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By Michael Griffiths
If your organisation ships or receives dangerous goods into or out of Australia by sea, understanding the requirements administered by the Australian Maritime Safety Authority is an important part of maintaining compliance.
The Australian Maritime Safety Authority, commonly known as AMSA, is the federal authority responsible for maritime safety in Australia and oversees the safety of commercial vessels operating in Australian waters.
AMSA also enforces international requirements relating to the carriage of dangerous goods by sea, including those contained in the International Maritime Dangerous Goods Code.
The IMDG Code and shore based personnel
The International Maritime Dangerous Goods Code, or IMDG Code, provides the international regulatory framework for transporting dangerous goods by sea.
Since 2012, with the Australian legislative framework subsequently updated in 2017, IMDG training has been mandatory for shore based personnel involved in activities associated with the transport of dangerous goods by sea.
For businesses moving dangerous goods internationally, this requirement can extend across a broad range of personnel involved in the transport process. This includes administrative staff preparing documentation as well as personnel involved in packing, unpacking, loading and other dangerous goods activities.
Relevant personnel must receive appropriate IMDG training and maintain their training in accordance with the applicable requirements.
Marine Order 41
The training obligation is specifically addressed in AMSA Marine Order 41, Carriage of Dangerous Goods, 2017.
Division 5, Training and safe system of work requirements, section 21 states:
An employer of a person, other than a seafarer, engaged in any activity relating to the handling, packing, stowing and carriage of dangerous goods must ensure that the employee is given training, including refresher training, in accordance with Chapter 1.3 of the IMDG Code.
Chapter 1.3 of the IMDG Code requires general awareness or familiarisation training and function specific training for shore based personnel.
Marine Order 41 also identifies specific activities for which training must reflect the person’s responsibilities, including:
- Packing dangerous goods in packages.
- Marking, labelling or placarding dangerous goods.
- Loading or unloading cargo transport units.
- Preparing transport documents for dangerous goods.
Training records also matter
The obligation does not end when the training has been completed.
Marine Order 41 also requires employers to retain evidence of training received by an employee or contractor for at least five years after the training occurred.
For businesses involved in international dangerous goods movements by sea, this makes training records part of the broader compliance system. It is not enough to ensure that personnel understand their responsibilities. The organisation must also be able to demonstrate that the required training has occurred.
A shared responsibility
Dangerous goods movements by sea involve people performing different functions across documentation, packing, handling and transport.
Understanding which personnel require training, ensuring that the training reflects their actual responsibilities, maintaining refresher training and retaining appropriate records are therefore important parts of an effective IMDG compliance framework.
For organisations shipping dangerous goods into or out of Australia, these requirements should be considered as part of normal operational planning rather than only when a compliance issue arises.