Srinivasan Raman: Signing a Dangerous Goods Declaration. Who’s Responsibility?

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Shippers Declaration for Dangerous Goods or Dangerous Goods Declaration (DGD) for air transport not meeting the applicable provisions of ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air and the IATA Dangerous Goods Regulations is direct breach of Law and is subject to civic or criminal penalties.

The Declaration “Must” be prepared and signed by the shipper.

ICAO Technical Instructions and IATA Dangerous Goods Regulations have laid down standards for this purpose. IATA Dangerous Goods Regulations clearly states that It is acceptable for persons or organizations (including consolidators, freight forwarders and IATA cargo agents) employed by the shipper to act on their behalf to undertake the shipper’s responsibilities in the preparation of the consignment and as trained in Subsection 1.5 to sign the Shipper’s Declaration for Dangerous Goods.

In addition, the freight forwarder who undertakes the shipper’s responsibilities must meet all the training requirements for shippers and they must also have a contractual arrangement that clearly defines the various responsibilities that the freight forwarder is going to take on behalf of the shipper.

Many shippers pass on their responsibility of preparing the dangerous goods documents to their freight forwarders, who issue the Air Waybill and other relevant documents for air transport and organize for the transport. These freight forwarders, who being trained on dangerous goods, further outsource for the preparation of the Shippers Declaration to a third party organization who is not at all involved in any of the functions between the shipper and the forwarder. This many a times have resulted in incidents or mis-declaration. Due to this practice, even the competence of the shipper or the freight forwarder cannot be judged subsequent to the training.

There have been instances where freight forwarders and cargo agents handling DG consignments, having attended the DG training and certified to sign, still do not undertake the responsibility as their excuse made is “our company policy does not allow our staff to sign DGD”, even though the staff are DG trained.

The third party organization staff who takes the responsibility of signing, many a times does not know about the internal and external packaging used, condition of the package, quantity (if it is as per the regulations), cushioning material used, marking, labeling etc. as he/she may not have seen the packing physically which results in incidents and accidents.

 

Srinivasan Raman

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