Must I Employ a DGSA? I’m Just a Consignor!
If you believe that as a “Consignor Only” you are exempted by derogation from the requirement in ADR to employ a Safety Advisor (DGSA), then the Regulations are changing from the 1st of January 2023.
ADR 126.96.36.199 states “undertakings which participate in the carriage of dangerous goods only as consignors, and which did not have to appoint a safety advisor on the basis of the provisions applicable until December 2018 shall, by derogation\’s from the provisions of 188.8.131.52 applicable from 1 January 2019, appoint a safety adviser no later than 31st December 2022”.
The previous derogation from the requirement to appoint a DGSA (as listed in 1.8.3 below) for businesses that only consigned dangerous goods was amended in ADR 2019 but included 4-year phase in period which will ends on 31st December 2022.
ADR 184.108.40.206 states that “each undertaking, the activities of which include the consigning or the carriage of dangerous goods by road, or the related packing, loading, filling or unloading shall appoint one or more safety advisers for the carriage of dangerous goods, responsible for helping to prevent the risks inherent in such activities with regard to persons, property and the environment”
With the removal of the previously mentioned derogation, all entities consigning, transporting, packing, loading, filling, or unloading dangerous goods will require a suitably qualified Safety Adviser (or DGSA) by the end of the year.
Below is a link to a Department for Transport (DfT) video explaining the changes and options
If you decide to engage the services of a Consultant DGSA then PLSS would be pleased to understand your requirements and provide a proposal.
By PETROCHEMICAL LOGISTICS SUSTAINABILITY SOLUTIONS (MARK APPLEYARD) LIMITED