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1. Name:

 test
 1 (1%) 
 
 Srinivasan Raman
 2 (1%) 
 
 Suliana Wesley
 1 (1%) 
 
 Susann Sack
 1 (1%) 
 
 Chris Reed
 1 (1%) 
 
 Mary Curtin
 1 (1%) 
 
 David Fuller
 1 (1%) 
 
 Gerald Mwaka Obol
 1 (1%) 
 
 William Wojtas
 1 (1%) 
 
 Martin Egeskov Pedersen
 1 (1%) 
 
 Flavio Monteze
 1 (1%) 
 
 Dennis Kampman
 1 (1%) 
 
 Bruno QUIRANT
 1 (1%) 
 
 John Christal
 1 (1%) 
 
 Glenn Murphy
 2 (1%) 
 
 Robin Gordon
 1 (1%) 
 
 TREVOR MILLS
 1 (1%) 
 
 Iain Picot
 1 (1%) 
 
 Paul Munro
 1 (1%) 
 
 Robert Beer
 1 (1%) 
 
 Paul Barrott
 1 (1%) 
 
 JAYNE CHAPMAN
 1 (1%) 
 
 Ulf Christensen
 1 (1%) 
 
 Susann Sack-Scrivener
 1 (1%) 
 
 Steven Woods
 1 (1%) 
 
 Gregory Sutherland
 1 (1%) 
 
 Alan Kuspert
 1 (1%) 
 
 John
 1 (1%) 
 
 Axel Mixa
 1 (1%) 
 
 d
 1 (1%) 
 
 Simon Pinnock
 1 (1%) 
 
 Andrew Fraser
 1 (1%) 
 
 Hasan Diaz
 1 (1%) 
 
 Delbeke Gregory
 1 (1%) 
 
 Musthapa Hassan
 1 (1%) 
 
 ARNET Christoph
 1 (1%) 
 
 Jim Powell
 1 (1%) 
 
 Captain Noel Wendelin Komba
 1 (1%) 
 
 Korniyenko Oleksandr
 1 (1%) 
 
 Rob Edson
 1 (1%) 
 
 Bob Richard
 1 (1%) 
 
 Romsai Phiothisoontron
 1 (1%) 
 
 Lior Stopper
 1 (1%) 
 
 Thomas Weigel
 1 (1%) 
 
 Philipp Schubert
 1 (1%) 
 
 Stefan Sauerbier
 1 (1%) 
 
 Tatjana Kronenbürger
 1 (1%) 
 
 Jurgita Jazdauskiene
 1 (1%) 
 
 Keith Harrington
 1 (1%) 
 
 Behrendt Rüdiger
 1 (1%) 
 
 Gerster
 1 (1%) 
 
 Eva Glimsche
 1 (1%) 
 
 Ulrich Sensche
 1 (1%) 
 
 Pavol
 1 (1%) 
 
 STANLEY GOODSON
 2 (1%) 
 
 Andy Walters
 1 (1%) 
 
 Yang Huan Fan
 1 (1%) 
 
 Paul Webster
 1 (1%) 
 
 Dan Lee
 1 (1%) 
 
 Gilbert de Chauvigny de Blot
 1 (1%) 
 
 Vanessa Webb
 1 (1%) 
 
 Richard J.Walsh
 1 (1%) 
 
 ALEKSANDRE GACHECHILADZE
 1 (1%) 
 
 Steve Walke
 1 (1%) 
 
 John RYAN
 1 (1%) 
 
 Eddy Vanderperren
 1 (1%) 
 
 UMIT YASAR CETIN
 1 (1%) 
 
 JULIO BOLLAIN
 1 (1%) 
 
 Julio Bollaín
 1 (1%) 
 
 Manfred Rave
 1 (1%) 
 
 jose Holguin
 2 (1%) 
 
 Paul King
 1 (1%) 
 
 REPUBLIC OF TURKEY, MINISTRY OF TRANSPORT, MARITIME AFFAIRS AND COMMUNICATIONS
 1 (1%) 
 
 LAMQUEMBE Pascal
 1 (1%) 
 
 Clive Savigar
 1 (1%) 
 
 JOSE ANDRES HOLGUIN VASQUEZ
 1 (1%) 
 
 LAHON Frederic
 1 (1%) 
 
 David FARLA
 1 (1%) 
 
 Frank WAI
 1 (1%) 
 
 Aibek Baiyshbaev
 1 (1%) 
 
 Nicholas Mohr
 2 (1%) 
 
 IFALPA
 1 (1%) 
 
 T. George
 1 (1%) 
 
 jackie Richardson
 1 (1%) 
 
 Eli Mandelawy
 1 (1%) 
 
 AYSU KOCABALKAN
 1 (1%) 
 
 SELCUK KAHRAMAN
 1 (1%) 
 
 Sergey Korovin
 2 (1%) 
 
 Charles Tse
 1 (1%) 
 
 Teun Muller
 1 (1%) 
 
 Michael Collins
 1 (1%) 
 
 Alice Lui
 2 (1%) 
 
 Senja Hakola
 1 (1%) 
 
 Jon Horsted
 1 (1%) 
 
 Jouri Vandenplas
 1 (1%) 
 
 Arzu Öztugran
 1 (1%) 
 
 Astrid van der Burgt
 1 (1%) 
 
 Waltraud Hasse
 1 (1%) 
 
 SERHAT KORKUSUZ
 1 (1%) 
 
 KANNATH MOHANAN
 1 (1%) 
 
 graham smiuth
 1 (1%) 
 
 Stefano Santi
 1 (1%) 
 
 Amy Park
 2 (1%) 
 
 Mats Bäckström
 1 (1%) 
 
 kemal ibiş
 1 (1%) 
 
 Mario Sommer
 1 (1%) 
 
 Robert Jaffin
 1 (1%) 
 
 Scott Lanphear
 1 (1%) 
 
 testing
 2 (1%) 
 
 FERHAT YILDIRIM
 1 (1%) 
 
 SEVENO Marie
 1 (1%) 
 
 1
 1 (1%) 
 
 Suphakit Rangsuwan
 1 (1%) 
 
 Gerhard Amann
 1 (1%) 
 
 Mohamed Tayfour
 2 (1%) 
 
 Juan Pablo Olaz
 1 (1%) 
 
 David Gnanaselvam
 1 (1%) 
 
 Lisa Davis age 52
 1 (1%) 
 
 bdsfbsd
 2 (1%) 
 
 MOHAMED TAYFOUR
 3 (2%) 
 
 Kamlesh Taank
 1 (1%) 
 
 Simona Signorelli
 1 (1%) 
 
 Cem Yakal
 1 (1%) 
 
 Ibrahim Negm
 1 (1%) 
 
 AMAR RAHAL
 1 (1%) 
 
 Mohamed
 1 (1%) 
 
 bg sawant
 1 (1%) 
 
 shaham jekobson
 1 (1%) 
 
 Marcio Ednaldo Ferreira Martins
 2 (1%) 
 
 Huseyin Dursun
 1 (1%) 
 
 Yacima CHEKHAR
 1 (1%) 
 
Total: 145

2. Job title:

 test
 1 (1%) 
 
 Senior Instructor
 2 (1%) 
 
 Dangerous Goods Coordinator for Fiji Airways
 1 (1%) 
 
 Dangerous Goods Specialist
 2 (1%) 
 
 DG Trainer Air/Sea & Road
 1 (1%) 
 
 Team Member
 1 (1%) 
 
 Logistics
 1 (1%) 
 
 Dangerous Goods Regulations Trainer
 1 (1%) 
 
 Manager DG
 1 (1%) 
 
 Dangerous Goods Safety Advisor
 2 (1%) 
 
 Head of Security and Training
 1 (1%) 
 
 Manager Dangerous Goods
 1 (1%) 
 
 DG Manager
 1 (1%) 
 
 MD
 1 (1%) 
 
 Senior DG Instructor SAS/SGH training. IATA DGTWG Chairman
 1 (1%) 
 
 Senior DG Instructor/designer. IATA DGTWG Chairman
 1 (1%) 
 
 Director (Operator and Trainer)
 1 (1%) 
 
 LEARNING AND DELIVERY EXECUTIVE
 1 (1%) 
 
 Compliance Officer
 1 (1%) 
 
 AOC Post Holder Ground Operations
 1 (1%) 
 
 Security Manager
 1 (1%) 
 
 CAA dangerous Goods Instructor
 1 (1%) 
 
 DANGEROUS GOODS INSTRUCTOR
 1 (1%) 
 
 Operational Inspector FW + FP DG
 1 (1%) 
 
 Manager - Training Design, Safety and Security
 1 (1%) 
 
 Consutant
 1 (1%) 
 
 Ground Operations Manager
 2 (1%) 
 
 Botha
 1 (1%) 
 
 President
 2 (1%) 
 
 d
 1 (1%) 
 
 SVP - Safety, Security and Regulatory Compliance
 1 (1%) 
 
 Skills Development Officer
 1 (1%) 
 
 Dangerous Goods Corporate Standards Assistant Manager
 1 (1%) 
 
 Head of Operations Department
 1 (1%) 
 
 CEO/Chief Facilitator
 1 (1%) 
 
 Safety and Security Advisor
 1 (1%) 
 
 Dangerous Goods Inspector
 1 (1%) 
 
 Training Centre Chief
 1 (1%) 
 
 VP Regulatory compliance
 1 (1%) 
 
 Business Devleopment Executive
 1 (1%) 
 
 Dangerous Goods inspector and SME
 1 (1%) 
 
 Managing Director
 5 (3%) 
 
 Instructor
 5 (3%) 
 
 Senior Director Dangerous Goods Europe Region
 1 (1%) 
 
 Head of Dangerous Goods Logistics and Environmental Affairs
 1 (1%) 
 
 Chief specialist, Flight Operations division
 1 (1%) 
 
 Trainer
 1 (1%) 
 
 Director
 4 (3%) 
 
 Consultant
 1 (1%) 
 
 Quality & Security Managment
 1 (1%) 
 
 Busovsky
 1 (1%) 
 
 SR.FACILITATOR
 2 (1%) 
 
 Chief Instructor
 1 (1%) 
 
 Team Leader
 1 (1%) 
 
 Transport Operations Manager
 1 (1%) 
 
 Owner Dan Lee Training Ltd
 1 (1%) 
 
 Owner, Managing Director
 1 (1%) 
 
 Head of Air Transportation Department
 1 (1%) 
 
 DSA-DLSR-MTSR-Reg-DG-SO2
 1 (1%) 
 
 Dangerous goods instructor / loadcontroller
 1 (1%) 
 
 GROUND OPERATIONS SPECIALIST
 1 (1%) 
 
 Technical Director
 2 (1%) 
 
 Cargo Manager
 1 (1%) 
 
 Enc. oficina transporte Seguro de Mercacias Peligrosas por Via Aerea
 2 (1%) 
 
 Chief Aviation Security Inspection
 1 (1%) 
 
 DIRECTORATE GENERAL OF DANGEROUS GOODS AND COMBINED TRANSPORT
 1 (1%) 
 
 DGR Instructor
 1 (1%) 
 
 ENC. OFICINA TRASNSPORTE SEGURO DE MERCANCÍAS PELIGROSAS POR VIA AEREA
 1 (1%) 
 
 pilot - Trainer
 1 (1%) 
 
 Dangerous Goods Manager - Sub Sahara Africa
 1 (1%) 
 
 Senior Safety Officer (Safety Regulation)
 1 (1%) 
 
 Senior inspector Flight Safety Oversiht Department, National Coordinator for the Transport of Dangerous Goods
 1 (1%) 
 
 Chief Executive
 2 (1%) 
 
 IFALPA
 1 (1%) 
 
 Chief Instructor DGT
 1 (1%) 
 
 Export Manager
 1 (1%) 
 
 Product manager, Regulatory Training DGR & Security
 1 (1%) 
 
 CABIN CREW TRAINING MANAGER & DGR INSTRUCTOR
 1 (1%) 
 
 DGR INSTRUCTOR
 2 (1%) 
 
 Policy advisor
 1 (1%) 
 
 Director Americas RCG
 1 (1%) 
 
 Senior Inspector
 1 (1%) 
 
 Operational and Support team Supervisor
 1 (1%) 
 
 Restricted Commodities and Airside Training Manager MENA
 1 (1%) 
 
 Global Dangerous Goods Manager
 1 (1%) 
 
 Product Manager doc.Hdl. & DGR Training
 1 (1%) 
 
 Head of Aviation Training
 1 (1%) 
 
 ibstructor
 1 (1%) 
 
 Owner
 1 (1%) 
 
 Senior International Technical Consultant
 2 (1%) 
 
 Restricted Commodities Manager / Founder
 1 (1%) 
 
 security manger
 1 (1%) 
 
 Hazmat specialist
 1 (1%) 
 
 LECTURER/TRAINER
 1 (1%) 
 
 Operations Unit Manager
 1 (1%) 
 
 123
 1 (1%) 
 
 testing
 1 (1%) 
 
 First Officer
 1 (1%) 
 
 Dangerous Goods Trainer
 1 (1%) 
 
 1
 1 (1%) 
 
 Head of Dangerous Goods Standards Development Division
 1 (1%) 
 
 Dangerous Goods Safety Adviser
 1 (1%) 
 
 Dangerous Goods Auditor
 2 (1%) 
 
 Captain Helicopter
 1 (1%) 
 
 Dangerous Goods Coordinator
 2 (1%) 
 
 job seeker/homeless tenant of shelter PA
 1 (1%) 
 
 fbdf
 2 (1%) 
 
 Instuctor
 1 (1%) 
 
 Dangerous Goods Instructor
 4 (3%) 
 
 Training Manager
 1 (1%) 
 
 IATA DGR Instructor
 1 (1%) 
 
 Freelancer certified trainer and auditor
 1 (1%) 
 
 SMS & CARGO MANAGER
 1 (1%) 
 
 chief instructor-dgr
 1 (1%) 
 
 Safety Auditor
 1 (1%) 
 
 DGR trainer
 1 (1%) 
 
 trainer DG
 1 (1%) 
 
Total: 145

3. Organization:

 test
 1 (1%) 
 
 Center for Graduate and Professional Studies
 1 (1%) 
 
 Fiji Airways
 1 (1%) 
 
 Aviasecure Ltd.
 1 (1%) 
 
 Australian Industrial Training Assessing & Consulting Pty Ltd
 1 (1%) 
 
 AFP
 1 (1%) 
 
 Australian Federal Police
 1 (1%) 
 
 Emirates Technical and Safety Development Centre
 1 (1%) 
 
 United Airlines
 1 (1%) 
 
 Cantell
 1 (1%) 
 
 Swissport
 1 (1%) 
 
 KLM Royal Dutch Airlines
 1 (1%) 
 
 AIR TAHITI
 1 (1%) 
 
 Origma Global Services Ltd
 1 (1%) 
 
 Scandinavian Airlines System - SGH
 2 (1%) 
 
 LyddAir Ltd (8 staff total)
 1 (1%) 
 
 IAG CARGO
 1 (1%) 
 
 Blue Islands (Regional Airline)
 1 (1%) 
 
 Bristow Helicopters Ltd
 1 (1%) 
 
 Flybe
 1 (1%) 
 
 Royal Navy
 1 (1%) 
 
 MOD
 1 (1%) 
 
 CAA-Norway
 1 (1%) 
 
 Aviasecure Ltd., Zurich, Switzerland
 1 (1%) 
 
 United Airlines Airport Operations Training
 1 (1%) 
 
 Shane Havoc Consulting LLC
 1 (1%) 
 
 Directflight Ltd
 1 (1%) 
 
 Zambian Aviation College
 1 (1%) 
 
 The CaT Specialist, Inc. 6915 Lake Island Dr. Lake Worth, FL 33467 USA
 1 (1%) 
 
 d
 1 (1%) 
 
 dnata UK
 1 (1%) 
 
 Pathology Queensland
 1 (1%) 
 
 Copa Airlines
 1 (1%) 
 
 Direction de l'Aviation Civile Luxembourg
 1 (1%) 
 
 AAT Training hub
 1 (1%) 
 
 SafeConsult AG
 1 (1%) 
 
 Transportation Development Group LLC
 1 (1%) 
 
 Tanzania Civil Aviation Authority (TCAA)
 1 (1%) 
 
 Boryspil Airport
 1 (1%) 
 
 Atlantic Airlines
 1 (1%) 
 
 Labelmaster Services, Inc.
 1 (1%) 
 
 DGM Support (Thai) Ltd.
 1 (1%) 
 
 Civil Aviation authority of Israel
 1 (1%) 
 
 Gefahrgutbuero Weigel GmbH
 1 (1%) 
 
 Gefahrgutbuero Weigel
 1 (1%) 
 
 DHL Express
 2 (1%) 
 
 German Association for Freight Forwarding and Logistics
 1 (1%) 
 
 Civil Aviation Administration
 1 (1%) 
 
 Roadsafe Europe Limited
 1 (1%) 
 
 Behrendt Consulting GmbH
 1 (1%) 
 
 APRON GmbH - Airline Support Services
 1 (1%) 
 
 savethesituation
 1 (1%) 
 
 Leschaco Aircargo GmbH
 1 (1%) 
 
 DHL Express Slovakia
 1 (1%) 
 
 DELTA AIR LINES,Inc
 2 (1%) 
 
 CRS LLP
 1 (1%) 
 
 Shipping
 1 (1%) 
 
 Leathams Ltd
 1 (1%) 
 
 Dan Lee Training Ltd
 1 (1%) 
 
 i4Safety BV
 1 (1%) 
 
 Biocair International
 1 (1%) 
 
 Trident Safety Group
 1 (1%) 
 
 Civil Aviation Agency of GEORGIA
 1 (1%) 
 
 DSA-MTSR
 1 (1%) 
 
 RathmoreRyan Aviation Ltd
 1 (1%) 
 
 Aviapartner N.V.
 1 (1%) 
 
 BORAJET AIRLINES
 1 (1%) 
 
 DGM SUPPORT
 1 (1%) 
 
 Dangerous Goods Management Support
 1 (1%) 
 
 SAA Cargo
 1 (1%) 
 
 Instituto Dominicano de Aviacion Civil
 2 (1%) 
 
 UAE General Civil Aviation Authority
 1 (1%) 
 
 MINISTRY
 1 (1%) 
 
 Butterfly Aero Training
 1 (1%) 
 
 DGSA Ltd
 1 (1%) 
 
 INSTITUTO DE AVIACION CIVIL DOMINICANO
 1 (1%) 
 
 AIR LOYAUTE
 1 (1%) 
 
 DHL
 2 (1%) 
 
 Dangerous Goods Office, Civil Aviation Department Hong Kong
 1 (1%) 
 
 CAA Kyrgyz Republic
 1 (1%) 
 
 Peter East Associates Ltd
 2 (1%) 
 
 IFALPA
 1 (1%) 
 
 Blue Dart Aviation Ltd
 1 (1%) 
 
 KILLGERM CHEMICALS LTD
 1 (1%) 
 
 International Air Transport Association
 1 (1%) 
 
 ONUR AIR
 2 (1%) 
 
 Aeroflot Aviation School
 2 (1%) 
 
 Logistics Professionals Consultancy Ltd.
 1 (1%) 
 
 Ministry of Infrastructure and the Environment
 1 (1%) 
 
 Hongkong Association of Freight Forwarding and Logistics (HAFFA)
 2 (1%) 
 
 Finnish Transport Safety Agency, Trafi
 1 (1%) 
 
 Afton Chemical Ltd
 1 (1%) 
 
 Pegasus Airlines
 1 (1%) 
 
 Kuehne + Nagel Management AG
 1 (1%) 
 
 Lufthansa Cargo AG - Training Academy -
 1 (1%) 
 
 MNG AIRLINES
 1 (1%) 
 
 SpeedWings Aviation Academy
 1 (1%) 
 
 self employed
 1 (1%) 
 
 DGR TRAINIING SRLS
 1 (1%) 
 
 Council on Safe Transportation of Hazardous Articles (COSTHA)
 2 (1%) 
 
 DHL Aviation / DG Pro
 1 (1%) 
 
 Corendon Airlines
 1 (1%) 
 
 Mario Sommer Gefahrgutbeauftragter
 1 (1%) 
 
 Robert Jaffin
 1 (1%) 
 
 Purolator Inc
 1 (1%) 
 
 testing
 2 (1%) 
 
 SunExpress
 1 (1%) 
 
 HELISUD SARL
 1 (1%) 
 
 1
 1 (1%) 
 
 The Civil Aviation Authority of Thailand
 1 (1%) 
 
 Gerhard Amann
 1 (1%) 
 
 Khartoum International Airport
 5 (3%) 
 
 Olaz helicopters
 1 (1%) 
 
 CGPS
 1 (1%) 
 
 Gulf Helicopters
 1 (1%) 
 
 House of Passage shelter
 1 (1%) 
 
 http://www.riadazama.com
 2 (1%) 
 
 Dangerous Goods Specialists Ltd.
 1 (1%) 
 
 APS Srl
 1 (1%) 
 
 Telepathy Aviation
 1 (1%) 
 
 freelancer
 1 (1%) 
 
 TASSILI AIRLINES
 1 (1%) 
 
 air india
 1 (1%) 
 
 SHOMAS
 1 (1%) 
 
 WFS
 2 (1%) 
 
 3E Academy
 1 (1%) 
 
 Gulf Helicopter Company
 1 (1%) 
 
 AIR LINE
 1 (1%) 
 
Total: 145

4. Occupation:

 Regulator
 73 (38%) 
 
 Trainer
 66 (34%) 
 
 Shipper
 9 (5%) 
 
 Freight forwarder
 5 (3%) 
 
 Operator
 22 (11%) 
 
 Trainer/Shipper/Forwarder
 1 (1%) 
 
 Internal Auditor and Compliance Monitor
 1 (1%) 
 
 airline
 1 (1%) 
 
 Ground Handling Agent
 1 (1%) 
 
 Facilitator
 1 (1%) 
 
 DG specialist
 1 (1%) 
 
 Consultant
 1 (1%) 
 
 Training and Consulting Organisation
 1 (1%) 
 
 Dangerous Goods Safety Adviser
 1 (1%) 
 
 Pilots representative
 1 (1%) 
 
 Training Provider
 1 (1%) 
 
 Association
 2 (1%) 
 
 industry association
 2 (1%) 
 
 unemployed seeker of jobs
 1 (1%) 
 
 Packing, Training, Operations & Consultancy
 1 (1%) 
 
Total: 192

5. Country:

 test
 1 (1%) 
 
 Sultanate of Oman
 2 (1%) 
 
 Fiji
 1 (1%) 
 
 Switzerland
 5 (3%) 
 
 Australia
 4 (3%) 
 
 United Arab Emirates
 2 (1%) 
 
 USA
 10 (7%) 
 
 Denmark
 2 (1%) 
 
 Brazil
 1 (1%) 
 
 The Netherlands
 2 (1%) 
 
 French Polynesia
 1 (1%) 
 
 UK
 8 (6%) 
 
 Norway
 3 (2%) 
 
 United Kingdom
 11 (8%) 
 
 UNITED KINGDOM
 1 (1%) 
 
 Jersey (British Channel Islands)
 1 (1%) 
 
 Great Britian
 1 (1%) 
 
 United States
 1 (1%) 
 
 Zambia
 1 (1%) 
 
 d
 1 (1%) 
 
 Panama
 1 (1%) 
 
 Luxembourg
 1 (1%) 
 
 Singapore
 1 (1%) 
 
 Tanzania
 1 (1%) 
 
 Украина
 1 (1%) 
 
 Thailand
 2 (1%) 
 
 Israel
 2 (1%) 
 
 Germany
 10 (7%) 
 
 Lithuania
 1 (1%) 
 
 Slovakia
 1 (1%) 
 
 Kazakhstan
 1 (1%) 
 
 Taiwan
 1 (1%) 
 
 Ireland
 1 (1%) 
 
 GEORGIA
 1 (1%) 
 
 UK & Ireland
 1 (1%) 
 
 Belgium
 1 (1%) 
 
 TURKEY
 6 (4%) 
 
 40 countries
 1 (1%) 
 
 38 Countries Worldwide
 1 (1%) 
 
 República Dominicana
 2 (1%) 
 
 France
 2 (1%) 
 
 REPUBLICA DOMINICANA
 1 (1%) 
 
 New Caledonia
 1 (1%) 
 
 Mauritius
 1 (1%) 
 
 Hong Kong, China
 1 (1%) 
 
 Kyrgyz Republic
 1 (1%) 
 
 All
 1 (1%) 
 
 INDIA
 1 (1%) 
 
 Russia
 2 (1%) 
 
 Hong Kong SAR China
 1 (1%) 
 
 Netherlands
 1 (1%) 
 
 Hong Kong
 2 (1%) 
 
 Finland
 1 (1%) 
 
 Bahrain
 1 (1%) 
 
 Turkey
 3 (2%) 
 
 India
 1 (1%) 
 
 ITALY
 1 (1%) 
 
 head office is located in the U.S., but member companies operate globally
 2 (1%) 
 
 Deutschland
 1 (1%) 
 
 Canada
 1 (1%) 
 
 testing
 2 (1%) 
 
 NEW CALEDONIA
 1 (1%) 
 
 1
 1 (1%) 
 
 Austria
 1 (1%) 
 
 Sudan
 5 (3%) 
 
 Spain
 1 (1%) 
 
 Qatar
 2 (1%) 
 
 fbdfb
 2 (1%) 
 
 Kenya
 1 (1%) 
 
 Italy
 1 (1%) 
 
 Türkiye
 1 (1%) 
 
 Egypt
 1 (1%) 
 
 Algérie
 1 (1%) 
 
 india
 1 (1%) 
 
 Brasil
 2 (1%) 
 
Total: 145

6. E-mail address:

 test
 1 (1%) 
 
 srinisaggi@gmail.com
 2 (1%) 
 
 suliana.wesley@fijiairways.com
 1 (1%) 
 
 susann.sack@aviasecure.ch
 2 (1%) 
 
 Chris@aitac.edu.au
 1 (1%) 
 
 mary.curtin@hotmail.com
 1 (1%) 
 
 david.fuller@afp.gov.au
 1 (1%) 
 
 mwakagerald@gmail.com
 1 (1%) 
 
 bill.wojtas@united.com
 1 (1%) 
 
 mep@cantell.dk
 1 (1%) 
 
 flavio.monteze@swissport.com
 1 (1%) 
 
 dennis.kampman@klmcargo.com
 1 (1%) 
 
 bruno.quirant@airtahiti.pf
 1 (1%) 
 
 john@origmaglobal.com
 1 (1%) 
 
 Glenn.Murphy@sas.no
 2 (1%) 
 
 robing@lyddair.com
 1 (1%) 
 
 trevor.mills@ba.com
 1 (1%) 
 
 Iain@blueislands.com
 1 (1%) 
 
 paul.munro@bristowgroup.com
 1 (1%) 
 
 robert.beer@flybe.com
 1 (1%) 
 
 paul.barrott@gmail.com
 1 (1%) 
 
 spo_jayne@yahoo.co.uk
 1 (1%) 
 
 uec@caa.no
 1 (1%) 
 
 steven.d.woods@united.com
 1 (1%) 
 
 grsuthe@attglobal.net
 1 (1%) 
 
 alan.kuspert@airtask.com
 1 (1%) 
 
 johnbotha@zambiaaviationcollege.ac.zm
 1 (1%) 
 
 amx500128@aol.com
 1 (1%) 
 
 d
 1 (1%) 
 
 simon.pinnock@dnata.co.uk
 1 (1%) 
 
 Andrew.Fraser@health.qld.gov.au
 1 (1%) 
 
 hdiaz@copaair.com
 1 (1%) 
 
 gregory.delbeke@av.etat.lu
 1 (1%) 
 
 hatzgc3@gmail.com
 1 (1%) 
 
 christoph.arnet@safeconsult.ch
 1 (1%) 
 
 jim@dgtraining.com
 1 (1%) 
 
 nkomba@tcaa.go.tz
 1 (1%) 
 
 alekskor1@mail.ru, o.korniienko@kbp.aero
 1 (1%) 
 
 rob.edson@westatlantic.eu
 1 (1%) 
 
 brichard@labelmaster.com
 1 (1%) 
 
 romsai.p@dgmsi.co.th
 1 (1%) 
 
 stopperl@mot.gov.il
 1 (1%) 
 
 weigel@gb-weigel.de
 1 (1%) 
 
 schubert@gb-weigel.de
 1 (1%) 
 
 stefan.sauerbier@dhl.com
 1 (1%) 
 
 tkronenbuerger@dslv.spediteure.de
 1 (1%) 
 
 jurgita.jazdauskiene@caa.lt
 1 (1%) 
 
 info@roadsafeeurope.com
 1 (1%) 
 
 rb.consulting@gmx.de
 1 (1%) 
 
 gerster@apron.aero
 1 (1%) 
 
 eva@savethesituation.de
 1 (1%) 
 
 ulrich.sensche@leschaco.com
 1 (1%) 
 
 pavol.busovsky@dhl.com
 1 (1%) 
 
 STANLEY.L.GOODSON@DELTA.COM
 2 (1%) 
 
 andy@crs.kz
 1 (1%) 
 
 fan6537@gmail.com
 1 (1%) 
 
 pwba18848@blueyonder.co.uk
 1 (1%) 
 
 danleetraining@icloud.com
 1 (1%) 
 
 gilbert@i4safety.nl
 1 (1%) 
 
 VAW@biocair.com
 1 (1%) 
 
 rwalsh@tridentsafety.com
 1 (1%) 
 
 a.gachechiladze@gcaa.ge
 1 (1%) 
 
 DSA-DLSR-MTSR-Reg-DG-SO2@mod.uk
 1 (1%) 
 
 rathmoreryan@sky.com
 1 (1%) 
 
 Eddy.Vanderperren@aviapartner.aero
 1 (1%) 
 
 umit.cetin@borajet.com.tr
 1 (1%) 
 
 julio.bollain@dgmsupport.com
 2 (1%) 
 
 manfredrave@flysaa.com
 1 (1%) 
 
 jose.holguin@idac.gov.do
 2 (1%) 
 
 pking@gcaa.gov.ae
 1 (1%) 
 
 tmkt@udhb.gov.tr
 1 (1%) 
 
 jean-louis@butterfly-training.net
 1 (1%) 
 
 clive.savigar@gmail.com
 1 (1%) 
 
 Maria.Suazo@idac.gov.do
 1 (1%) 
 
 frederic.lahon@air-loyauté.nc
 1 (1%) 
 
 david.farla@dhl.com
 1 (1%) 
 
 fsfwai@cad.gov.hk
 1 (1%) 
 
 a.baiyshbaev@caa.kg
 1 (1%) 
 
 info@petereast.com
 2 (1%) 
 
 IFALPA.org
 1 (1%) 
 
 georget@bluedart.com
 1 (1%) 
 
 jackie.richardson@killgerm.com
 1 (1%) 
 
 mandelawye@iata.org
 1 (1%) 
 
 akocabalkan@onurair.com
 1 (1%) 
 
 skahraman@onurair.com
 1 (1%) 
 
 k4@avb.ru
 2 (1%) 
 
 charlestse@lpcl.com.hk
 1 (1%) 
 
 teun.muller@minienm.nl
 1 (1%) 
 
 michael.collins@dhl.com
 1 (1%) 
 
 training@haffa.com.hk; alice@haffa.com.hk; hilary@haffa.com.hk; edith@haffa.com.hk
 2 (1%) 
 
 senja.hakola@trafi.fi
 1 (1%) 
 
 john.horsted@aftonchemical.com
 1 (1%) 
 
 jouri.vandeplas@dhl.com
 1 (1%) 
 
 arzu.oztugran@flypgs.com
 1 (1%) 
 
 astrid.vanderburgt@kuehne-nagel.com
 1 (1%) 
 
 waltraud.hasse@dlh.de
 1 (1%) 
 
 serhat.korkusuz@mngairlines.com
 1 (1%) 
 
 kannath_mohanan@yahoo.com
 1 (1%) 
 
 graham.smith53@gmail.com
 1 (1%) 
 
 info@dgrtraining.it
 1 (1%) 
 
 amy@costha.com
 2 (1%) 
 
 mob@dgpro.biz
 1 (1%) 
 
 kibis@corendon-airlines.com
 1 (1%) 
 
 sommer.mario@t-online.de
 1 (1%) 
 
 hazmatgo@myfairpoint.net
 1 (1%) 
 
 scott.lanphear@purolator.com
 1 (1%) 
 
 testing
 2 (1%) 
 
 ferhat.yildirim@sunexpress.com
 1 (1%) 
 
 rdos@helisud.nc
 1 (1%) 
 
 1
 1 (1%) 
 
 suphakitr@caat.or.th
 1 (1%) 
 
 gefahrgut@gerhard-amann.at
 1 (1%) 
 
 tayfour@hotmail.com
 4 (3%) 
 
 j619872575@gmail.com
 1 (1%) 
 
 gdavidjune06@gmail.com
 1 (1%) 
 
 davisbaby758@gmail.com
 1 (1%) 
 
 fsdfg@protonmail.com
 2 (1%) 
 
 info@dg-specialists.com
 1 (1%) 
 
 manager@aaaps.it
 1 (1%) 
 
 cemberkayyakal@yahoo.com
 1 (1%) 
 
 neg.aviation@gmail.com
 1 (1%) 
 
 amar.rahal@tassiliairlines.com
 1 (1%) 
 
 safety@krtairport.gov.sd
 1 (1%) 
 
 bg.sawant@airindia.in
 1 (1%) 
 
 shahamj@walla.co.il
 1 (1%) 
 
 marcio.martins@grupoorbital.com.br
 2 (1%) 
 
 huseyin9dursun@gmail.com
 1 (1%) 
 
 mohamed.tayfour@gulfhelicpters.com
 1 (1%) 
 
 yachekhar@airfrance.fr
 1 (1%) 
 
Total: 145

7. 1. Overall, what is your impression of the new training provisions, competency framework and guidance material?

 Strongly unfavourable
 18 (13%) 
 
 Unfavourable
 23 (17%) 
 
 Favourable
 61 (44%) 
 
 Strongly favourable
 37 (27%) 
 
Total: 139

8. 2. How do you currently determine whether your employees are competent to perform their functions?

 The employee is tested after training and the assessment is based on 80% passing mark.
 1 (1%) 
 
 during the courses by questioning and the test
 1 (1%) 
 
 Documentary assessments and physical application
 1 (1%) 
 
 This would be for the Team leader to decide
 1 (1%) 
 
 Relying on the training matrix of categories, I dispense training as is stipulated in the table. Using continuous assessment through the course to verify understanding of the functions they are supposed to perform.
 1 (1%) 
 
 Through testing and subsequent job performance.
 1 (1%) 
 
 yearly evaluation talk
 1 (1%) 
 
 We have an training programme basead on carriers needs, involving at least the topics recommended by ICAO.
 1 (1%) 
 
 Initial and recurrent training.
 1 (1%) 
 
 Feedback, controls, audits.
 1 (1%) 
 
 Traditional training and testing
 1 (1%) 
 
 Training (function-specific, commensurate With their responsibility) Testing on above If employee makes an error on job, re-Train, re-test.
 1 (1%) 
 
 Train (function specific/commensurate With their responsibilities), Test as per above If employee makes significant error, retrain & retest, as above.
 1 (1%) 
 
 Classroom training and examination
 1 (1%) 
 
 Validation, then working with experienced collegue.
 1 (1%) 
 
 Compliance monitoring by regular auditing process.
 1 (1%) 
 
 IATA Dangerous Goods by Air courses
 1 (1%) 
 
 Training delivered at recruitment and every 24 months. Exams must be passed.
 1 (1%) 
 
 The exam set by the CAA, but the course we use has a lot of practical elements to ensure students see the wider picture of what is required by them in industry.
 1 (1%) 
 
 Final CAA examination
 1 (1%) 
 
 By checking that the DG initial and recurrent courses are done within the timeframe stated. BUT - only for operators.
 1 (1%) 
 
 Feedback from the industry, forwarders and DG Checkers at the Airport of Zurich
 1 (1%) 
 
 Lessons and assessments which are tailored to job role and functional duties. We use hands-on examples and test to real world scenarios. Electronic learning is custom made for a variety of work groups and job responsibilities.
 1 (1%) 
 
 Written test plus sample DG preparation for shipment.
 1 (1%) 
 
 classroom based bi-annual training with test.
 1 (1%) 
 
 We conduct post training evaluation
 1 (1%) 
 
 Assessment (feedback, verbal questions, written test), communication with customers in regards to compliance and procedures
 1 (1%) 
 
 Through identification by our training provider of employees needing further guidance and coaching
 1 (1%) 
 
 They sit an examination after completing the course and are required to obtain 80% to pass. Further checks are made in the workplace to ensure compliance is being maintained.
 1 (1%) 
 
 Through on-site supervision and hands-on training
 1 (1%) 
 
 Employees always start under supervision and only once their are found competent, they are released.
 1 (1%) 
 
 NA
 1 (1%) 
 
 No employees. Training and Audit activities
 1 (1%) 
 
 Testing, but much of the responsibility left up to the employer who directs their day-to-day activity.
 1 (1%) 
 
 We have a training program in place by the name INSPECTOR TRAINING SYSTEM (ITS) which is a comprehensive national training program for Flight Operations Inspectors who are also Dangerous Goods Inspectors. It is a single integrated program which provides oversight and management of inspector development from new-hire status through retirement from the Tanzania Civil Aviation Authority (TCAA). The program is systematic and structured to provide for the delivery of an effective ICAO compliant program at minimum cost. It is intended to prepare professionals from the aviation industry for their new role as Aviation Safety and Security Inspectors.
 1 (1%) 
 
 We are not currently accepting Dangerous Goods ourselves, within the airline our crews have Dangerous Goods awareness training as per the regulation, and just myself and a colleague are Category 6 trained.
 1 (1%) 
 
 Managers observe employees performing their pre-transportation functions and evaluate their competency on the job. When employee knowledge or skill level deficiencies are observed the employees are provided with appropriate support and refresher training. In some cases they are required to demonstrate the responsibilities with a more knowledgeable employee or manager until their is confidence they are capable of competently performing the applicable function.
 1 (1%) 
 
 CAAI DG Subject Matter Experts undergo ICAO DG training part 1 & 2 and OJT by existing instructor staff
 1 (1%) 
 
 all employees active in this field are trained to perform functions for all dangerous goods classes; employees are assessed by biannual training and test
 1 (1%) 
 
 I have been training employees of external companies. These employees have been assessed by biannual training and tests. We offer two different training programmes: 1. Training courses are offered to different companies with manifold activities. These courses do not relate to their individual requirements. We guess that the majority of German companies prefer this kind of training, because the departments do not employ enough staff to provide individual training > question no. 3: "No". 2. Inhouse training courses which relate to the respective dangerous goods classes handled in the company with special emphasis on the individual activities of the respective company > question no. 3: "Yes" (partly).
 1 (1%) 
 
 The determination is based on job specification, job description or hazard assessments.
 4 (3%) 
 
 Training according ICAO TI and test.
 1 (1%) 
 
 Examination
 1 (1%) 
 
 The Determination is based on Job specification, Job description or hazard assessments.
 1 (1%) 
 
 For my clients we already do a very thorough assessment for in-house training. And it´s wonderful that those requirements will now also be laid out for open DG Training courses.
 1 (1%) 
 
 The determination is based on jobs specification, job function and risk assessments.
 1 (1%) 
 
 I confirm by proficiency exercises.
 2 (2%) 
 
 As a training provider, we do not have employees per sei. Regular training and tests are provided to all relevant candidates
 1 (1%) 
 
 Risk assessment and induction
 1 (1%) 
 
 Continous assessment and setting of clear procedures and arrangements to follow
 1 (1%) 
 
 Our training will always be focussed on the job specific responsibilities. Providing the full story (Cat 6) on the subject will create a much more responsible person, instead of learning someone a trick..
 1 (1%) 
 
 Following external 3 Day IATA training course we follow our own function specific one to one training and in house competency testing based on our own criteria and job roles
 1 (1%) 
 
 Both our employees and clients receive training which focuses on the function of the regulations to decrease risk in the logistics chain, how to use the various regulations, how to apply these directly to the functions required, how to interpret and if unsure where to go to seek assistance. Our direction being, if you are unsure, don't ship until you are 100% sure.
 1 (1%) 
 
 Georgian CAA has elaborated training programmes for all employees and flight safety inspectors, including the Dangerous Goods Inspectors. Such training programmes includes the list of initial training and recurrent training as well. it also determines the list of basic, obligatory and additional training courses which the inspector/employee must pass.
 1 (1%) 
 
 CAA DG Shipper and Operator qualifications are incorporated into the trade training structure. These courses are conducted at Defence Schools (and include other relevant modal regulations pertinent to each particular trade) with rigorous written examinations on civilian regulations, and others covering additional Defence “Operator Variations”. Once training has been completed, workplace performance is monitored by Line Management and the Quality Assurance process. Any substandard work is highlighted through these avenues with either further targeted training or removal of their competency may be recommended.
 1 (1%) 
 
 My company works within the DG training scheme laid out by the UK CAA. We have no flexiblity, and must follow their guidelines (CAP 483 etc)
 1 (1%) 
 
 - Training and recurrent training every 24 months. - Evaluation on the job
 1 (1%) 
 
 Every job requires a specific knowledge and skills. And this varies depending on the type and complexity of the job.: 1- Compilation of skills and knowledge. 2- Assesser reviews. 3- Development needs. 4- The job learning.
 1 (1%) 
 
 In a way, we apply a competency based methodology, as we develop the training sessions always in a very practical way with real situations to solve and using real materials and even practices in our warehouses
 1 (1%) 
 
 In a way, we apply a competency based methodology, as we develop the training sessions always in a very practical way with real situations to solve and using real materials and even practices in our warehouses .
 1 (1%) 
 
 Job Description On the Job Customer Service Q/A according to the actual IATA DGR
 1 (1%) 
 
 por medio a evaluaciones de desempeño
 2 (2%) 
 
 In accordance with ICAO TI
 1 (1%) 
 
 According to perform the competence to the Regulations.
 1 (1%) 
 
 N/A (Not applicable) as we are a training school accredited by IATA. Note : the Survey is not adapted to DGR training schools. It seems that only DGR stakeholders are concerned.
 1 (1%) 
 
 By the demonstation of an employee to perform a specific task
 1 (1%) 
 
 Esto se hace a través de los procesos y procedimientos de vigilancia establecidos para mercancías peligrosas.
 1 (1%) 
 
 knowledge written test
 1 (1%) 
 
 Based on the training they will attend and a close follow up on the field.
 1 (1%) 
 
 The submitted training programmes are reviewed in accordance with local regulations and the provisions in T.I. Chapter 4. The core contents are verified against the subject matters with which particular categories of personnel should be familiar with as per T.I. Table 1-4. 1-5 or 1-6.
 1 (1%) 
 
 Not in full
 1 (1%) 
 
 They have to take an exam which is set by the regulator (the UK Civil Aviation Authority), and we refer them to 1.5.2.2 (b) function specific training and the equivalent reference in the ICAO Technical Instructions.
 2 (2%) 
 
 Not applicable
 1 (1%) 
 
 Only the test conducted after the category based training
 1 (1%) 
 
 In house training and check but mainly attending specific training courses provided by Cargo Training International which we find perfect for our needs and understanding
 1 (1%) 
 
 not applicable
 2 (2%) 
 
 By exam pass mark is 80.
 1 (1%) 
 
 Each trainee sits on a exam and have to score 80. We only presume that employee who achieves passing score do the job.
 1 (1%) 
 
 By assesing how study exercises, summary exercises, final exam paper are done.
 2 (2%) 
 
 Through IATA dangerous goods training programme.
 1 (1%) 
 
 With regard to the required ICAO training for DG by air, have a specific national requirements in the Netherland. All entities involved in the transport of DG by air have to certified by the AA. One requirement is that at least 2 persons within those entity involved in the transport of DG (shipper, operator), have to be trained fully according to cat 1,3 or 6. The other persons in that organization need to be trained commensurate their responsibilities.
 1 (1%) 
 
 We use required theoretical training in addition to practical "on the job" training to evaluate the proficiency of the trainee.
 1 (1%) 
 
 The cargo industry to decide based on job titles whether or not the person satisfies the prerequisites of the job (e.g., educational background, recognition of prior employment experience, skills, licenses, technical knowledge and other job-related requirements). Also by tasks and may have ad-hoc assignments for employees.
 2 (2%) 
 
 Competence check is done for operators (and designated postal operator) based on tables 1-4, 1-5 and 1-6 and compared to operators' own guidance (OM-A and OM-D) and training programme. Trafi's own staff is trained with basic knowledge depending on duties and dedicated DG inspectors with CAT 6 and/or courses for authority. During oversight spot check method will be used. Previous years joint DG audits (in Europe) have been valuable.
 1 (1%) 
 
 External training company with refresher training and exams every 2 years
 1 (1%) 
 
 Assessments during training SALT test for general awareness
 1 (1%) 
 
 Our employesss are competent to perform their functions acccordig to their categories
 1 (1%) 
 
 We prescribe a Minimum of two persons per Location to hold Cat 6, all others Cat 2, 3, 7, or 8 as appropriate.
 1 (1%) 
 
 By fulfilling all training requirements according to the IATA rules on a high quality level. Furthermore our own employees are trained in practical training sessions.
 1 (1%) 
 
 By close supervision and monitoring their work and define the job functions and assessing the staff discharge of his functions
 1 (1%) 
 
  I TRAIN MANY DIFFERENT COMPANIES- NO STANDARDISED SYSTEM XZISTS ACXREOOS ALL ORGANISATIONS
 1 (1%) 
 
 I have no employee
 1 (1%) 
 
 On the job evaluation. New staff is assigned to an experienced staff member that shows the local procedures associated with relevant job function. Attached to this is an On the Job evaluation sheet where the new member has to show competency before being signed off. This depends on there being an experienced staff member available in the organization. The courses held by me are designed to be hands on so even if no mentor program is available the demonstrated competencies during the course along with the exam is the best alternative.
 1 (1%) 
 
 We can determine with product audit process.
 1 (1%) 
 
 I´m by my self create the shippers declaration and chack the ready pakced goods.
 1 (1%) 
 
 NA I train employees of others and do not get to evaluate/observe job performance over time. The language used throughout is misleading and for that reason I cannot support program as it stands. There is a very distinct difference tween training courses and training programs, the 2nd indicates a commitment on the part of the employer to continuous oversight feedback. Training courses have to be much more limited in scope and merely demonstrate a students ability to understand the requirements at a single point in time. Separating the concept of training courses and training course content (often from an outside provider and/or from someone with very significant subject matter expertise),from training programs (which are truly an internal company policy commitments and expense.
 1 (1%) 
 
 We train our employees based on their current or sometimes future roles with the company , and provide on going support to allow the employees to build a better knowledge base. We do utilize an exam at the end of the course to qualify the employee as being trained and we use a 90% mark as a passing grade. We also recertify every year for our dangerous goods acceptance specialists. This allows us to keep our employee group up to date in this ever changing industry.
 1 (1%) 
 
 testing
 1 (1%) 
 
 By applying a multiple choice & classical type exams.
 1 (1%) 
 
 1
 1 (1%) 
 
 IATA-DGR Trainings PK 1,2
 1 (1%) 
 
 about the doucmentqation
 2 (2%) 
 
 Through perfomance apprisal, Incident and Accidents related to particular person, ability to pass training defined for the category.
 1 (1%) 
 
 http://www.riadazama.com
 2 (2%) 
 
 Operation Activity
 1 (1%) 
 
 Traditional Instructional training on Dangerous Goods with assessment based on the participants scope of work, i.e. live working practical scenario.
 1 (1%) 
 
 Employers are not fully prepared in all matters. For ex. a perfumery producer relies on approved training from third parties to understand the regulations and learn how to apply them. It is difficult to apply assessment after training, particularly in small companies where it is common that few people do all the activities in the company such as identifying, packing, issuing docs and book the transport. Being an employer I rely on the training and on it's final test. The most forgotten part is Training On the Job, which should be imposed so that new people learn-by-doing with senior one.
 1 (1%) 
 
 I've been researching of our related workers which staff need trainings
 1 (1%) 
 
 By practical evaluation
 1 (1%) 
 
 As provided in the regulations , presently it is totally based on the participants performance in the test paper. We do review and impart additional training in case the employee faces any issue in his job or if there are mistakes
 1 (1%) 
 
 Training on the system of indicative work by direct representation in the classroom and showing the practical side of dangerous goods in terms of direct dealing according to the type of job
 1 (1%) 
 
 atraves de uma avaliação com base nos conteudos abordados no treinamento
 2 (2%) 
 
 OJB training
 1 (1%) 
 
 Practical teaching system
 1 (1%) 
 
 practise
 1 (1%) 
 
Total: 127

9. 3. Are you using a competency-based approach to training and assessment as described in this document?

 Yes
 51 (38%) 
 
 No
 63 (47%) 
 
 Unsure
 21 (16%) 
 
Total: 135

10. 4. If you are using a competency-based approach to training and assessment, do you find the guidance material helpful?

 Yes
 49 (37%) 
 
 No
 23 (17%) 
 
 Not using a competency-based approach
 60 (45%) 
 
Total: 132

11. Additional comments on question 4):

 Strictly following the tables laid down in ICAO TI and IATA DGR
 1 (3%) 
 
 The competency based approach used is not in detailed as the guideline used.
 1 (3%) 
 
 But is must be clearely defined what is mandatory. the competency based Training only works for specific Trainings on one e.g. shipper. difficult to implement is a " genral" Training for e.g. shippers.
 1 (3%) 
 
 I have a plethora of shippers on any particular course, including off- shore personnel (oil and gas rigs), mostly one person from one company. Most companies have no more than two trained members of staff, including road and sea modes.
 1 (3%) 
 
 Specially for Shippers with limited DG products
 1 (3%) 
 
 Competency-Based-Training will support Safety Management System, will improve performance on job and facilitate development of effective dangerous goods training and reduces risks to the Aviation System around the globe.
 1 (3%) 
 
 We currently rely heavily on computer based training with tests. We agree the conventional approach of testing can be improved. An that assessment to demonstrate competency is more effective. Establishing the standards to support the development of appropriate assessments to ensure that personnel not only understand the subject matter involved in their job, they also have the required skills and knowledge to carry out their functions in compliance with safety standards will take time to develop and appropriate transition periods should be provided in the TI.
 1 (3%) 
 
 The guidance material is confusing. Even though the competency units provide the scope of the individual functions, it is difficult to assign the competency elements to the activities. In order to understand or apply the guidance, a safety advisor with special knowledge is required.
 1 (3%) 
 
 The guidance material isn’t comprehensive enough. We still have the same challenge with the current table 1-4 and 1-5. There is missing information on how to implement the new system and there is too much room for interpretation.
 1 (3%) 
 
 The guidance material isn’t comprehensive enough. We still have the same challenge with the current table 1-5 and 1-5. There is missing information on how to implement the new system and there is too much room for interpretation.
 3 (8%) 
 
 Yet what would be really helpful for the shipper is to keep Table 1.5.A in order to give the shipper who has no idea about the wide field of DG Training an overview of who needs to be trained. The trainer and the training companies can then implement the competency-based approach in their training and give the shipper advise on how to assess the individual employee.
 1 (3%) 
 
 The guidance material isn’t comprehensive enough. We have still the same challenge as we have with the current table 1-5 and 1-5. There is missing information how to implement the new system and there is too much space for interpretation.
 1 (3%) 
 
 It may be helpful to employers who train their own personnel, but not to a training school which does not have access to the workplace.
 1 (3%) 
 
 Already understand the needs for 30 years of all stakeholders involved
 1 (3%) 
 
 Confused by questions 3 and 4, understand that the USA can do the intial IATA training by CBTA but in the UK we cannot. Our own in house training we do following up from the initial IATA training is both one on one and competency based. I still feel strongly that the initial training should be class room face-to-face based but think that revalidation training could be easily done by CBTA and via online suppliers.
 1 (3%) 
 
 We have attended competitor training events and have invariably found that the end examinations have been far too simplified for the purposes of getting people across the exam line. This is of course a ridiculous approach and does nothing to raise standards. We operate our DG by Air training on our DGSA training model which really tests the delegates.
 1 (3%) 
 
 Scheme would help in the over 200 countries that DO NOT HAVE ANY training scheme. Very few countries make an effort to present any logical training, and rely on IATA Based training. I feel that ICAO is wasting more time, getting already operating schemes to change, but not getting the remainder of the world to do even the most basic elements.
 1 (3%) 
 
 The guidance material is not completely. There are still issues with Table 1.5 there ist a lot of information missing how to implement the new system and too much room for guesswork
 1 (3%) 
 
 sin Comentarios
 2 (5%) 
 
 N/A as we are not using a CBTA.
 1 (3%) 
 
 The actually DG training does not facilitate this approach
 1 (3%) 
 
 The new guidance material only provides a framework on competency-based approach to dangerous goods training and assessment. Compared with the existing training provision, the new guidance material does not provide information on the “depth” of training that individual personnel should receive, which could range from familiarization-level training (e.g. for Category 4, 5, 7, 8 & 9 personnel as described in current T.I. Table 1-4) to expert-level training (e.g. for Category 1, 3 & 6 personnel as described in current T.I. Table 1-4). The Hong Kong Civil Aviation Department considers that such details would be essential for the uniform implementation of the new training provision considering the diversity of the job nature of the logistics industry.
 1 (3%) 
 
 Not using a competency-based approach
 1 (3%) 
 
 The guidance material draftly is helpfull but, matrix of training elements need to be guided by samples, explanations and guideliness.
 1 (3%) 
 
 As there still a number of concerns not clearly stated in this programme leading standardization, applicability, and recognition difficulties.
 1 (3%) 
 
 The material clearly defines the intent and scope of CBT.
 1 (3%) 
 
 We prescribe the training category based on the job each person carries out. When in doubt, the next level up will be chosen.
 1 (3%) 
 
 The Guidance material would be of great assistance to the employer as well as the instructors to have a continuous assessment of the employee
 1 (3%) 
 
 However there is too much room for interpretation, and more details would be useful. As the current table only is a recommendation there is ample room to customize the provided trainings to suit the audience. The overall issue with dangerous goods trainings is not properly addressed (see Overall Additional Comments)
 1 (3%) 
 
  As noted above the failure to separate out development of formal training courses which include tools to test knowledge point in time from training programs that embrace the concept of continuous learning feedback and improvement, this comes another variation most likely to fail in the long run.
 1 (3%) 
 
 testing
 1 (3%) 
 
 1
 1 (3%) 
 
 The Guidance Materials is extremely helpful in developing CBTA, across the wide variety of people, companies, organizations etc.. in the Supply Chain, that are involved in Safe Transport of Dangerous Goods by Air.
 1 (3%) 
 
 The guidance material is very high level approach. It seems to me not immediately applicable for training design and delivery. Particularly in case of people performing more than one function and at different performance level. For ex. Packing supervisors might need to receive a different course than a new-entry packer. Will both attend a same course??? Then I see particularly difficult a mutual training recognition between different stakeholders / States etc
 1 (3%) 
 
 nao estou utlizando
 2 (5%) 
 
Total: 39

12. 5. If you are not using a competency-based approach to training and assessment as described in this document would you consider implementing it?

 Yes
 81 (72%) 
 
 No
 32 (28%) 
 
Total: 113

13. Additional comments on question 5):

 Training is more focused on the type of work you do. This will be more effective.
 1 (1%) 
 
 I am applying CBT approach
 1 (1%) 
 
 this is for T/L to decide
 1 (1%) 
 
 We would be compliant with the regulations of our competent authority. It if was mandated, we would implement it.
 1 (1%) 
 
 Impossible to assess all delegates in their workplace particularly if they were on several different rigs in the North Sea, and between companies in a 50 mile radius. What about costs to the employers of such personnel? It will work fine for an airline or a consolidator.
 1 (1%) 
 
 For small operators like ourselves the vast majority of the material required to be covered is just not relevant; the move to actually dealing with subjects that are relevant would be welcome however I am seriously concerned regarding the over zealous implementation that may be applied to this by UK CAA.
 1 (1%) 
 
 Would be difficult to implement as an airline we deliver training all over the globe. Competancy based assessment would be almost impossible to regulate if it was not classroom based.
 1 (1%) 
 
 We are a small regional operator so we have people fulfilling several roles across the company. It would be advantageous to have specific tasks trained for to ensure maximum efficiency.
 1 (1%) 
 
 it would be almost impossible to assess aircrew on DG.
 1 (1%) 
 
 A competency approach to training would be of great benefit it allows trainers to focus on student need and ensure ability in there employed role.
 1 (1%) 
 
 I feel this would give the students a lot more confidence to go out and do their job.
 1 (1%) 
 
 The competency based training will ensure that the trainees are able to put what they are taught in practice
 1 (1%) 
 
 We would consider it, but only if it becomes a regulatory requirement or if the competency-approach is achievable within reasonable timescales and without excessive impact on the operation.
 1 (1%) 
 
 Competency would be simulated and most probably using an on-line tool.
 1 (1%) 
 
 Probably if it is required
 1 (1%) 
 
 Yes, as long as the market will follow along, we'd love it. Shippers and customers in general only allow us a fraction of the time we need to provide adequate instruction, so we have to make do as best we can and put the onus on them as employers to ensure their employee is doing their job correctly. With this type of a framework we can say -- here, you HAVE to use this type of approach and hopefully they'll give us the time we need to really do the job of training.
 1 (1%) 
 
 Competency-Based-Training will reduce risks to the Aviation System.
 1 (1%) 
 
 Our own exposure to Dangerous Goods means that competency based approach would not be suitable.
 1 (1%) 
 
 It is not clear why this efforts wouldn't apply to all modes of DG transport and why the UN TDG SC is not leading this effort.
 1 (1%) 
 
 Additional guidance on how to transition from current approach to competency based approach is required for both operators and regulators.
 1 (1%) 
 
 All training programmes would have to be re-written, which requires an enormous amount of human and administrative resources.
 1 (1%) 
 
 All serious working companies are interested or should be interested in ensuring that their employees and the appropriate training requirements fulfil legal and practical needs. Therefore we believe that all operators already have something adequate in place to ensure compliance and effectiveness.
 5 (7%) 
 
 Implementation only if the requirements will be changed.
 1 (1%) 
 
 All serious working companies are interested or should be interested to ensure that their people and the appropriate training requirements fulfil legal and practical needs. Therefore we believe that all operator have already something adequate in place to ensure compliance and effectiveness.
 1 (1%) 
 
 To provide CBT in a training establishment, certain equipment and materials must be used. Considerable expense would be required for this.
 1 (1%) 
 
 The problem with competency assessment is who will do the assessing? I am a trained assessor and training content professional - the problem is that you will appoint unqualified assessors to determine whether the person is competent - this is a recipe for conflict and will undermine what you are trying to achieve
 1 (1%) 
 
 if trainers need this information only now, what have they been doing all that time...
 1 (1%) 
 
 Our courses give a grounding in all 9 UN Classes because personnel may be expected to Ship or handle any Class. The current system teaches and trains in regulatory requirements then continuation training/mentoring at the working unit provides further training and exposure of personnel engaged in the particular requirements of that working post. It would not be practical or feasible to introduce such an inflexible competence based approach to training in place of the current regime; there are too many variants of class combinations for specific personnel to be trained, tested and assessed in those combinations.
 1 (1%) 
 
 Does China bother to follow any rules regarding training, and do the USA intend to follow a world plan, or simply insist on 49CFR to be used. If these two countries do not change, what will ICAO acheive.
 1 (1%) 
 
 it is not clear for me who decides the minima for every specific job. F.e. staff accepting DGR - do they really need to know how the classification is done? They are not allowed to open DGR packages and are completely independant on the Shipper's info. Of course they should know the differences for each class, but how far do we need to go?
 1 (1%) 
 
 -What about the continuation of the category scheme? -Problems for organizing trainings to smaller agents -We should assess the value of understanding the rules you have to apply globally (considering the full process)
 2 (3%) 
 
 Every company should have somethign similar in place. But an internal quality assurance should not be the start of a training, rather then what comes afterwards. Internal follow ups, updates etc.
 1 (1%) 
 
 sin Comentarios
 2 (3%) 
 
 Pending further deliberation by ICAO and Industry at this time.
 1 (1%) 
 
 We would implement CBTA as soon as ICAO will implement the new rules.
 1 (1%) 
 
 Being an internal training for my organization, the implementation would not be so challenging and follow up also.
 1 (1%) 
 
 Although substantial amendment is required.
 2 (3%) 
 
 See overall comments
 1 (1%) 
 
 In past I have found this approach to be unhelpful (NVQ style) and does not deliver appropriate skills. We are unlikely to have the time to justify the required approach. Currently a training course outside the organisation is justifiable to Directors.
 1 (1%) 
 
 As a training provider, the approach to implement competency based training will be to research and develop complimentary digital learning tools that will allow to program the training and the assessment to the job functions. One example will be a simulation tool to simulate complete scenarios for each of the competency unit that will be programmable to customize to different job functions and responsibilities
 1 (1%) 
 
 While implementing competency based approach I need to be checked that I m doing correct thing.
 1 (1%) 
 
 I would like to use competancy-base training but I find rather hard to use the matrix.
 1 (1%) 
 
 We implement this approach in the training programs
 2 (3%) 
 
 We will consider to implement this programme until all the concerns and unclear areas are clarified.
 1 (1%) 
 
 We are currently considering on howe we could implement this training approach
 1 (1%) 
 
 Because there are a lot of issues not yet resolved such as: 1. It is not widely recognized by employers of such approach in Hong Kong, hence no effective use of competencies underpinning training. 2. There is no recognized mechanism to check functional areas and levels of tasks/qualifications possessed by employees. 3. There is no subsidy for launching these initiatives. 4. There is no clear progression pathways whereby employees may draw up their own career development plans.
 2 (3%) 
 
 Basically the new guidance is good, but it gives no or only little help for authority to evaluate the training programme or determine if training is enough for each employer or group. Most of the guidance text is only general information for the competency based training purpose and not giving any standard type information. The quality of programmes will be very dependent on CAA inspector doing check/approval or acceptance with result that the general level of competence will probably vary a lot in or between each state.
 1 (1%) 
 
 Since most people working with DG in the transport chain are not from academic backgrounds trainings must be made more hands-on with physical exercises rather than traditional “PowerPoint” presentation.
 1 (1%) 
 
  Again the answer is driven by the existing language and approach as distinct from the underlying concept. I have essentially developed “courses” based primarily on “ competency” within much narrower bands of employees separating out the C suite from top management 1st line supervisors and various job functions within a large functioning organization
 1 (1%) 
 
 testing
 1 (1%) 
 
 1
 1 (1%) 
 
 Already considering the Competency based approach.
 1 (1%) 
 
 The current format of training is good for small operations. The training could be outsourced. The current format forces small operators to develop a plan specific to the operation and this is going to be an additional burden.
 1 (1%) 
 
 We are currently working on design, development, implementation and testing of the CBTA based on the broad Job Functions of participants involved in the Safe Transport of Dangerous Goods by Air.
 1 (1%) 
 
 If this is mandatory
 1 (1%) 
 
 nao estou utlizando
 2 (3%) 
 
 I would like to use a competency-based approach to training and assessment,
 1 (1%) 
 
Total: 67

14. 6. Do you consider the removal of Tables 1-4 and 1-5 appropriate, given the rationale provided in Section 2.5.1 of the guidance document?

 Yes
 51 (38%) 
 
 No
 53 (39%) 
 
 Unsure
 32 (24%) 
 
Total: 136

15. Additional comments on question 6):

 Tables 1-4 and 1-5 must remain. DGP should consider combining certain categories. For example - Categories 1, 2, 3 and 6 have most of the topics in common. Since Category 6 is the most stringent these four categories can be clubbed into one single category. Likewise Categories 4,5,7 and 8 and Categories 9,10, 11 and 12 can be clubbed into single categories. This will make things way more easier.
 1 (2%) 
 
 Agree , we do find the titles at work tend to direct the person to the type of training.
 1 (2%) 
 
 I believe that they should be retained as supplementary guidance
 1 (2%) 
 
 With the categories gone, my challenge is knowing what the certification will be called. Will it be a block certification ie Dangerous Goods Regulations Certified or For example if it is a person who is in the oil and gas industry, shall it be called say, Dangerous Goods Regulations for oil and gas?
 1 (2%) 
 
 Operators rely on the structure of the tables. They provide a benchmark with which we can evaluate another operator against to know if their training meets the needs of our enterprise. Knowing that they have met all the requirements established in the tables for a particular job function, the review process is easier and the differences training can be standardized for all entities that are in line with the tables.
 1 (2%) 
 
 it's good to keep as a guidance
 1 (2%) 
 
 Table 1-4 and 1-5 provide a form of guidance and structure. CBT may identify may be a few more roles / tasks.
 1 (2%) 
 
 Shippers are not sufficiently catered for.
 1 (2%) 
 
 IATA Table 1.5A important platform for DG training – please do not remove! Yes, it’s based upon categories…..BUT also “function-based” and “commensurate with their responsibilities”, which in essence is already CBT! So, again, why change it? If IATA table 1.5.A (which is “official” basis/platform for building DG training) is removed, what will then be the substituted “official platform?” What will become the ICAO/IATA basis platform for holding a DG course? Who will decide that? Different countries have different standards as we know. With Table 1.5.A all have a guide. Removing table 1.5.A will allow for further diversification and differing understanding of which are the main foundations to be trained in. Given a difference of opinion, it has always been helpful to go back to the table to find these foundations. Without the table, it is up to schools to find their own, with all the misinterpretations that can cause/contribute to. We hear much talk of stream-lining a course to make it leaner/more specifically about what must be done. Is it not important to know why it is to be done, how it is done etc? Therein lies another problem because a company often loses out financially on training staff. Ticking a box is often the main aim and the training without an “official platform” to be adhered to will risk being watered down and totally non-standardized! Standardized training is what we have been working towards in IATA for many, many years. (Ref. IOSA/ISAGO).The risk of losing what we have achieved worries me greatly. Lastly, table 1.5.a affords a total “overview of the regulations”. Using all aspects of the table in training, to build a function-specific course which also ensures the person’s responsibilities are covered, gives a more complete understanding and appreciation of the risks involved with DG.
 2 (3%) 
 
 Yes; this matter should reflect the training needs of small carriers and airports; the job titles could be drawn from: DG specialist Aerodrome Manager Pilot in Command All other staff
 1 (2%) 
 
 They are a useful guide to skills expected for the roles so if they are replaced, the replacement needs to be as informative or provide greater information.
 1 (2%) 
 
 This provides a training enviroment which focuses on the students need and gives them competancy in there area of work, it also allows individuals to build a protfolio of skills and abilities.
 1 (2%) 
 
 This would help the trainers to train more to the needs of the students.
 1 (2%) 
 
 Very helpful to avoid " Overkill " in regular Trainings with the effect of poor aceptance by the participants
 1 (2%) 
 
 That could create a wildly different standard by which to audit, both from internal and external auditors.
 1 (2%) 
 
 this would help as one size does not fit all!!
 1 (2%) 
 
 This changes focus from just theoretical knowledge to actual practice competency
 1 (2%) 
 
 I believe the tables do provide some benefit and do still allow the adaptation to make the training commensurate with responsibilities.
 1 (2%) 
 
 There are many Levels of workers who will require different topics to apply in their jobs. Good to identify the Categories.
 1 (2%) 
 
 Table 1-4 and 1-5 are job specific.
 1 (2%) 
 
 The tables present clear cut requirements - if your job titel is A, undego category B training. These can be followed by operators and regulators. The new competency framework needs to achieve the same level of detail. What's missing is an ICAO recommendation on the knowledge needed for each CE - a sample filled knowledge / CE matrix, from which an operator / regulator can branch out and expand. Also, the training industry needs to adopt and adapt - offer training courses based on CUs and CEs.
 1 (2%) 
 
 The current tables clearly state the training contents and the respective responsibilities; any specialisation of knowledge of the employees should only relate to the restriction to certain dangerous goods classes
 1 (2%) 
 
 For the courses which are offered for different companies, the new competency-based training seems difficult to be applied. The new system consisting of the competency framework is too detailed. The tables used so far define clear training contents. The development of training programmes and the assessment cannot be done by employers since this knowledge cannot be expected or is limited.
 1 (2%) 
 
 Because the rationale as given in 2.5.1.1 still gives room for interpretation and is partly not giving the real facts e.g. contending that training is or was based on a job title. The regulations and the appropriate references as already given in ICAO TI Chapter 4 – 4.2 stating exactly what is required – training commensurate with the particular job junction and its responsibilities.Therefore we need table 1-4 and 1-5 to have a clear understanding of the legal requirements given by the book. We may add some more practical exercises but this is another question and does not validate that the current way of training bears risks which could be overcome by changing the whole training concept.
 4 (6%) 
 
 Yet what would be really helpful for the shipper is to keep Table 1.5.A in order to give the shipper who has no idea about the wide field of DG Training an overview of who needs to be trained. The trainer and the training companies can then implement the competency-based approach in their training and give the shipper advise on how to assess the individual employee.
 1 (2%) 
 
 because the rationale as given in 2.5.1.1 gives still space for interpretation and is partly not giving the real facts e.g. to contend that training is or was based on a job title. The regulations and the appropriate references as already given in ICAO TI Chapter 4 – 4.2 stating exactly what is required – training commensurate with the particular job junction and its responsibilities. Therefore we need table 1-4 and 1-5 to have a clear understanding of the legal requirements given by the book. We may add some more practical exercises but this is another question and does not validate that the current way of training bears risks which could be overcome by changing the whole training concept.
 1 (2%) 
 
 The tables give a minimum requirement for each category. This is usually followed by employing companies, to the letter, in order to reduce costs. Leaving the employer to decide what is required is a direct route to non-standardisation and even less training. Employers will always do what is most cost effective (minimum) and are usually totally unsure of what subjects they actually need to be training in. This has already been demonstrated in the IMO DG system.
 1 (2%) 
 
 gives a better summerization of the training components
 1 (2%) 
 
 It appears to me that many training organisations offer to get delegates certified with little thought as to how they actually do their job when they get back to their day jobs. We see this all the time with shippers who have no idea how to complete Declarations, how to spot problem shipments and the first time their knowledge is actually tested is when a GHA rejects the shipment. Scatter gun approaches do not work with such a detailed piece of legislation.
 1 (2%) 
 
 Tables 1-4 and 1-5 provide industry wide guidance for DG training. Without them DG training could become role specific with potentially huge variations in levels of training. This could result in personnel having to undertake in depth training every time they move to another posting, and will lead to an overall reduction in the standards of DG training. The Tables are an easy way of understanding the level of training expected by personnel employed in the wide variety of roles within an air environment.
 1 (2%) 
 
 These tables never suited a training scheme, but helped to set planning up.
 1 (2%) 
 
 We need Table 1.5A since training is not based on a job title, but on a job responsibiloity. Table 1.5A shouild be more precise and praqctical exercises should be added. Also it should be much more praxis oriented
 1 (2%) 
 
 sin Comentarios
 2 (3%) 
 
 See Q5 'Additional Comments'
 1 (2%) 
 
 It is true that Tables 1-4 and 1-5 in the current Part 1;4 do not support a Competency -based approach. Nevertheless "the function approach" has to be clarified. It will be difficult to organize as it is said "the person's training must adress all of the functions performed".
 1 (2%) 
 
 Yes the existing tables are too prescriptive and lead to "training to pass a test" rather than to the operatives actual function
 1 (2%) 
 
 The removal of Tables 1-4 and 1-5 will not be appropriate given that the scope and depth of the training required by the different Categories of personnel are non-identical, particularly for Category 4, 5, 7, 8 and 9 personnel who are involved in handling cargo other than dangerous goods. Our experience indicates that Tables 1-4 and 1-5 enable the uniform application and implementation of the related training requirements. Therefore, it is the view of the Hong Kong Civil Aviation Department that Tables 1-4 and 1-5 should be retained until clearer guidance on competency based training is available providing a direct mapping of the scope of training required by the different Categories of personnel under the competency based scheme. In other words, ICAO should provide a “Conversion Table” to map and indicate the required competency units / elements (as a minimum) that each category of personnel should attain.
 1 (2%) 
 
 I understand the reasoning for the removal of the tables, but it is relatively easy for people involved to work out the topics that have to be covered in dangerous goods training. So, a packer (Category 2) is likely to need the topics outlined, and one could always add or take away modules if the basic list is incorrect.
 2 (3%) 
 
 Competency Units do not cover the whole range of possible events that may face pilots. In addition, some competencies listed are performance criteria, while safety considerations would look for expected behaviours. See overall comments for details
 1 (2%) 
 
 Because Tables 1-4 and 1-5 are vital for to determinate minimum training subjects.
 1 (2%) 
 
 Category table provides basic knowledge at the moment and an Instructor is free to richen the subjects with material she/he use. Now Instructor is completely free to design the course but there is no control line. There may be minimums for the categories/jon titles.
 1 (2%) 
 
 Our opinion is that Tables 1.5A and 1.5B should remain in use as at our training centre their use is considered recommended, not mandatory. As an example for training personnel of Categories 7, 8, 9, 10 and 11 we cover Classification and General Packing Requirements though for these categories these topics are not in the Training Curricula.
 2 (3%) 
 
 Old tables give basic lines what you could expect to see when approving training programmes and they give frames for general training package. We understand that the proposed new Chapter 3 gives good details for the training. The text in 2.5.1 is already described as condensed in 4.1 and more or less the content is clear enough.
 1 (2%) 
 
 Given the rationale yes, however we do not support it.
 1 (2%) 
 
 Replacement of current provisions of DGR 1.5 and new Training Requirements to be added in TI's of 2017-2018 as supplement Edition- Chapter 5 & attachment
 1 (2%) 
 
 We agree that, as stated in 2.5.1.1, “…personnel must be trained in the requirements commensurate with their responsibilities. Responsibilities are not necessarily category- or job- specific as indicated in Tables 1-4 and 1-5 in Part 1;4 of [the 2017-2018] edition of the Technical Instructions. …[E]ntities must train their personnel commensurate with their responsibilities and the functions they perform regardless of their job title.” Also as stated on the ICAO website, “The current training provisions in the Technical Instructions require employees to be trained commensurate with their responsibilities. … While these tables [1-4 and 1-5] are intended as guidance, they are often considered as mandatory requirements which contradicts the overarching principle of ‘commensurate with responsibilities’.”
 2 (3%) 
 
 There still needs to be an MTL (Minimum Training List) depending on the function you have in the safety chain. Chapter 4 – 4.2 clearly state that training must commensurate with personnel responsibilities. That gives enough room for the trainer to adopt is training. In-house training has an easier way of customizing the training to accommodate the specific requirements of their internal policy and procedures. 3rd party trainer will have to focus more on “general” Dangerous Goods competencies as the individual participants “on the job” requirements will vary. I had 12 nationalities on my last course from 8 different locations but I feel content with that after passing my course they will be equipped with adequate competencies to function as a safety filter for aviation as the course intend them to be.
 1 (2%) 
 
 The new templates sound like they will become the equivalent of the current tables and since titles versus job functions versus specifics of individual with the title: the question the approach is articulated in the documents put forth so far. Appropriate templates that are narrowly enough focus can be put together to fit each individual's role but that requires an investment in time and perso This scheme to work very narrow and specific tasks need to be templated but they should not necessarily be called functions. Notice we are back to using much more precise and correct language skills to articulate both the concept and the specifics of this new program.l that I do not believe most entities are actually willing to commit to Large amount of investment required in terms of personnel time and dollars.
 1 (2%) 
 
 i do not believe that the tables would necessarily need to be removed, however they should be clearly identified as a guide line only, and that additional training may be required based on the actual role that each employee performs on a daily basis.
 1 (2%) 
 
 testing
 1 (2%) 
 
 1
 1 (2%) 
 
 Table 1-4 & 1-5 was more theoretical and not practical, leading to a final test. The Categories were making participants too comfortable in their roles(title) and not conducive to the appropriate Job Functions. The Tables can be used as a reference guide to the determination of personnel required.
 1 (2%) 
 
 Tables 1-4 and 1-5 have been used for decades as a benchmark and they were much simpler than the new approach. Unless countries will approach together the change and choose common minimum, common point of references, the worldwide scenario may be very unstable when referring to the safety part of training in dangerous goods transportation: If a person only issues DGD, shall he/she really be trained on the only performed function??? What about the logical link between functions and their result on shipments???
 1 (2%) 
 
 Removing it at the present time is not appropriate, so that many employees have not heard of it or some Instructor's have not tried it and put it to all operators
 1 (2%) 
 
 sim super apoio pois assim treinamos os colaboradores diretamente sobre o tema que esta inserido no dia a dia deles, evitando passar conteúdo desnecessário
 2 (3%) 
 
Total: 64

16. 7. Are the roles and responsibilities in a competency-based approach to training described in Section 2.6 of the guidance document clear to you?

 Yes
 96 (72%) 
 
 No (please elaborate)
 38 (28%) 
 
Total: 134

17. If no on question 7), please elaborate:

 it seems you have to purchase the guidance materials, they were not available for review.
 1 (2%) 
 
 They are clear however additonal roles may be needed. It would be good to have a mandatory structure for this from ICAO so across the world this may otherwise differentiate from State to State.
 1 (2%) 
 
 XXXXX
 1 (2%) 
 
 rather complicated but comprehensive
 1 (2%) 
 
 From our perspective I am unsure the competency based approach can be utilised with nothing to measure against
 1 (2%) 
 
 No, I believe further consideration is needed. The guidance was not coordinated with professional industry trainers. A workshop or working groups inviting both regulators and professional DG trainers should be scheduled to improve the requirements and guidance.
 1 (2%) 
 
 the framework is complex and detailed. ICAO-led training on the new training requirements, framework, and transition process will help with implementation on both regulators and operators side
 1 (2%) 
 
 If an employee only issues DGDs and is only trained for this activity, how can they fulfill their shipper's responsibilities and sign the certification statement on the DGD ("I hereby declare that...") if they don't have the required knowledge to ensure the packing requirements (packing instruction, limits per package)
 1 (2%) 
 
 It is not clear how the regulator will assess and approve training progresses. How can the competent authority ascertain the validity of delivered data? Also missing are the competency criteria for the regulator resources, assessment and times. It is not clear who will be competent to do the necessary assessment and how the authorities will validate this assessments. The introduction of employer, trainee and instructor is very positive.
 5 (11%) 
 
 most employers have no possible means of implementing such processes, so none will be put in place, and no training will be given.
 1 (2%) 
 
 Thank you very much for the immense amount of work you put into this! I think it really covers the transport chain and responsibilities very well and gives a clear overview on who is responsible for what and who needs to have which competencies in order to do his/her job.
 1 (2%) 
 
 Not clear how the regulator will assess and approve training progresses. How can the competent authority ascertain the validity of delivered data? Also missing competency criteria for the regulator resources, assessment and times. Not clear who will be competent to do the necessary assessment and how the authorities will validate this assessments. Positive is the introduction of employer, trainee and instructor.
 1 (2%) 
 
 Leaving the employer to decide what is required is a direct route to non-standardisation and even less training. Employers will always do what is most cost effective (minimum) and are usually totally unsure of what subjects they actually need to be training in. This has already been demonstrated in the IMO DG system. The CAA of many countries do not have the resources or the experience to implement this, they struggle with the present system of approving training organisations, due to their lack of skill, resources and experience in the subject.
 1 (2%) 
 
 Yes, crystal clear.
 1 (2%) 
 
 By its very nature competency based training (or a skills lesson) is a more “labour intensive” method of instructional delivery than the current “facts” style. From an instructional point of view – far fewer would be trained, or, many more instructors would be required. In addition there is a limited number of locations that CAA based instruction is given, these would not be able to cope with the longer courses and, not all are located within a flying station environment with a “workplace” to hand that could be used for training purposes.
 1 (2%) 
 
 If assement is to be used, how many countries have competant asserors in place already. Who will decide what skills are need, or indeed the time frame for completion?
 1 (2%) 
 
 See Q5. Who completes the framework? IATA, ICAO or can it be done locally?
 1 (2%) 
 
 But the employer and regulator responsibilities are going to be difficult to implement
 1 (2%) 
 
 But the employer and regulator responsibilities are going to be difficult to implement.
 1 (2%) 
 
 It is noit clear how the regulator will asess and approve training progresses. How can the competent authority ascertain the validity of data? As well missing are the competency criteria for the regulator ressources, assesment and times. It is not clear whol will be competent to do the necessary assesment, and how it will be validated.
 1 (2%) 
 
 sin Comentarios
 2 (4%) 
 
 Roles and Responsibilities : Employer : his tasks are significant. He must sign off a TNA (Training needs Assessment) for each of his employees, establish an updated training program, He has to acquire specialized knowledge and skills required to perform his responsibilities. Instructor : is it correct to understand that the instructor must have heoretical and practice (on ther job training)? Trainees : paragraph 2.6.3 is constructive Regulator : their role describded in § (2.6.4.2) is theoretical. It has to be much more precise.
 1 (2%) 
 
 Yes but the role of the freight forwarder warrents a defined Competency Unit
 1 (2%) 
 
 Pilots responsibilities during the flight go far beyond their duties as trainees, and should be specifically addressed. See overall comments
 1 (2%) 
 
 Unnecessarily complex
 1 (2%) 
 
 most of it yes, but there are areas that there are gaps: • General training requirements or subjects are not defined. There is an introductory part of a training that is a common ground to all competency units. (General philosophy, limitation etc.) • Job functions (previously “categories”) are not clearly defined from the competency units. In fact functions such as security screening staff, cabin crew are missing from the CU as provided.
 1 (2%) 
 
 Reference Chapter 3 PANS TRG is very complex and the subject of document is Multi Pilot Licence Training, its hard to adapt to DGR regulations. Such document need to be ıssued for DGR Regulations as an guidence for competency-based approach.
 1 (2%) 
 
 It is rather concised document. It refers to PART-TRG Chapter 3. It is for pilot licence training.
 1 (2%) 
 
 Section 2.6 is not found
 2 (4%) 
 
 1. In terms of role, clear to a certain extend but we believed some of them are wrong and not practical for employers to do so. 2. In terms of responsibilities, it said “Employers should ensure that training is designed and developed to establish clear links among the competencies to be achieved, learning objectives, assessment methods, and course materials.” is too big a responsibility and not clear of how employers could ensure such a long list of responsibility.
 2 (4%) 
 
 2.6.1.1 Unclear how the word “need” should be taken compared to shall/must/should. Not sure what is meant by "the clear links" among the competencies to be achieved etc. and how these links would be ensured. 2.6.4.1 General text, not answering the question, neither defining the role of the authority. 2.6.4.2 Quite a huge task to ensure that the training programme produces personnel the information they are able to perform their DG functions when no actual level is defined or the level maybe be quite different within operators and in different states. Implementation options seem very broad or liberal on authority perspective.
 1 (2%) 
 
 Although there is a LOT to read.
 1 (2%) 
 
 no clear enough - too general
 1 (2%) 
 
 Do small scale operations possess the resources to fulfil 2.6.1? If not can a 3rd party provider gain access to evaluate its effectiveness? 2.6.4 Will put a lot of pressure on the regulator. Do they have the time and resources to do this competently? What are the competencies required for the regulator to do this. This has to be defined so that the oversight is done in similar fashion by different regulators. There are too many different interpretations and local regulations today, the competencies of regulators vary too much as well, I don’t see that changing with this approach.
 1 (2%) 
 
  At the present time I do not have access to the document but I suspect my answer would be no
 1 (2%) 
 
 testing
 1 (2%) 
 
 1
 1 (2%) 
 
 to stablished the list or guide for competency based
 2 (4%) 
 
 Where should we fix role but overall the responsbilities of a person in cargo booking? where for security personnel/screeners? where for freight forwarders, particularly the responsibilities???
 1 (2%) 
 
Total: 47

18. 8. Is there anything you think should be added to the competency framework provided in Chapter 3?

 Yes (please elaborate)
 44 (34%) 
 
 No
 87 (66%) 
 
Total: 131

19. If yes on question 8), please elaborate

 it seems you have to purchase the guidance materials, they were not available for review.
 1 (2%) 
 
 Provision for small carriers
 1 (2%) 
 
 Additional guidance on the requirements for instructors to demonstrate their competancy
 1 (2%) 
 
 I would like to see a standard test for core competency. Then we can use function specific training for individual responsibilities
 1 (2%) 
 
 Probably add an OJT element at the end of the training
 1 (2%) 
 
 More emphasis on detection of hidden shipment including screening or physical verification of items involved More emphasis on compliance by customers with different levels of pre-knowledge and consequences of non-compliance
 1 (2%) 
 
 Apparently the students will need to have a basic UNDERPINNING KNOWLEDGE (UK) before performing a CE. Good to introduce UK to every CEs.
 1 (2%) 
 
 will need to comment more on this later. need to save this survey to finish later.
 1 (2%) 
 
 Not sure at this time
 1 (2%) 
 
 The notified body (regulator) should keep assessing and approving training programmes and trainers. The development of training programmes and the assessment cannot be done by employers since this knowledge cannot be expected or is limited
 1 (2%) 
 
 Depth of contents. The current recommendation is incomplete: For example the Competency Elements and Performance Criteria are very vague. Furthermore some of the today’s training topics are not covered in Competency Units such as the current forwarder roles. What is really needed is a unified training requirement and not a requirement individually adjusted by each country concerning own criteria and timeframe of particular training modules.
 5 (11%) 
 
 Scrap the whole idea.
 1 (2%) 
 
 It would be helpful to get an indication from ICAO that within a course individual differentiated topics and exercises to acquire the needed competencies may be used. And that the training company and the trainer in consultation with the shipper develop materials and tests to cover the specific topics for employees of different companies in one course.
 1 (2%) 
 
 Intensity/deepness of contents. The current recommendation is incomplete: For example the Competency Elements and Performance Criteria are very vague. Furthermore some of the today’s training topics are not covered in Competency Units such as the current forwarder roles. What is really needed is a training requirement to be followed the more or less the same way globally and not again something which is built the way that each country is allowed to defined their own criteria and timeframe for each particular training module.
 1 (2%) 
 
 I do believe much more should be added, however too early to elaborate.
 2 (4%) 
 
 An ICAO requirement for employers to employ professional training staff or contract them in
 1 (2%) 
 
 A recognition that all shipments will start with a road section - this is invariably where the compliance issues start and need to be addressed - just training the IATA requirements limits the true scope of dangerous goods shipments
 1 (2%) 
 
 There is little attention given (for some groups) to the performance standards of packagings. Actually DGR should mention that UN spec packages can only be used according to their testreports...
 1 (2%) 
 
 Clear instruction as to what is considered a UN approved packaging is vital. We know of many shippers who think they can buy a Fibreboard box and basically pack anything into it. Clear instruction is vital.. when is a 4G not a 4G ? We spend a good bit of time on standards for packaging, marks and labels.
 1 (2%) 
 
 The competency framework is very comprehensive and in effect provides, Training Objectives/Enabling Objectives/Key Learning Points for any DG training.
 1 (2%) 
 
 You must be joking - elaborate what - is this another case of an ICAO meeting IDEA, with no one having any hope of actually knowing what is needed?
 1 (2%) 
 
 What about multimodal situation?. Competency can not be separated easily as many functions are common
 1 (2%) 
 
 What about multimodal situation?. Competency can not be separated easily as many functions are common.
 1 (2%) 
 
 Depth of contetns Training topics of today are not covered in some competency units, e.g. current forwarders role. We need a worldwide unified training only divided by job functions
 1 (2%) 
 
 The framework is very extensive. It could be useful to add Competency elements dedicated to radioactive materials and lithium batteries.
 1 (2%) 
 
 Yes as in Question 7 the Freight Forwarder undertakes Verification of Packages and Documents as well as completion of the AWB. A seperate Competenvy Unit for processing aircargo and checking for hidden and undeclared should be included
 1 (2%) 
 
 As commented in Question 4 above, the competency framework provided in Chapter 3 does not differentiate the “depth” of the scope of competency that individual personnel should attain. Such depth of training should be appropriate to a person’s job functions (e.g. cabin crew VS cargo acceptance staff), and could range from familiarization level to expert level training. More information / guidance should be provided in this aspect. The provision of a “Conversion Table” as suggested in Question 6 is recommended.
 1 (2%) 
 
 See overall comments
 1 (2%) 
 
 See previous point 7
 1 (2%) 
 
 Need to be determinte minimum competency based subjects for each function and job descriptions.
 1 (2%) 
 
 I can not transfer any practics from that document to DGR training. On the other hand providing clear guideline it will be more usefull.
 1 (2%) 
 
 Additional information /guidance on when persons moving to a function that is slighty different. When do they need to be retrained. Guidance on how to implement this approach for small shippers and that it is still economical feasible. How to deal with the current large training organizations that have now mixed groups of people all with different functions. Will there be guidance for States on how the approve CBT programmes.
 1 (2%) 
 
 General requirements and legislation when transporting DG (TI, operational requirements (Annex 6, in EU EASA OPS), etc.); Responsibilities of operator, shipper, etc. From SMS point of view the profile of reporting (what, how, when, etc.) too low. It could be under separate CU.
 1 (2%) 
 
 If anything, it needs to be made simpler.
 1 (2%) 
 
 Specific UN numbers for shippers (i.e. Perfumes or Lithium batteries) should be taken in account
 1 (2%) 
 
 Further detail is needed. I feel that this opens for too much interpretation, and I fear that the trainings provided will have shortcomings as a result of individual interpretation. If an employer can get away with less but still be legally compliant then that sets the bar. Unless forced to it will not happen. What is really needed is a training requirement to be followed the more or less the same way globally and not again something which is built the way that each country is allowed to defined their own criteria and timeframe for each particular training module.
 1 (2%) 
 
  I would need an opportunity to review the material again before I can provide meaningful commentary.
 1 (2%) 
 
 testing
 1 (2%) 
 
 1
 1 (2%) 
 
 Clear criteria for Flight Crew Members and Crew Members (other than Flight Crew Members). No Carry Operators
 1 (2%) 
 
 I think the actual framework is very generic. It may apply to many context. It is not tailored on the DG industry at all. Particularly the first "Application of procedures and compliance with regulations" it's for me the most important one with regard to DG but it is the less detailed and does not quote many aspects, for instance the continuity in compliance. The regulations change, Is there a reviewing process management?
 1 (2%) 
 
Total: 46

20. 9. Is the guidance provided for developing competency-based training in 2.7.2 useful?

 Yes
 99 (75%) 
 
 No (please elaborate)
 33 (25%) 
 
Total: 132

21. If no on question 9), please elaborate:

 As a draft document , YES
 1 (2%) 
 
 it seems you have to purchase the guidance materials, they were not available for review.
 1 (2%) 
 
 Where will the resources (assessors) come from ?
 1 (2%) 
 
 again rather complicated but can be a guidance to set up trainings
 1 (2%) 
 
 It is useful if you are preparing, accepting loading Dangerous Goods, however I am sub-contracting this to a nominated and approved ground handler but I cannot see how it will work for us.
 1 (2%) 
 
 However it could be improved through industry collaboration. Very few regulators have real life experience as trainers. Many don't do a good job training their enforcement staff as was evidenced in the ICAO State audits. Perhaps this should be the first step before imposing these requirements on shippers is to apply it for enforcement staff.
 1 (2%) 
 
 It's a good start, but most operators will not have the level of knowledge or the time to perform a detailed training needs analysis for each of their numerous functions in the process of dangerous goods. A sample CE/knowledge matrix by ICAO is needed as a benchmark.
 1 (2%) 
 
 In order to understand or apply the guidance, a safety advisor with special knowledge is required
 1 (2%) 
 
 Some competency elements are overlapping. The flow chart does not clearly provide the limits between the individual activities. In order to understand or apply the guidance, a safety advisor with special knowledge is required. Clear differentiation between the activities
 1 (2%) 
 
 The more often you read it the more you get the feeling that following this approach we may end up in uncontrollable with numbers of different trainings for individuals. This could lead to more challenges than we may consider right know. Also, what about resources required, time, costs and competence of the assessor? How will these factors be guaranteed and who will give guidance at this point?
 5 (12%) 
 
 It assumes all employers are huge multi-national organisations with training budgets etc. That's a completely false view of how industry actually exists.
 1 (2%) 
 
 Once again. I admire the wonderful job you did. And I´m glad that finally in DG Training a clear and precise standard is set.
 1 (2%) 
 
 The more often you read it the more you get the feeling that following this approach we may end up in uncontrollable numbers of different trainings for individuals. This could lead to more challenges as we may consider right know. What is about resources required, time, costs and competence of the assessor? How will that be guaranteed and who will give guidance at this point.
 1 (2%) 
 
 To a lot of employers perhaps.
 1 (2%) 
 
 more convincing that there is a need for training
 1 (2%) 
 
 We plan to integrate some of the directions into our training courses.
 1 (2%) 
 
 It seems that those who set this up, have no practical idea of what happens in the DG work place. It is not just Shippers and Operators, it is packer, and handling agents, as well as seasonal staff doing jobs with minimal training. It is Airport security staff and grand staff like ramp agents, baggage loaders, catering staff, re-fueling operators and cleaners, Engineers and mechanics, plus drivers check-in teams. When you have a list of the various tasks to be undertaken, and a matching list of core skils and individual training needs, then, and only then, might you have a plan for developing a method to produce this CBT.
 1 (2%) 
 
 No access to it
 1 (2%) 
 
 We will end up in an no overseeable number of different trainigs for individuals.
 1 (2%) 
 
 sin Comentarios
 2 (5%) 
 
 2.7.2 is very theoretical and relies entirely on the employer.whose role is becoming essential. The methods to develop competency-based training have to be detailed..
 1 (2%) 
 
 In contrast to the existing training provision that the employers are only required to ensure relevant DG training is given to their staff in accordance with T.I. Tables 1-4 and 1-5, the new training approach as detailed in Section 2.7.2 places more responsibilities on the employers, from conducting a training needs analysis, formulating their own competency framework / training curriculum, arranging tailor-made training courses to implementing continuous assessment and evaluation. This incurs a much higher cost to the employers and will not be cost effective for the large number of small enterprises (i.e. freight forwarders and shippers) which have only a few staff. The diversity in the scope of training to be required by the workforce and to be implemented by the logistics industry, including not only large-sized enterprises but also medium-sized and small-sized shipping / freight forwarding agents, will render regulatory oversight of compliance difficult, if at all possible.
 1 (2%) 
 
 Too detailed - some of the topics need not be covered so the risk is to return to the situation as with Table 1.5. For example, 3.3.1 is complete acceptance checklist followed by provide shipment information for load planning - this is often done at a far later stage than acceptance, and yet seems that it must be covered. I could give you other examples.
 2 (5%) 
 
 See overall comments
 1 (2%) 
 
 I am not a trainer nor trained in delivering training thus the language is somewhat alien
 1 (2%) 
 
 Very brief not enough information.
 1 (2%) 
 
 2.7.2.3 gives a little information and very exact. It must be more explaination how to use .
 1 (2%) 
 
 2.7.2. not found
 1 (2%) 
 
 2.7.2 not found
 1 (2%) 
 
 The methods are not practicable and the guidance on changing roles would only increase the responsibilities to all Employers and some of them are not capable to undertake as they often do not get involved in determine the knowledge/skills needed by employees, some of them are not able to assess the level of competency prior to them performing a specific function. Therefore if they do not know the above details, cannot make decision to fulfil competency-based training, thus it will increase costs due to the need to employ an employment and training assessor role.
 2 (5%) 
 
 Though very general information.
 1 (2%) 
 
 I fully agree with that the trainings provided should switch to being active not passive but do the employers possess the resources and qualifications to fulfil 2.7.2? If this is provided for them it will be more generic. But who is the employer? So far only operators and regulators have been mentioned thus will that allow for interpretation that shippers, freight forwarders etc are not covered by the training requirements? The assessor’s qualifications are not addressed, can this be done by a 3rd party if the competencies for such is not present in the organization. My personal opinion is that it is possible.
 1 (2%) 
 
  See above
 1 (2%) 
 
 testing
 1 (2%) 
 
 1
 1 (2%) 
 
Total: 42

22. 10. If you were to implement a competency-based approach to training and assessment, how would it impact your organization?

 Provides for a more competent workforce. Establish reliable assessment tools to evaluate the achievements.
 1 (1%) 
 
 We would have to find a way to meet al requirements for the different Needs. We are Training various shippers, forwarder, passenger handlers, checkers. Training must be very well planned to meed the different Needs ( shippers from different branches together in one course e.g. paint producing ind. , chem. ind., Lithium shippers,....)
 1 (1%) 
 
 AITAC P/L applies CBT now
 1 (1%) 
 
 not sure
 1 (1%) 
 
 No impact on training
 1 (1%) 
 
 A competency-based approach is surely the way to go. This approach ensures that all the elements of training are delivered.
 1 (1%) 
 
 We would continue to train according to the guidance established by our competent Authority (USDOT). If our CA mandated the change, our training is already based on job function, however, our system is set up to use testing as our method to determine competency.
 1 (1%) 
 
 Not much as we allready evaluate competencies as part of a quality management system
 1 (1%) 
 
 As we are working on this methodology, the impact in my organization is not considerable.
 1 (1%) 
 
 The impact would be big as it is completely different from the traditional way of training. However we beleive this will geratly benefit safety and the development of our employees
 1 (1%) 
 
 To review the lenght of training courses.
 1 (1%) 
 
 If it became mandatory I would cease to be a DG Training provider
 1 (1%) 
 
 I'm fearful we would have to Close due to unsustainability issues.
 1 (1%) 
 
 We would consider using an online provider instead of, as has been the case over the last 6 years, developing programmes that are relevant to our operation. The burden of this work does not, in my view, reflect the gains in safety that are achieved; that the burden would be better offloaded and "forgotten about".
 1 (1%) 
 
 Would be difficult to implement when we deliver CAA approved DG training all over the globe. If it was just classroom based it is a lot easier to control. In the workplace with the variety of shifts we work 24/7 would be virtually impossible to implement
 1 (1%) 
 
 Tailored skills would bring greater focus to the roles actually carried out which would offer us the flexibility a small but growing carrier requires.
 1 (1%) 
 
 The impact would be minimal
 1 (1%) 
 
 Financial cost of employing assessors. It would slow down aircraft turn around times is an assessor had to make on board assessments of aircrew.
 1 (1%) 
 
 No impact in real terms on training in the class room. External work from the classroom could be a little more difficult as students are dispurssed around the world. It is potential that rather than visiting the students they are sent details of an items and ask to carried out their duties under the competancy level they have, this could be a simulated package for return to the school under pain cover no DG in the item to ensure regulations are not broken
 1 (1%) 
 
 The impact on the school would not be too great. We already do practical exercises throughout the course. However the continual assessment could be more difficult as our students can be anywhere around the world. A simulated practical of sending a package back to the school could alleviate this problem.
 1 (1%) 
 
 We simply need more Manpower to Control this.
 1 (1%) 
 
 I fully appreceate the new idea of training but it will be a problem to all regular DG Trainings offered since the number of participants will decrease as well as the revenue. In-house " tailor made" Trainings will therefore decrease
 1 (1%) 
 
 We already have it and it works very well.
 1 (1%) 
 
 It would require some 1 on 1 training which will increase costs, but improve safety
 1 (1%) 
 
 I would see little impact over the current training method.
 1 (1%) 
 
 The quality of the personnel that we will train will be a valuable asset to the SMS in the industry because they will be able to apply functionality to their roles
 1 (1%) 
 
 Revamp and reapproval of National Authority approved training procedures and manuals
 1 (1%) 
 
 This would extend the time needed to train personnel greatly and it would add cost to the business as more trainer/assessor time would be needed.
 1 (1%) 
 
 It would have a huge impact on the organisation. Queensland has many remote health clinics that send infectious substances by air to laboratories for testing and training all these staff using a competency-based system would have enormous consequences. The current system provides sufficient outcomes.
 1 (1%) 
 
 Greater clarity of handling of dangerous goods Increased learning ability Improved efficiency of dangerous goods training
 1 (1%) 
 
 A transition period would be necessary because we would have to adapt ourselves to this new approach. This would include as regulator, development of new tools for the approval of DG training programmes.
 1 (1%) 
 
 Locally many courses are into Competency Based approach. This way of structured learning is effective and ensure that students learn in small portions.
 1 (1%) 
 
 Adoption of Training documents to competencies of Trainees/companies
 1 (1%) 
 
 I have a lot of comments on this, I want to save this review and finish it later, I want to put a lot of thought into it. Jim Powell jim@dgtraining.com
 1 (1%) 
 
 1. Improvement on Jobs performance 2. Effective Dangerous Goods Training
 1 (1%) 
 
 N/A
 2 (2%) 
 
 If this does not allow for computer based training it will have a significant impact for many companies that currently use this approach. This is especially critical for companies with retail employees and workforces with high turnover. Classroom training is not cost effective. Computer based training supplemented with an assessment approach to ensuring appropriate competency would be acceptable if sufficient transition time is allotted. ICAO should consider hosting a few industry forums to solicit feedback before implementing this change.
 1 (1%) 
 
 All training programmes would have to be re-written, which requires an enormous amount of human and administrative resources
 1 (1%) 
 
 Our consulted companies have to reorganise their current training approach. Training programmes and instructors certified by the competent authority have been used. In future, the companies would have to develop their own training programmes and assess the trainers themselves. This would be a completely new system.
 1 (1%) 
 
 Large-scale investment of time and money for only little improvement of today’s system. Low improvement of safety since training is already based on a job function rather than a job title. More detailed instructions would be preferable. The Function/Knowledge matrix should be used more as an additional tool to translate the tables as given into a job function.
 5 (5%) 
 
 No training would be given.
 1 (1%) 
 
 In my company and in the training network that I´m working with we already use the competency-based approach and assessment for in-house training. And in our open courses we adjust the topics to the needs and competencies that our trainees need to acquire now already. So the only change for us will be the implementation of the more detailed structure. What would help us though is a clear time frame set by the authorities for the different competency units. So that everyone in the business has the same time frames to follow and can not reduce the times in order to have advantages over those training company that do it thoroughly.
 1 (1%) 
 
 Time and money-investment for only little improvement towards today’s system. Low improvement of safety since training is already based on a job function rather than a job title.. Detailed directions how to use would be preferable. We see the Function/Knowledge matrix more than an additional tool to translate the tables as given into a job function.
 1 (1%) 
 
 I believe the impact would be immediate, and time consuming.
 2 (2%) 
 
 More cost, more time, and a requirement to arrange at least part of the training at a suitable facility (airport)
 1 (1%) 
 
 Significantly as it would require an additional trained employee to apply it as part of the role - therefore there is a cost implication where there didn't used to be one
 1 (1%) 
 
 more difficult to survive as a traing institute, as other persons can now learn someone part of the trick, but will not have full understanding of the whole philosophy
 1 (1%) 
 
 Not at all as we have been doing this type of training since 1999.
 1 (1%) 
 
 It would have a positive impact as we would have a training requirements which would much more better be focused on the detailed training of separate functions.
 1 (1%) 
 
 It would have an enormously negative impact on our organisation. The training burden would increase unrealistically; either current courses would have to be extended, or a plethora of varying shorter, specific courses would be required. Additional resources would be required for; assessment fees, assessors, line managers’ management of staff and inflexibility of personnel movement. Without extra resources, negative points far outweigh the benefits, not to mention a detrimental effect on operational capability.
 1 (1%) 
 
 I would need to employ 10 times my existing staff, who would need to come from those with existing knowledge and skills. This in turn would mean taking people from the Airport work force, forcing them to employ staff requireing full training. Implementation of this scheme, could cause a sreadful backlash in the work force.
 1 (1%) 
 
 a lot of extra work and extra trainingcosts. It is also much more complicated to have different groups in one trainingsession. Untill now we give training cat 6 to our acceptance staff and these sessions can also be followed by staff from other compagnies. Can this still be the case? If not, training costs are much higher as more (and different) sessions have to be given.
 1 (1%) 
 
 Positive
 1 (1%) 
 
 Improve safety and reduce risks Some problems in the transition period
 1 (1%) 
 
 Improve safety and reduce risks.
 1 (1%) 
 
 Stick to Table 1.5 A and increase it with a number of topics depending on job functions. Control via IATA and Local Authorities especially in the aewrea of shippers and packers
 1 (1%) 
 
 El impacto seria mínimo o ninguno porque al momento ningún transportista nacional transporta comercias peligrosas por vía aérea. Ni han manifestado interes de hacerlo.
 2 (2%) 
 
 CBTA who certainly impact our current dangerous goods certification regime.
 1 (1%) 
 
 Competence of the organization (Ministry) will raise.
 1 (1%) 
 
 It would be very burdensome for our training school as we will be forced to radically change all our DGR training courses.
 1 (1%) 
 
 By directly relating it to an employees actual functions and duties it will allow a focussed and relevant approach to training and instruction
 1 (1%) 
 
 El impacto seria mínimo o ninguno, en razón de que al momento ningún transportista aéreo nacional trasporta mercancías peligrosas por via aérea. tampoco han manifestado su interés en transportarlas.
 1 (1%) 
 
 Massive additional workload
 1 (1%) 
 
 we are evaluating the impact
 1 (1%) 
 
 As commented in Question 9 above, the new training approach would inevitably incur additional costs to the industry, particularly for those small and medium-sized enterprises, in the development of an appropriate competency framework. Additional resources would be required to establish new training programme (or modify existing training programme), and to formulate suitable tools to assess personnel competency. The impact of this cost would be disproportionately greater for small enterprises with limited resources and for large enterprises with a large number of staff who have different job functions and/or are in various remote locations. Besides, the diverse business nature and enterprise sizes of the logistics and air cargo industry will render the uniform application of the related standards on competency-based training and assessment quite impossible and regulatory oversight of compliance very difficult.
 1 (1%) 
 
 Positively
 1 (1%) 
 
 As an independent training provider, it would be extremely difficult to implement as we have between 8 and 15 delegates on a course from different organisations - shippers (small and large), handling agents, forwarders, couriers, airlines and others and we often have no prior knowledge of their involvement with dangerous goods before we meet them on the course.
 2 (2%) 
 
 The role of the employer becomes important. Continuous assessment requires more time. Cost factor also will go up.
 1 (1%) 
 
 Time consuming in a small organisation with few demands to actually ship dangerous goods by air
 1 (1%) 
 
 As a training provider this will require large scope of work to develop new training program and additional supporting tools such as digital learning based systems and tools. This will involve large investments
 1 (1%) 
 
 It will get long time and expence to adapt a competency based training.
 1 (1%) 
 
 In my opinion, It requires some time to prepare class material, activities and so on. It may also need some extra spending bugdet.
 1 (1%) 
 
 Not possible to make typical training curriculum in accordance with local requirements of aviation authorities and Ministry of Education of Russian Federation. As there is job mobility among the employer’s staff it is also hardly possible/ practical.
 2 (2%) 
 
 All the training will need to be re-qualified. The training class size will be restricted. No sure how many persons will attend in each of the CUs. No sure how many instructors will be required to meet training needs. Additional cost the new programme need to be calculated. Need information from the industry to re-plan training schedule
 1 (1%) 
 
 Not applicabler
 1 (1%) 
 
 I believe this would create a greater administrative burden on the training organization due to the increase in training module combinations. Additionally I believe that it would reduce the operational flexibility as the ability to reassign staff during an operation would be restricted based on the applicable CBT for the employee.
 1 (1%) 
 
 1. Hence it may greatly increase the cost of training for trainers and forwarders because: a. In case employers are not familiar with how to determine the "knowledge maintained by personnel performing specific functions "for each of the staff, outsourcing to the training consultant may be required. OR the employers will tend to save the cost of outsourcing by "ticking" all the boxes in the DG Competency Framework form in order to play safe. As a result it will totally defeat the purpose of competency-based approach. b. Need to tailor-made training on various functions the staff performing. c. No competitive pricing under standard training programme will be applied to this competency-based approach training. d. Need to tailor-made assessment on various functions the staff performing. e. No competitive pricing under standard training assessment will be applied to this competency-based approach training. 2. Hong Kong’s air cargo industry is very complex as we offer a variety of services including but not limited to consolidations. 3. The competitiveness of the market will be substantially undermined due to the above problems.
 2 (2%) 
 
 For CAA FI the national decree has to be rewritten. Basically if we restrict individuals rights somehow we need to have law level regulation doing this in Finland. The material presented in this New Training Provisions lacks information on how approval or oversight decisions could be made. For operators training programmes need to be rearranged and basically rebuilt. The personnel may need to be trained in smaller groups based on the DG activities they perform. Maybe costly for smaller operators. Good thing is that E-learning materials need to be reconstructed and shall be more detailed for each work. Training providers/instructors demonstration and certification system need to be solve somehow (who is checking the demonstration and what are demand on instructor or organization giving the training). PANS-TRG (Doc 9868), as it is now, is not “perfect” guidance for DG instructor, maybe adding separate chapter for this group would be good idea.
 1 (1%) 
 
 It would allow to make the training material more specific to some of the functions within the organization. Certain functions don't necessarily fall nicely within the 12 categories available at this point in time
 1 (1%) 
 
 It would require us to hire many more assessors to ensure the correct level of traning was offered to the operators.
 1 (1%) 
 
 It would need long time, Manpower and high costs involved!!!
 1 (1%) 
 
 The Employer himself will be updated in turn the employee can be trained in a competency based environment.A continuous assessment will encourage the employee to deliver the expected standards of service
 1 (1%) 
 
 training materials would need to be re written
 1 (1%) 
 
 Probably It will oblige me to employee new trainer. It means more costs with no money advantage for a little company
 1 (1%) 
 
 I continuously develop my trainings (primarily cat 6) to be more and more active thus my students physically demonstrate through exercise, group discussions and games the competencies gained during the course. Therefore I see my training as more and more competency based. Providing training internally the assessment parts is also worked out but I feel some reservations towards how this will be for 3rd party training providers. For many other training providers is will require a lot of investment in instructors, and limiting the sizes of the classes.
 1 (1%) 
 
  a properly designed and implemented program would create opportunities for me as an outside contract trainer/consultant. For the program to achieve the results articulated the costs are much higher than might be suspected from reading the literature I have seen today. Competency-based training can that starts with the concept of lifelong learning and that is what is being described here only work where there is regular (even if not frequent) direct assessment applied and that represents consumption of assets which in turn represents costs. I am not aware of any commercial operation that seems to be willing to invest the actual effort time and costs required to implement a true lifelong learning model and that is what is being described here
 1 (1%) 
 
 testing
 1 (1%) 
 
 Time & energy saving, much more effective training for specific roles of each individual in DG transportation chain
 1 (1%) 
 
 1
 1 (1%) 
 
 the same like simulator
 2 (2%) 
 
 It would actually increase the burden by increasing the number of courses being offered.
 1 (1%) 
 
 The CBTA will bring in a better understanding to the function specifics of all involved in ensuring that Safety is primal in Safe Transport of Dangerous Good by Air. The CBTA brings in the aspect of Knowledge, Skill and Attitude, which was previously lacking, plus the obligation of oversight by the Employer in ensuring that personnel are competent in their functions.
 1 (1%) 
 
 Establish a training program for all employees
 1 (1%) 
 
 It will surely develop a competent workforce
 1 (1%) 
 
 It will increase great opportunities for training for all employees of the institution, according to the type of job task that the employee is assigned to.
 1 (1%) 
 
 it make a change that need a new understanding
 1 (1%) 
 
 additional training document we will arrange and update our files
 1 (1%) 
 
 Increases working knowledge of dangerous goods Reduce training effort
 1 (1%) 
 
 This is the subject I would like to focus on.
 1 (1%) 
 
Total: 110

23. 11. Is the matrix tool in Chapter 5 useful?

 Yes
 96 (72%) 
 
 No (please elaborate)
 37 (28%) 
 
Total: 133

24. If no on question 11), please elaborate:

 Practice will show
 1 (2%) 
 
 it seems you have to purchase the guidance materials, they were not available for review.
 1 (2%) 
 
 to some extinct
 1 (2%) 
 
 Not written with small carriers in mind. I also train the RFFS team here at Lydd Aerodrome; they never touch DG, have never seen any DG. They occasionally load baggage and cover ramp. I try and make the subject interesting but it is a forlorn task.
 1 (2%) 
 
 Again it is useful if you fall into those categories
 1 (2%) 
 
 But it certainly could be improved with additional consultation.
 1 (2%) 
 
 See remarks for 9.
 1 (2%) 
 
 too detailed; each workplace needs a separate training schedule and a separate trainer
 1 (2%) 
 
 Too detailed; each workplace needs a separate training.
 1 (2%) 
 
 Instruction including appropriate examples is missing! Competency Units and Competency Elements do not match in all cases, e.g. the forwarder functions are not really covered. Making an assessment mandatory will not cover the issue when it is not clearly mentioned who will be responsible and what this person needs to know respectively needs to be certified in. Unfortunately it leaves the same space for interpretation as the current system. Generally we would recommend using and improving the existing system to give clearer guidance and examples on how to use the existing tables.
 4 (9%) 
 
 As above.
 1 (2%) 
 
 Instruction including appropriate examples is missing! Competency Units and Competency Elements do not match in all cases, e.g. the forwarder functions are not really covered. Making an assessment mandatory will not cover the issue when it is not clearly mentioned who will be responsible and what this person needs to know respectively needs to be certified in. Unfortunately it leaves the same space for interpretation as the current system. Generally we would recommend using and improving the existing system to give clearer guidance and examples on how to use the existing tables.
 1 (2%) 
 
 Missing guidance how to use it by giving appropriate examples. Competency Units and Competency Elements do not match in all cases, e.g. the forwarder functions are not really covered. Making a assessment mandatory will not cover the issue when not clearly mentioned who will be responsible and what does this person need to know respectively needs to be certified in. Unfortunately it leaves the same space for interpretation as the current system. Generally I would recommend using and improving the existing system the way to give more clear guidance and examples how to use the existing tables.
 1 (2%) 
 
 But will be abused by employers
 1 (2%) 
 
 Do not ask silly questions.
 1 (2%) 
 
 Confusing
 1 (2%) 
 
 Some Competency elements do not match, forwarders are not covered It even lease more room for interpretation then the current system Frankjly spoken, something like this should not be invented from the green table but more from the front side
 1 (2%) 
 
 sin Comentarios
 2 (5%) 
 
 Must be stated with more detail.
 1 (2%) 
 
 N/A
 1 (2%) 
 
 Similar to the provision in Chapter 3, the matrix tool in Chapter 5 does not differentiate the “depth” of the scope of competency that individual personnel should attain. Such depth of training should be appropriate to a person’s job functions (e.g. cabin crew VS cargo acceptance staff), and could range from familiarization level to expert level training. More information / guidance should be provided in this aspect. The provision of a “Conversion Table” as suggested in Question 6 is recommended.
 1 (2%) 
 
 It is far too complex,
 2 (5%) 
 
 See overall comments.
 1 (2%) 
 
 I guess it would be if I were in favour of the change, but I am not
 1 (2%) 
 
 The matrix is very draft and unclear.
 1 (2%) 
 
 I found myself lost in the matrix. I started checking the Dangerous Goods Knowledge for a sample group but I could not do anything with Competency Elements above in the matrix. 2.7.2.3 does not provide a developing pathway.
 1 (2%) 
 
 TI are not received yet (a long delivery to Russia)
 2 (5%) 
 
 This would not only add more burden to Employers who are not capable to determine, but also limit the flexibility of the staff as there will be cases of ad hoc tasks.
 2 (5%) 
 
 Example on e.g. for pilots or loader would be very useful to clarify how table should or could be used.
 1 (2%) 
 
 Too confusing
 1 (2%) 
 
 The matrix tool in Chapter 5 seems useful. However, we would suggest that, in the column with the heading “Dangerous goods knowledge”, some of the rows warrant further granularity. For example, several rows use the term “packaging” (e.g. “Requirements for packagings”) – this term is very general and could be further specified, for some personnel, detailing the actual types of packaging (e.g. boxes, drums, jerricans) being handled. Also, in the row “Requirements for the construction and testing of cylinders and closed cryogenic receptacles, aerosol dispensers and small receptacles containing gas (gas cartridges) and fuel cell cartridges containing liquefied flammable gas”, many very different types of packagings for Class 2 dangerous goods are grouped together, and we would suggest that each of these (i.e. cylinders, closed cryogenic receptacles, aerosol dispensers, small receptacles containing gas (gas cartridges), and fuel cell cartridges containing liquefied flammable gas) should be addressed in five separate rows.
 2 (5%) 
 
 Again there should be an MTL (Minimum Training List) to ensure the basics are covered regardless of job function. Some knowledge components like the provisions hidden dg and for passengers and crew should be mandatory for all, just for the purpose that all travel by air and are subjected to these. It will help spread the word to the “general public”. The safety chain consists of shipper – freight forwarder – handling company – operator – regulator. All should be mentioned in matrix.
 1 (2%) 
 
 testing
 1 (2%) 
 
 1
 1 (2%) 
 
 http://www.riadazama.com
 1 (2%) 
 
 I have no access to it consequently I would request to have access.
 1 (2%) 
 
Total: 44

25. Overall Additional Comments:

 As a draft document it does very well, explaining what CBT is and how it work.
 1 (2%) 
 
 I think that all training programs should be hands on
 1 (2%) 
 
 With this approach, will require more that a written assessment. Say for example an on ground practical exercise to ensure that employees are well equipped to carry out their functions especially for warehouse personnel
 1 (2%) 
 
 We have the following concerns: 1. will the assessments replace the need for recurrent training? 2. Currently many States still have problems with correctly applting the current requirements and have there own interpretations of the regulations. This becomes problematic where a State wants to review our training program in order to provide us traffic rights and a DG license. We believe if there is no clear instructions to States this problem becomes bigger. States shall respect ICAO annex 6, this will help prevent problems.
 1 (2%) 
 
 Internal and external verifiers would find access to some sites very difficult particularly off-shore, and to large chemical manufacturers. It would add significantly to the cost of training and would lead to many smaller shippers not bothering. It's bad enough to convince companies they need the training as things stand now.
 1 (2%) 
 
 Competency based training (CBT) & assessment – ICAO survey. Feedback from Glenn Murphy/SAS-SGH-Spirit Cargo College with reference primarily to the main, in-depth DG course, known generally as the full DGR Regulations course, covering: Cat.1 (shippers), Cat.2 (Packers), Cat.3 (Freight Forwarders), Cat.6 (GHA & Operators staff). Wheel is not broken for Cat.6, so why fix it? For a company training 1200 pilots fly an A320 in exactly the same way, I can see the benefit of CBT. For us training many different small groups, that will be extremely difficult to achieve. For Cat’s 1,2,3,6. I believe ICAO (& CAA’s) should be focusing more on ensuring Shipper’s and Forwarders are trained correctly worldwide. In some countries this is obviously a very high priority, whereas in others, it is definitely not! This must be more important, than again starting from scratch with Cat.6 staff who are already well-defined and well trained worldwide. Who knows what is actually inside the package? The shipper or packer! Who trains shipper’s & packers? In my 30 plus years in the classroom, we are looking at less than 5% from this category attending our courses. That is a major concern to me! Small training companies/schools with diverse groups attending There are very few possibilities to be trained locally in Scandinavia, the Baltics & Iceland by IATA & CAA approved companies. Companies like ours – holding courses for a mix of shipper’s/packers (rare!), forwarders, GHA and Operator staff simultaneously, have no choice, due to low numbers locally needing a course. There is No possibility for individual focus of a person because we can’t hold a course for an individual. No possibility to continually assess an individual’s progress (or lack of it). It’s extremely impractical (read: impossible) to do more than train and test an individual. If (s)he passes the course, then (s)he is approved to work with DG (commensurate with responsibilities/function-specifically). However if the individual makes mistakes, (s)he will be re-trained/re-instructed. How can a small school or small GHA’s management like ours, take time out to perform “task analysis” and on-going “assessments” for all involved? Do we stop all DG training and production to take time out to do this? If we do, many staff due for recurrent training will have their licences expire! We have held DG courses using the current method since the late 70’s and have an excellent name and record! If we are forced to follow this new requirement I am fearful we will have a sustainability issue and perhaps be forced to close. That will remove one of the few professional local training institutions in Northern Europe. Will that be beneficial for the Safe transport of DG by air within the area? IATA Table 1.5A important platform for DG training – please do not remove! Yes, it’s based upon categories…..BUT also “function-based” and “commensurate with their responsibilities”, which in essence is already CBT! So, again, why change it? If IATA table 1.5.A (which is “official” basis/platform for building DG training) is removed, what will then be the substituted “official platform?” What will become the ICAO/IATA basis platform for holding a DG course? Who will decide that? Different countries have different standards as we know. With Table 1.5.A all have a guide. Removing table 1.5.A will allow for further diversification and differing understanding of which are the main foundations to be trained in. Given a difference of opinion, it has always been helpful to go back to the table to find these foundations. Without the table, it is up to schools to find their own, with all the misinterpretations that can cause/contribute to. We hear much talk of stream-lining a course to make it leaner/more specifically about what must be done. Is it not important to know why it is to be done, how it is done etc? Therein lies another problem because a company often loses out financially on training staff. Ticking a box is often the main aim and the training without an “official platform” to be adhered to will risk being watered down and totally non-standardized! Standardized training is what we have been working towards in IATA for many, many years. (Ref. IOSA/ISAGO).The risk of losing what we have achieved worries me greatly. Lastly, table 1.5.a affords a total “overview of the regulations”. Using all aspects of the table in training, to build a function-specific course which also ensures the person’s responsibilities are covered, gives a more complete understanding and appreciation of the risks involved with DG. Yours sincerely Glenn Murphy Senior DG Instructor – SAS Ground Training – Oslo.
 2 (3%) 
 
 A strong plea that ICAO will recognise the needs of small carriers (I think these are in the majority BTW), carriers who offer AOG services in the most part and do not carry commercial loads of DG, just occasional small shipments.
 1 (2%) 
 
 Competency based training would work for DG shippers, packers, etc but not for aircrew who rarely handle DG including in passengers bags. When they do it is usually a simple issue such as checking no lithium batteries are being put in the hold when cabin bags do not fit the cabin.
 1 (2%) 
 
 Instructors should retain the same broad level of competancy and hold a state recongnised training and assessment qualification beyond the state required competancy level of the appropriate authority for teaching the movement of dangerous goods. Competancy training is helpful for students and employers as it allows both to focus their requirements
 1 (2%) 
 
 I feel this change to training could be of great advantage to the students.
 1 (2%) 
 
 I and my organisation are in full support of the competency based training proposals
 1 (2%) 
 
 We do understand the need to look at improving training to DG professionals, but to move to competency based training does have the potential to cost business dearly. Unless the move to a more 'commensurate with responsibilities' basis frees up a lot of time to feed into the competency model.
 1 (2%) 
 
 IATA DGR regulations provide rules on how to transport dangerous goods and not a guide on how to physically pack dangerous good. Therefore this is a knowledge transfer and not a skills transfer. Shipping companies need to train their staff on how to transport shipments that meet the DGR regulations once this knowledge has been acquired from the DGR regulations.
 1 (2%) 
 
 It is time to change and provide better tools for more efficient of dangerous goods training
 1 (2%) 
 
 a. In Classification ...to add SDS and GHS information b. In Report writing ..good to have info like Emergency Response, Use of Fire fighting equipment ...knowledge on fire type. c. To have UK(Underpinning knowledge) at every CE/PC. d. Cross Matrix Table will be useful. Chapter 5 Matrix is also good but need to have to address target group because in the end some fields or topics is NOT APPLICABLE to other group of workers. Regards e. Tools required in Teaching like Prepare Boxes.labels etc...
 1 (2%) 
 
 A competency-based Training definitely helps shippers to Focus on their needs. However, freight forwarders still Need to receive full Training, but also competency-based. EG: No Need to Train forwarders on passenger restrictions.
 1 (2%) 
 
 I am going to try and use your web page to save this draft and return to it later...
 1 (2%) 
 
 In a competency-based training program, both the employer and the employee benefit. Personal judgment and subjectivity are minimized, creating a more positive work environment and a stronger relationship between the employee and the employer. This is a result of establishing transparent workforce planning, performance standards, performance assessments and succession plans within the Organisation.
 1 (2%) 
 
 Taking our experience into account, we think the competency-based approach to training and assessment is not feasible. Employers will get to much liability for requirements they might not be able to meet. The notified bodies should be involved to a higher degree.
 1 (2%) 
 
 The currently used system of personnel categories is established and well integrated into practice. We don't see the necessity to change this system. The new system requires a complete revision of the current training organisation by our clients. It will be difficult to implement the new system to the open courses with trainees from various companies. The majority of training courses in Germany is provided in this way. Employers will get to much liability for assessing workplaces, trainers and employees, which they might not be able to meet. In my opinion, the cancelling of the final test may lead to a decrease in the level of security. Most companies may not be able to develop training programmes and to assess workplaces, trainers or employees by themselves and may require an external advisor. The competent authorities should keep certifying training progammes and trainers, but not only randomly check assessments.
 1 (2%) 
 
 To promote a more competency based training approach is a good thing but I have my doubts that it will become practical or even improve safety more than the existing system. Therefore we need a globally followed system in all aspects, not only a proposed way which at the end of the day will be amended regarding individual country views and understanding. The first priority must be that all authorities having agreed ICAO must endure having the knowledge and competence to observe this regulatory requirement. It is easy to implement regulations but totally different to maintain and control such regulations. It is understood that all these amendments are based on the EBT approach which started with the MPL project but I would suggest to review this approach again by considering also the differences of dg training versus standardized Aviation requirements for pilots or A/C maintenance people. This new approach will create by far more training variances as we already have which leave space for doubts that this will make the world safer. What really is needed a clear and globally accepted interpretation and guideline what is to be trained in accordance to the existing table content - and time-wise. As long different countries can make their own rules on a international subject regarding interpretation and way to proceed with it we will not get a saver transport environment globally.
 1 (2%) 
 
 It's an incredible leap backwards that will result in thousands of shippers not being trained as most organisations would have no means to conduct these pointless assessments.
 1 (2%) 
 
 I know that you will have a lot of input from the industry saying this new system can´t work. In my opinion most of it is backed by the fear for change. Yet you have seen the need of raising the standard of knowledge by implementing this competency-based training and assessment approach and you´re absolutely right in going through with it. The clearer the set-up. The easier for everyone to fulfill the requirements. And the matrix you´ve created combined with a time frame will do just that. One item still open is how to visualize the CUs and CEs for each employee. Will this be done by printing the matrix on the back of the certificate with those CUs and CEs ticked that were part of the training? I think it´s very valuable that you´re taking the time and looking at all comments from the industry and from training and consulting companies. Just don´t let negative views on the new approach water down your clear set-up. Speaking for our training network at Strober & Partner GmbH and for my companies savethesituation and Lithium-Battery-Service Werny & Glimsche GbR I can only stress it once more that what you´ve created is perfect for training purposes and covers the responsibilities and competencies in a very detailed and clear way. Wishing you all the best for the finalizing of this new approach. Eva Glimsche
 1 (2%) 
 
 CBT can be implemented, to a certain degree, by training schools, but not fully. Making the employers responsible for further training and assessment, without having a method of checking that this is being carried out, will result in lower/different standards. Testing after initial classroom training is still going to be required, to ensure at least a minimum level of knowledge. A lot of DG training is theoretical and cannot be easily implemented into a CBT environment.
 1 (2%) 
 
 Broadly welcome the proposed changes - however, there will be cost implications and there is a danger of creating training cartels where they can charge what they like. Current system is not perfect and requires change. Similar competence based training programmes don't work as they rely on companies to do the assessment - this requirement will be pushed to the back of the queue in favour of operational needs. Who then will monitor, report and update the competency records? Need to look at on-line assessment every 2 hours - failure to achieve the required standard would require re-training - look at the UK's NXCT x-ray operator training programme - this works!!
 1 (2%) 
 
 I do not feel that the subject of Dangerous Goods is fit for competency based training as it is not a trick but a full awareness! Rgds. Gilbert
 1 (2%) 
 
 I am individually delighted that ICAO is getting to grips with sub standard training. I recently attended a training course in Atlanta, Ga. It was presented by a well known local company. The trainer however had only qualified in the previous year (1 initial course) and was now a trainer at a well known organisation. This is the sort of situation which will invariably lead to poorly qualified candidates entering the work force and increasing the risk in aviation. A ludicrous situation really. Hopefully this initiative will weed out the poor providers...well at least I live in hope ! Keep up the great work !
 1 (2%) 
 
 Whilst competency based approach to training an effective method of ensuring requisite skills and training match individual post outputs; it is indeed inflexible and does not lend itself to the requirements of multi-skilling without the availability of significant additional resources and costs. Whilst I can see how it works in the Engineering domain where tasks are set; process driven and have little or no scope/requirement to deviate. This is not true for DG operations. I would like to understand what is behind the decision to introduce a completely new training regime. What evidence is there that the Competency based training will significantly improved what is already an area that is heavily regulated.
 1 (2%) 
 
 It took ICAO from 1944 to 1982 to produce a manual (TI) for the control of DG by Air. This has changed almost every year, so it is now almost a clone of the IATA Manual. In 1982 ICAO introduced the Limited Quanties provisions by Air, for a two year "Transitional" period, It's 36 years later, and we still have it. Since adopting Lithium Batteries from Division 4.3, into Class 9, materials once considered perfectly safe in air transport, are now considered as a threat to life and aircraft, with changes on a almost weekly basis. ICAO produces problems, not solutions, is there any wonder why undeclared DG is growing daily. If CBT is not introduced correctly and ALL COUNTRIES made to follow the rules, there is no point in wasting further time and money.
 1 (2%) 
 
 The basic principle is very good, the practical use of it will be much more complex. For smaller stations, compagnies, the costs will increase a lot. Will there be a minimum for the different items to be followed, or can each employer decide for himself what the minimum needs/requirements for his staff are?
 1 (2%) 
 
 Many questions: Who and how is going to measure the performance? Are they independent? How CBTA links with new technology advances? Is the use of simulators and virtual reality acceptable? Are there no minimum number of hours? How long is the training acceptable?
 2 (3%) 
 
 No Additional Comments
 1 (2%) 
 
 The proposals to improve training by a change to competency based training and assessment by ICAODGP should be welcomed by all parties who are concerned with the safe preparation and consignment of dangerous goods. Most companies rely on assessment of competency to perform specific functions as the basis of employment and in regulatory matters compliance. Whilst there is a fundamental requirement for underpinning knowledge, competency in task to regulatory or occupational standards, rather than academic testing must be paramount. The provision of training to job titles or positions has inevitably resulted in numerous employees of FREIGHT FORWARDING agents being trained to test in unrelated matters to their actual functions or responsibilities. ICAO and IATA sets out the responsibilities of the SHIPPER and OPERATOR but in any pragmatic functional analysis of airfreight transactions the distinct role and functions of the FREIGHT FORWARDER are not included. (A person or organisation who offers the service of arranging the transport of cargo by air Source ICAO – IATA glossary). The FREIGHT FORWARDER is neither SHIPPER nor OPERATOR but has integral and distinct functions that need to have a designated Competency Unit which will duplicate some of the elements that appear with those of the SHIPPER/OPERATOR. Any additional verification checks can only support and enhance safety and reduce costs to industry with unnecessary airline rejections. It will also facilitate more focussed and cost effective training of FREIGHT FORWARDERS) IATA already sets the functions of the FREIGHT FORWARDER in its Dangerous Goods Regulations and requirements: - “The detailed content of these regulations gives all the necessary provisions to enable a SHIPPER to correctly prepare a consignment of dangerous goods for air transport and for a FREIGHT FORWARDER to be able to verify to the extent possible, that a consignment of dangerous goods complies with the requirements etc. (Source IATA “HOW TO USE THE REGULATIONS”). Whilst cited in the context of DG in Consolidations: - IATA 1.3.3.2.6 The FREIGHT FORWARDER must for all consignments check documents and the exterior of packages for indications of dangerous goods. This is reinforced in Section 2.2 Hidden Dangerous Goods/ IATA 8.2.6.6 If follows that as the FREIGHT FORWARDER is arranging transport and thereby establishing route and carrier that they will be responsible for identifying applicable State and Operator Variations which are frequently unknown to a SHIPPER. It is therefore my recommendation that the Dangerous Goods Competency Framework should be modified to include the role of the FREIGHT FORWARDER by modifying CU3 Processing/accepting cargoes so that the verifying aspects CE-1 CE-2 are a specific competency unit rather than just included as part of the acceptance of cargoes by OPERATORS. This revised Competency Unit(CU) should also include Competency Elements (CE) for: - a) Based on selected routing and carrier verify compliance with State and Operator variations b) Completion of Airwaybill (AWB) c) Checking for damage/leaking d) Checking of general cargoes, a) Check Documentation for indications of undeclared dangerous goods b) Check Packages for indications of undeclared dangerous goods c) Endorsement of airwaybill (AWB) e) Retention of documents Whilst it is not specifically part of the airfreight regulations, that as transport to and from airports always involves other modal regulations (IATA 1.2.8.1 Note) and is part of the signed declaration and we are looking at competency I would also suggest that a further section relative to FREIGHT FORWARDERS is included to state f) Verify compliance with applicable national or international modal requirements
 1 (2%) 
 
 Given the complexity and implications as mentioned above in the development of a competency-based framework for various job functions along the cargo supply chain, in particular for those small and medium-sized enterprises, the existing training approach / provision should be allowed to be run in parallel with the proposed competency-based training approach, to cater for the different business and operational nature and needs of the stakeholders. If this suggestion cannot be adopted, i.e. the competency-based training approach has to be mandated by ICAO, more concrete examples and specific guidelines to facilitate the industry’s implementation and regulatory oversight should be provided. Specific details of the acceptable forms of continuous assessment as proposed in chapter 2, paragraph 2.7.2.6 should also be provided. A transition period of at least 5 years should be considered prior to the mandatory implementation of this new training approach.
 1 (2%) 
 
 The basic idea is sound and will work for in-house training when you have a homogeneous group of students. For independent training providers, it is going to be very difficult or almost impossible to implement as we might have 8 to 10 different organisations represented at a course. In addition, many might be very small so there is perhaps only one person with dangerous goods knowledge, so internal assessment is not an option. We also run our courses in hotels, often fly to locations, so it is quite impractical to have available sufficient packaging and labels to cover the requirements of all delegates whom, as mentioned in question 10, we have no knowledge of their dangerous goods requirements in advance of the course as they book and pay for their place via e-mail. The independent training providers have been forgotten in these proposals, and we are the backbone of training provision in Europe, North America, Asia and Australia. So, a substantial re-think and amendment is required before these proposals move forward.
 2 (3%) 
 
 IFALPA Comments on CBT for Dangerous Goods Training In light of the proposed draft ICAO proposal related to the implementation of competency-based training for dangerous goods training, IFALPA would like to express the following considerations related to CBT: The proposed "CBT" is not in line with the recent amendment of Doc 9868 PANS-TRG, which describes what is a Competency, and a Competency Framework. The proposed "Competencies" are now described as Tasks in PANS-TRG. Although it is necessary for CBT to describe thoroughly the Tasks to be performed on the job in a Task Analysis, those tasks do not constitute a Competency Framework as such. IFALPA regrets that no consideration is given throughout this framework to recognized key-principles of flight safety improvement, such as ASAP, FOQA and Just Culture provisions. In addition to the guidance principles exposed above, IFALPA has the following concerns about the ICAO CBT framework: CU 1 Classifying dangerous goods (Usually not a crew-related task but may be performed by pilots in NCC, cargo or small aircraft operations) CE 1.1 Evaluate substances or articles against classification criteria, as applicable Requires adequate awareness that needs to be addressed through experience and in-situ teaching, how can it be achieved by CBT? PC 1.1.1 Determine if it is dangerous goods (how?) PC 1.1.2 Determine if it is forbidden under any circumstances CE 1.2 Determine dangerous goods description Ok with CBT, still requires efficient knowledge and processing of the applicable regulation / documentation (TI) PC 1.2.1 Determine class or division PC 1.2.2 Determine packing group, if applicable PC 1.2.3 Determine proper shipping name and UN number PC 1.2.4 Determine if it is forbidden unless approval or exemption is granted CE 1.3 Review special provisions Same comment as per CE 1.2 PC 1.3.1 Assess if special provision(s) is applicable PC 1.3.2 Apply special provision(s) CU 2 Preparing dangerous goods shipment (Usually not a crew-related task but may be performed by pilots in cargo or small aircraft operations) Comments expressed at CE 1.2 apply also to this chapter CE 2.1 Assess packing options including quantity limitations PC 2.1.1 Consider limitations (de minimis quantities, excepted quantities, limited quantities, passenger aircraft, cargo aircraft only, special provisions) PC 2.1.2 Consider State and operator variations PC 2.1.3 Determine if all-packed-in-one can be used PC 2.1.4 Select how dangerous goods will be shipped based on limitations and variations CE 2.2 Apply packing requirements PC 2.2.1 Consider constraints of packing instructions PC 2.2.2 Select packaging materials (absorbent, cushioning, etc.) PC 2.2.3 Assemble package CE 2.3 Apply marks and labels PC 2.3.1 Determine applicable marks PC 2.3.2 Apply marks PC 2.3.3 Determine applicable labels PC 2.3.4 Apply labels CE 2.4 Determine if overpack can be used PC 2.4.1 Apply marks if necessary PC 2.4.2 Apply labels if necessary CE 2.5 Prepare documentation PC 2.5.1 Complete the dangerous goods transport document (Shipper's Declaration) PC 2.5.2 Complete other transport documents (e.g. AWB) PC 2.5.3 Include other required documentation (e.g. approvals/exemptions, etc.), as applicable PC 2.5.4 Retain copies of documents as required CU 3 Processing/accepting cargo Usually not a crew-related task but may be performed by pilots in cargo or small aircraft operations. Besides, there is no discussion here of checking for appropriate packaging, damage, leaks, odors, UN marks on specification packaging. These items should be specifically mentioned in lieu of a vague statement about acceptance check). CE 3.1 Review documentation PC 3.1.1 Verify air waybill PC 3.1.2 Verify dangerous goods transport document (Shipper's Declaration) PC 3.1.3 Verify other documents as applicable (exemptions, approvals, etc.) PC 3.1.4 Verify State/operator variations CE 3.2 Review package(s) PC 3.2.1 Verify marking PC 3.2.2 Verify label PC 3.2.3 Verify package type PC 3.2.4 Verify package conditions PC 3.2.5 Verify State/operator variations CE 3.3 Complete acceptance procedures PC 3.3.1 Complete acceptance checklist, if applicable PC 3.3.2 Provide shipment information for load planning PC 3.3.3 Retain documents as required CE 3.4 Process/accept cargo other than dangerous goods PC 3.4.1 Check documentation for indications of undeclared dangerous goods PC 3.4.2 Check packages for indications of undeclared dangerous goods CU 4 Managing cargo pre-loading CE 4.1 Plan loading PC 4.1.1 Determine stowage requirements PC 4.1.2 Determine segregation, separation, aircraft/compartment limitations CE 4.2 Prepare load for aircraft PC 4.2.1 Check packages for indications of undeclared dangerous goods PC 4.2.2 Check for damage and/or leakage, and odors what to do in case of superficial damage? Identify the pilot’s procedure to follow on the discovery of a failed package (so as to make sure the pilot’s training is specific to his task) PC 4.2.3 Apply stowage requirements (e.g. segregation, separation, orientation) PC 4.2.4 Apply ULD tags when applicable PC 4.2.5 Transport cargo to aircraft CE 4.3 Issue NOTOC PC 4.3.1 Enter required information PC 4.3.2 Verify conformance with load plan PC 4.3.3 Transmit to loading personnel PC 4.3.4 Provide pilot-in-command with paper copy CU 5 Accepting passenger and crew baggage Pilots, in some countries or for specific operations, will be the first calling point for cabin crew should they have suspicion regarding DG being present on or with a passenger so knowledge of this CU is of paramount importance for pilots. CE 5.1 Process baggage PC 5.1.1 Identify forbidden dangerous goods how? Can it be reworded “Use applicable documentation to identify forbidden dangerous goods”? (There is a table in the TI's that outline acceptable DG for passenger checked and carry on baggage) PC 5.1.2 Apply approval requirements CE 5.2 Accept baggage PC 5.2.1 Apply operator requirements PC 5.2.2 Advise pilot in command CU 6 Transporting cargo/baggage CE 6.1 Load aircraft PC 6.1.1 Transport cargo/baggage to aircraft PC 6.1.2 Check packages for indications of undeclared dangerous goods how? PC 6.1.3 Check for damage and/or leakage, odors same as PC 4.2.2 PC 6.1.4 Apply stowage requirements (e.g. segregation, separation, orientation) PC 6.1.5 Verify that NOTOC reflects against aircraft load PC 6.1.6 Verify passenger baggage requirements if applicable PC 6.1.7 Inform pilot-in-command via paper copy and flight operations officer/flight dispatcher CE 6.2 Manage dangerous goods during flight PC 6.2.1 Detect presence of dangerous goods not permitted in baggage this is not a performance criteria but an expected behaviour... how to teach it? PC 6.2.2 Apply procedures in the event of an emergency on pilot side: how do you assess this competency? Should it be integrated to initial/recurrent training syllabus? -Locate information sources to aid with DG incident -Determine appropriate action related to emergency response drill code -Determine a suitable course of actioin in event of DG spillage From NOTOC : -Able to determine location of DG -Able to identify UN or ID shipping number of DG -Able to identify number of packages of a DG shipment -Able to identify quantity of each DG shipment -Able to identify hazard class of each DG shipment -Identify Emergency Response Drill code as expansion of the PC “Apply procedures in event of emergency or identification of damaged or leaking package.” (or alternatively as a separate PC). This is probably the most applicable section to pilots yet is all condensed into a single, broad statement. PC 6.2.3 Inform flight operations officer/flight dispatcher/air traffic control in the event of an emergency in the appropriate order: inform ATC, then flight dispatcher and flight ops (if applicable), time permitting CE 6.3 Unload aircraft PC 6.3.1 Apply specific unloading considerations as applicable PC 6.3.2 Check packages for indications of undeclared dangerous goods +report any occurance PC 6.3.3 Check for damage and/or leakage + report any occurance PC 6.3.4 Transport cargo/baggage to facility/terminal
 1 (2%) 
 
 Please keep with the current approved method of provided the necessary requirements through training organisation with exam based assessment. Although not all is appropriate to each role the understanding of the entire process is useful for staff involved in the packing and shipping of DG.
 1 (2%) 
 
 We see with the new provisions opportunities as well as challenges: Opportunities; • Continues assessment requirements may represent an opportunity for training organizations to support the implementation especially for small and medium organizations outsourcing the DG training • If there is going to be more cost there must be identification of the cost benefit • Assessment needs to be done on the job environment, therefore it is more relevant for the trainee to prepare them to their job function Challenges: • Greater diversify the training programs and may have many variations depending on the composition of trainees. • Individualized exams will differ based on the job function. • Require of new training development programs, use of additional tools or technologies (such as exam generator, simulation tools etc.)
 1 (2%) 
 
 Competency based approach for DGR may be improved by a good guideline and adaptation work shops for programme developers. Thank you.
 1 (2%) 
 
 I will personally happy to have more information like AMC materials to grasp in new methodology. Videos, reading materials, workshops would be very practical and useful.
 1 (2%) 
 
 the overall objective of the programme is positive. There needs more specific guidance and clarification in a number areas Support programme should be provide to the industry before the fully implement the programme Below are some of the concerns: 1.        There is only two years’ time to organize and formulate the new programme, does the industry have enough resources and sufficient time to meet the requirements. 2.        Though the specific Performance Criteria has not yet proposed, we did not see any information on how to access the technical competence of the individual. For example, in CE 2.2.3 Assemble package. This involves a wide range of technical knowledge, such as in Packing Instruction PI208: When tightly packed to prevent movement in strong outer packagings and when charged to not more than 1380 kPa, at 21C the following conditions also apply.   Is the individual required to demonstrate how to measure the pressure of the article? Further, is the trainer required to demonstrate how to measure the pressure? If this is the case, then, the trainer must have all the technical knowledge as required in the DGR or we need functional specific trainer to provide this technical training.
 1 (2%) 
 
 1. The competency-based approach is very complicated for (freight forwarders) to understand and it is NOT well recognized in the market, hence very little incentive for employers to use this pathway to find the right worker as well as for employees to use this pathway to find the right company for career development, and encourage lifelong learning. 2. It would be difficult for the employers (in particular SMEs) to determine the "knowledge maintained by personnel performing specific functions" (technical terms of ICAO) for EACH of the staff (see template TABLE H.1.5.2.A, P.981-982 of IATA Appendix H, it will be very difficult for employers to fill out the DG Competency Framework form). 3. It would also be difficult for the forwarders to request their subcontractors to do the same, difficult to fill out the DG Competency Framework form. 4. Hence it may greatly increase the cost of assessment AND training for forwarders because: a. In case employers are not familiar with how to determine the "knowledge maintained by personnel performing specific functions "for each of the staff, outsourcing to the training consultant may be required. OR the employers will tend to save the cost of outsourcing by "ticking" all the boxes in the form in order to play safe. As a result it will totally defeat the purpose of competency-based approach. b. Tailor-made training on various functions the staff performing. c. No competitive pricing under standard training programme will be applied to this competency-based approach training. d. Tailor-made assessment on various functions the staff performing. e. No competitive pricing under standard training assessment will be applied to this competency-based approach training. 5. Hong Kong’s air cargo industry is very complex as we offer a variety of services including but not limited to consolidations. 6. It would reduce the flexibility of the company operation if new task is added to the staff who may not be trained in such new aspect. Under this circumstance, it would have adverse impact that the employer to request the staff to train all aspects out of their original designated functions (or add more functions under the staff to fulful this requirement). 7. The competitiveness of the market will be substantially undermined due to the above problems as it will not enhance the effectiveness of human resources management.
 2 (3%) 
 
 Read (or style) of the text in new training provisions differs from the rest of ICAO TI, which states "shall/must/should". Item 4.2.8 The text refers to Annex 6, which refers only for international operations. We suggest deleting this reference. In Finland ICAO TI is applicable to all flight operations, including domestic non-commercial operations. 2.2 Competency-based training and assessment: text repeating itself, more precise, shorter text would be preferred. 2.3 Competency-based provisions in ICAO and 2.4 Benefits: is this information relevant to the user of TI? Would it be better to insert all presentations, benefits and other "preparative" text to Annex 18 foreword text than in ICAO TI which is used as precise instructions how and what to do when transporting DG items. Again 2.4.1 is referring to Annex 6 part I and Part III which are for international operations and which will drop out e.g. domestic operations and helicopters in aerial work.
 1 (2%) 
 
 - CBTA methodology appears to be suited to larger organisations where there is less overlap between functions - Splintering training into competency units means that fewer individuals involved in dangerous goods will have a complete understanding of the dangerous goods shipping process. This could lead to a greater risk of misunderstandings/non-compliance and reduces the safety net effect of having people broadly trained in all aspects of the dangerous goods shipping. - Potential for increased costs: employers are likely to send employees on multiple training courses to cover required competencies. - Potential for increased costs: employers are likely to look for external auditors to review who should receive which competency training.
 1 (2%) 
 
 I can see a concern when it comes to the “employer determining the knowledge and skills needed “ for the employee based on their area of responsibility; job descriptions are often vague and incomplete and tasks and responsibilities are added over the years; would we then need to potentially add extra function in an / our organization to be in charge for these evaluations and the assessment of the employees competences; considering that we need personnel to be DG trained in all stations, this could be a lot of extra “control” staff needed; should we indicate that we prefer global standards and (external) training providers that are experts that we can send our employees to in order to receive the required level of training and competence Second issue I see is how to compare these “competency-based” training contents across the forwarding industry, i.e. if we hire somebody, we would not be able to determine easily if their certification will suffice our requirements and potentially have to evaluate them and have them re-trained according to our “criteria”; it would be better to have some ICAO standards / training packages that are pre-defined so that completed trainings are comparable in the industry; so for example for airfreight export there could be three different training grades, depending on the individuals involvement with DGR but if they are official levels created by ICAO the whole industry will work on the same levels and can easily determine what the qualification of a specific individual is Lastly, it would Need to be clearer what continuous assessment of skills and competencies means. Category based Training had the Advantage that there are just a few Options and with external Providers offering the Training it meant better Standardisation across the Company.
 1 (2%) 
 
 Dear Sirs, herewith I want to provide to you the following information: It is well appreciated that the implementation of a competency based training concept can add value. Nevertheless we have identified the following weaknesses: Safety Management System: No link to SMS, no training, not even awareness foreseen for Management staff Indirect are no functions included with a process oriented scope, i.e. flight dispatcher, security screener, reservation staff, etc. No minimum and standardized requirements are included Varying standards and quality may be applied by different countries (contradictory to international transports and common understanding) How can instructor qualifications be measured The employer having the responsibility of the training design may not have the expertise to take over this responsibility Complexity will increase and, due to the assessments, the training will become more time consuming How can training certificates be managed, when they are solely function based: Will an employee be able to change jobs at all, without re-training (inside and outside of companies) or can an employee be sent (for a limited period of time) to another country to support the local organization Implementation of a Dangerous Goods Safety Advisor (DGSA) role, comparable to road transport might be an option Audits: If each country sets different standards the training evaluation of e.g. handling agents gets more complex. To get the whole picture each inspector must always start from the beginning We are convinced that a common basis is required, i.e. a minimum training, ideally complemented by modular training parts according to the role/function and involvement of respective staff members and management. Currently, we see a high risk of failure due to uncertainties and potentially incorrect training set-up at certain providers. We assume that the financial burden for all stakeholders will increase without yielding the desired improvements. In case of any further questions please feel free to contact me. Kind regards Waltraud Hasse.
 1 (2%) 
 
 The proper Audits especially on external contractors will have considerable impact on the CBTA.The Instructors and Employers should be given Competency Based Training first and the necessary tools for the assessment of employees
 1 (2%) 
 
 • Training requirements should be flexible and not prescriptive, as there are widely varying levels of job function that require TDG training, from powered industrial vehicle (PIV) drivers who load or unload specific dangerous goods, to professionals who determine shipping names and certify shipping documents. Training requirements must address diverse needs and be commensurate with job functions and responsibilities. We agree that, as stated in 2.4.1.2, “…the depth of training each person receives should be appropriate to the functions performed. This could range from a familiarization level to expert level for dangerous goods professionals.” We also agree that, as stated in 2.5.1.1, “…personnel must be trained in the requirements commensurate with their responsibilities. …[E]ntities must train their personnel commensurate with their responsibilities and the functions they perform regardless of their job title.” A competency-based approach to training should be flexible to accommodate job-specific and site-specific competencies. For example, competency should only have to be demonstrated for those dangerous goods classes with which an employee works. We agree that, as stated in 2.7.2.2, “…employers must consider their own operational and organizational environments...”, and as stated in 2.7.2.2, “[t]he employer then determines the level of knowledge and/skills necessary to perform each of the customized competencies.” We also support that, as stated in 2.7.2.4, training needs should take into account “…preferred learning styles…and…the social and linguistic environments of…trainees, all of which could have an impact on the design of the training.” • Revisions to the training provisions in the ICAO Technical Instructions should not unnecessarily burden or penalise employers who are already implementing successful training programs. We support a goal, as described in 2.3.2, “…to develop provisions that would not put conventional…training methods out of compliance but would allow an alternative training path that made use of contemporary instructional methods.” We recommend that ICAO work through the UN Sub-Committee of Experts on the Transport of Dangerous Goods to implement a training regime for all modes of transport. Although the principles of competency-based training are supported, implementing dangerous goods training requirements in the air mode that are different from those in other modes may impose unnecessary burdens on employers. • The proposed Part 1;4.3.1 states, “Unless otherwise provided for by the appropriate national authority, instructors of initial and recurrent dangerous goods training must demonstrate or be assessed as competent in instruction and the function that they will instruct prior to delivering such training.” It is not clear who would assess the instructor and how the instructor would be assessed. We would suggest the text be amended as follows: “Unless otherwise provided for by the appropriate national authority, instructors of initial and recurrent dangerous goods training must demonstrate competence in instruction and the function that they will instruct prior to delivering such training.” • The proposed Part 1;4.2.9 states, “Dangerous goods training programmes required for entities other than operators and designated postal operators should be approved as determined by the appropriate national authority.” We recognise that this text is very similar to the current requirement in Part 1;4.1.2.3: “Dangerous goods training programmes required by other than 4.1.1 b) [operators] and h) [designated postal operators] should be subjected to review and approval as determined by the appropriate national authority.” Nevertheless, the meaning is not clear, and we would suggest clarification that such training courses are not necessarily required to be approved by national authorities but may be subject to their approval at their discretion. • The development and inclusion of guidance material on implementing a competency-based approach to training, as provided in Chapters 2 to 5, is beneficial and welcome. We note that the proposed revisions to the training provisions would no longer require a “test” but an “assessment”. As stated in the proposed Part 1;4.2.7.1 e), “The record of training and assessment must include…evidence which shows that personnel have been assessed as competent.” Also, as stated in 2.7.2.6, “…A trainee’s assessment may be completed through a variety of tools including observation of job performance, test, or other practical exercises.” Further guidance regarding acceptable forms of evidence of assessment, in addition to traditional test results and training certificates, could be helpful.
 1 (2%) 
 
 (Apologies if these responses are submitted twice. After the first attempt, there was no confirmation of submission, so we are trying again.) • Training requirements should be flexible and not prescriptive, as there are widely varying levels of job function that require TDG training, from powered industrial vehicle (PIV) drivers who load or unload specific dangerous goods, to professionals who determine shipping names and certify shipping documents. Training requirements must address diverse needs and be commensurate with job functions and responsibilities. We agree that, as stated in 2.4.1.2, “…the depth of training each person receives should be appropriate to the functions performed. This could range from a familiarization level to expert level for dangerous goods professionals.” We also agree that, as stated in 2.5.1.1, “…personnel must be trained in the requirements commensurate with their responsibilities. …[E]ntities must train their personnel commensurate with their responsibilities and the functions they perform regardless of their job title.” A competency-based approach to training should be flexible to accommodate job-specific and site-specific competencies. For example, competency should only have to be demonstrated for those dangerous goods classes with which an employee works. We agree that, as stated in 2.7.2.2, “…employers must consider their own operational and organizational environments...”, and as stated in 2.7.2.2, “[t]he employer then determines the level of knowledge and/skills necessary to perform each of the customized competencies.” We also support that, as stated in 2.7.2.4, training needs should take into account “…preferred learning styles…and…the social and linguistic environments of…trainees, all of which could have an impact on the design of the training.” • Revisions to the training provisions in the ICAO Technical Instructions should not unnecessarily burden or penalise employers who are already implementing successful training programs. We support a goal, as described in 2.3.2, “…to develop provisions that would not put conventional…training methods out of compliance but would allow an alternative training path that made use of contemporary instructional methods.” We recommend that ICAO work through the UN Sub-Committee of Experts on the Transport of Dangerous Goods to implement a training regime for all modes of transport. Although the principles of competency-based training are supported, implementing dangerous goods training requirements in the air mode that are different from those in other modes may impose unnecessary burdens on employers. • The proposed Part 1;4.3.1 states, “Unless otherwise provided for by the appropriate national authority, instructors of initial and recurrent dangerous goods training must demonstrate or be assessed as competent in instruction and the function that they will instruct prior to delivering such training.” It is not clear who would assess the instructor and how the instructor would be assessed. We would suggest the text be amended as follows: “Unless otherwise provided for by the appropriate national authority, instructors of initial and recurrent dangerous goods training must demonstrate competence in instruction and the function that they will instruct prior to delivering such training.” • The proposed Part 1;4.2.9 states, “Dangerous goods training programmes required for entities other than operators and designated postal operators should be approved as determined by the appropriate national authority.” We recognise that this text is very similar to the current requirement in Part 1;4.1.2.3: “Dangerous goods training programmes required by other than 4.1.1 b) [operators] and h) [designated postal operators] should be subjected to review and approval as determined by the appropriate national authority.” Nevertheless, the meaning is not clear, and we would suggest clarification that such training courses are not necessarily required to be approved by national authorities but may be subject to their approval at their discretion. • The development and inclusion of guidance material on implementing a competency-based approach to training, as provided in Chapters 2 to 5, is beneficial and welcome. We note that the proposed revisions to the training provisions would no longer require a “test” but an “assessment”. As stated in the proposed Part 1;4.2.7.1 e), “The record of training and assessment must include…evidence which shows that personnel have been assessed as competent.” Also, as stated in 2.7.2.6, “…A trainee’s assessment may be completed through a variety of tools including observation of job performance, test, or other practical exercises.” Further guidance regarding acceptable forms of evidence of assessment, in addition to traditional test results and training certificates, could be helpful.
 1 (2%) 
 
 Having spent 27 years on the operator side of dangerous goods and the last 20 also as a trainer for all categories my personal opinion is that the focus should be put on the instructor qualifications rather than changing the entire system. The CBT approach to Dangerous Goods Training is not entirely comparable to the CBT described in the PANS-TRG and the majority of the difference is in instructor, Examiner, Inspector qualifications. After receiving your pilots’ license you can’t call yourself an instructor, but with DG it is enough with a valid certificate and “adequate instructional skills”. The DG world really needs something like Chapter 4 from the PANS-TRG, that would make more to enhance the safety of aviation than changing the whole training regime.
 1 (2%) 
 
 Ithink it´s very unusable for hazamt specialists to made the work for differnt compnies! So I think the terms which we have no are the right and we get in trouble when the new rules for training will be done. Because this is in case of hazmat speialist with ore customers not possible to do!!
 1 (2%) 
 
  lovely idea and feel that I was developing materials as a traitor to create the 1st steps for such a model as far back as 1994. The US DOD also developed an analogous starting point for competency-based training in their DLA I 4145.11. Again this was looking at the formal training course requirement not a competency-based evaluation program. It is actually critical that the articulation of this concept clearly separates while adequately defining the overarching training program lease as distinct from the initial formal training courses.
 1 (2%) 
 
 it would also be nice to see a national / international type of certification available. It could be modeled similar to an engineer or other professional type of certification. I feel that this would help close the gap on training and companies would have the option of requiring an employee to be certified to a particular level.
 1 (2%) 
 
 teesting
 1 (2%) 
 
 Thank you for offering such a more specific training program
 1 (2%) 
 
 1
 1 (2%) 
 
 thanks to developing dangerous goods training
 2 (3%) 
 
 This is a change that is not required and does not improve the level of safety in any way. This is just going to lower the level of training being provided to staff and may result in seriour incidents and accidents.
 1 (2%) 
 
 http://www.riadazama.com
 1 (2%) 
 
 Thank you for the opportunity to express my opinion.
 1 (2%) 
 
 no
 1 (2%) 
 
Total: 66