaff

SecurityCrewCheckedBaggage

PassengersCheckedBaggage

EmployeesCheckedBaggage

Shippers

Crew Employees


4.2 Purposes• This Part details the responsibilities of

operators with regard to the acceptance, handling and loading of dangerous goods...… Also, nothing in this Part is intended to preclude a ground handling agent from carrying out some or all of the functions of an operator. However, such ground handling agents are subject to the operator’s responsibilities of Part 7.

Source: ICAO TI, Part 7, Introductory Note



4.2 Purposes• “There are many air carriers who delegate to

third parties some of the duties that are assigned to them in the ICAO Technical Instructions and in this Part.

• There is nothing in these Regulations that hinders this practice but it should be noted by air carriers that delegating responsibility for certain duties does not include delegating liability for those duties. Transportation of Dangerous Goods Regulation (CANADA) chapter 12



4.2 Purposes• 4.2.3 The establishment of inspection

procedures will ensure that dangerous goods are transported safely without placing an aircraft or its occupants at risk.



4.2 Purposes• 4.2.4 There are numbers of aspects

related to the transport of dangerous goods by air to verify during an inspection.

• The inspection needs to confirm that the operator has sufficient resources for the intended operation and has identified those individuals who have specific responsibilities and has made them aware of their responsibilities.



4.2 Purposes• It will ensure that reference manuals

are up-to-date and available to staff who will need to use them.



4.2 Purposes• The manner of handling and storing

dangerous goods in airport premises is checked to ensure there are no practices which could lead to accidental damage of packages or put staff at risk;



4.2 Purposes• … and the method of loading and

stowage on aircraft is checked to ensure it is carried out according to the requirements.




4.3Inspection Procedures



4.3 Inspection Procedures• 4.3.1 Inspections are carried out at

cargo facilities, …



4.3 Inspection Procedures…, on the ramp,…



4.3 Inspection Procedures…, in passenger terminals and, ...



4.3 Inspection Procedures… occasionally, other places such as

security check-points, …



4.3 Inspection Procedures…, shippers, freight forwarders,

packaging manufacturers, at a frequency commensurate with the

scale and nature of the operation…



4.3 Inspection Procedures• In addition, audits of procedures

include visiting operator's or handling agent's premises, as appropriate.




4.4Summary of Inspection

Procedures



4.4 Summary of Inspection Procedures

• 4.4.1 Each inspection listed below will be explained in a separated chapter of this manual and sample inspection checklists will be annexed:A. Initial inspection:B. Periodic inspections:




• 4.4.2 The purpose of an initial inspection is to verify that the operator meet the requirements of the National Regulations and the ICAO Technical Instructions before transporting dangerous goods.




An initial inspection includes a review of:• Operator application to transport

dangerous goods in normal or special circumstances;

• Operations manual and other staff instructions; and

• Training programs approvals.




• 4.4.4 The periodic inspections are to verify that the operator keeps the information in the reference manuals up to date and that the manner of handling and storing dangerous goods in airport premises and the method of loading and stowage on aircraft are carried out according to the requirements.




• The types of inspections for operators / handling agents may vary from in-depth audits to consignment checks and ramp inspections;

• inspections at airports also include checks for notices for passengers.




4.4.5 Periodic inspections includes:• Operations manual and other staff

instructions inspection• Training programs inspection• Staff training inspection• Consignment inspection (package

and documents) at cargo facilities• …




• …• Ramp inspection (loading and

stowage)• Passenger information inspection

(warning notices)• In-depth audits.




4.5How to Plan an Inspection



4.5 How to plan an inspection

• 4.5.1 Pre-Inspection • 4.5.1.1 Before an

inspection is started, all information concerning the operator’s procedures shall be reviewed.



4.5 How to plan an inspection• 4.5.1.2 Examine all relevant operator

information such as: Operator Company file Certification file Company Manuals Occurrence report Previous inspection records State Approvals



4.5 How to plan an inspection … Referral materials Any other relevant

carrier/company information available



4.5 How to plan an inspection



4.5 How to plan an inspection4.5.2 Site Inspection • 4.5.2.1 When an inspection is

scheduled, adequate notice should be given to advise the operator / handling agent and arrangements made for access to relevant areas.

• In some circumstances the inspection may be made without giving prior notice.

• However, this may not always be practicable or desirable.



4.5 How to plan an inspection4.5.2.2 On arrival:• Introduce self to company

representative (it is recommended to provide a business card)

• State purpose of inspection and request name of appropriate person to contact

• Explain to appropriate person in charge reason for inspection and general inspection process



4.5 How to plan an inspection…• Ensure safety equipment meets

carrier / company requirements (i.e. safety boots, high visibility vest, etc.)

• Arrange for accompaniment of person in charge




4.6Results of Inspections



4.6 Results of inspections• 4.6.1 The results of a dangerous

goods inspection are documented so as to produce a record of what was seen and noted at the time.

• The record must be sufficiently comprehensive to identify any deficiencies, since these will need to be identified in a request to the operator to take action to remedy them.



4.6 Results of inspections4.6.2 The answer, requested from the operator

should include: • An internal investigation report indicating the • Short term corrective action plan• Long term / system wide corrective action

plan• Method to verify the effectiveness of

corrective action plans (Specifying frequency and how documentation will be retained)



4.6 Results of inspectionsSituation: • During an inspection, you discovered

that three cargo acceptance staffs have expired the validity of their training by one month.



Operator’s Corrective Action PlanProbable / Root Causes• The responsibility for tracking the

competency of staff was delegated to each station; and

• The person responsible for this duty has been on maternity leave for the last ten months and the duties were not assigned to someone else.

4.6 Results of inspections



Short term corrective action plan• The no longer qualified employees will

be ordered not to accept any dangerous goods cargo until they have been re-trained.

• Training for them will be done in the next 30 days.




Long term / system wide corrective action plan:

• A database will be establish in the next 60 days to track the validity of training of all employees.

• This database will be located at headquarter

• The training coordinator will be responsible for the database.




• On the 1st day of every month, a list of staff requiring training in the next 90 days will be send to:– The Station Manager; and– The Director of training

• On the 20th of every month, the Station Manager will have to report to the Vice President Operations on the staff no longer qualified (if applicable).




Method to verify the effectiveness of corrective action plans :

• Every a year, during the internal station’s audit, every training records will be reviewed for lapse of training qualification.

• An associated report will be retain for ten years in the training department.




4.6 Results of inspections• 4.6.3 If during an inspection an

Inspector discovers a violation, his response will be determined by various factors which will warrant different courses of action.



• Factors/Circumstances to Consider When Choosing a Response

• “Whenever a violation of the Transportation of Dangerous Goods Act is discovered and substantiated, Inspectors will consider the following factors when deciding what enforcement response to take:”




4.6 Results of inspections• The nature of the violation. • This includes consideration of the

seriousness of the violation or the harm or potential harm to life, health, property and the environment, the type and quantities of dangerous goods involved and circumstances of the violation.

• Whether there are attempts to conceal information or otherwise subvert the objectives of the Act.



4.6 Results of inspections• The attitude and attempts to comply or

the intent to contravene the Act.• Whether the violation is correctable on

site.• Previous recorded history of non-

compliance.• Whether the non-compliance is of a

continuing nature and likely to reoccur.




4.7Frequency of Inspections



4.7 Frequency of inspections• 4.7.1 The Technical Instructions does not

specify the frequency of such inspections.

• However the “Manual of Procedures for Operations Inspection, Certification and Continued Surveillance”, produced by ICAO, recommends that all significant aspects of the operator’s procedures and practices should be inspected at least once every twelve-month period.



4.7 Frequency of inspections• Consequently, states should consider

inspecting all aspects related to dangerous goods of an operator engaged in the carriage of dangerous goods as cargo on an annual basis, as a minimum.

• Operators choosing not to transport dangerous goods as cargo may be inspected at a less frequent rate.



4.7 Frequency of inspections4.7.2 Some of the factors which may affect

an inspection’s schedules are as follow:• Risk assessment of the air operator

based on:– Prior inspection; and– Compliance record

• Quantity of COMAT or commercial dangerous goods accepted at the location.



4.7 Frequency of inspections• Location of many air operators at one

location• Seasonal operation in limited access

area.• ICAO Technical Instructions’ two years

cycle.



End of Unit GM-04



Daniel J. SylvestreSuperintendent, Dangerous GoodsTRANSPORT CANADANational Operations – Airlines DivisionTel: 1 (514) 633-3116 / Fax: 1 (514) 633-3717Email: [email protected]: www.tc.gc.ca700 Leigh Capreol, Suite 2093 (NAROA), Dorval, Quebec H4Y 1G7, CANADAGovernment of Canada

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