The training of dangerous goods safety advisors
The Ordinance on Dangerous Goods Safety Advisers (GGBV) regulates which companies must appoint a dangerous goods safety adviser (GGB) and what his tasks and duties are. The GGBV explicitly allows that, in addition to employees or owners of a company, external persons can also assume the function of the GGB. This opens up the possibility for service companies and freelancers to commit themselves as external dangerous goods safety advisors at several companies at the same time.
The advantages are obvious: Instead of building up the necessary knowledge and experience in the area of dangerous goods regulations in the company itself and burdening own employees with an additional task, current knowledge, broad experience and the necessary working time are simply bought in. However, it is not worthwhile for every company to outsource the task of SCI. The involvement of an external SCI makes sense for companies that have only few points of contact with Dangerous goods have, but still fall under the obligation to appoint a SCI: Typically, these are establishments that receive hazardous materials in quantities above the exemption limits of the hazardous materials law and are involved in unloading, as well as establishments that discharge hazardous well in the form of hazardous waste and rely largely on the work of hazardous waste handlers.
"Every company has a duty and must follow the requirements from the GGBV."
Mathias Breimesser, Neosys AG
For such companies, it is often not worthwhile to train an internal person as a SCI and to keep him constantly up to date with the latest knowledge. On the other hand, an external SCI, who looks after several mandates in parallel, can take advantage of synergies and efficiently perform his duties, such as writing the annual report on dangerous goods or training employees. Depending on the operational situation, the SCI with his knowledge of the extensive exemption rules and exemptions can also advise the company so that it falls below the exemption limits and no longer needs to appoint a SCI. Of course, even in these cases, it is still useful to have someone on hand who keeps an eye on the constantly changing regulations and operational processes in connection with dangerous goods, points out any deficiencies and has practicable solutions at hand.
Read the full technical article from SAFETY-PLUS 4/2019 (p. 54 ff.) as PDF online.
