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Part 92 Post Implementation Review
Background to the changes that Part 92 introduced
- Shippers to undertake approved training courses in dangerous goods handling conducted by industry instructors in accordance with recent changes to ICAO requirements
- Cabin Crew DG training courses to be approved by the Authority
- Additional operators to maintain a dangerous goods manual in accordance with changes by ICAO
- Employees to have ability to gain necessary (DG) qualifications on a single course
- All training valid for 2 years
- A period of grace for employees to also apply to enable employees to re-qualify in (DG) training qualifications
- Automatic exemptions for certain operators from the requirement for (DG) training and from the regulations for certain types of operations
- Automatic exemptions for groups such as emergency and police services to carry certain equipment
- Certain statutory exemptions i.e. Display parachute jumpers; carriage of DG in helicopter underslung load, non-class B cargo compartments etc. Standing exemptions for DG carried by police aircraft and on aircraft engaged in emergency service operations.
Part 92 PIR Working Group
The Part 92 Post Implementation Review is managed by Ben Firkins, Dangerous Goods Inspector, Safety Assurance Branch. The Part 92 PIR Working Group is comprised of prominent safety experts in aviation and dangerous goods from a number of airlines, freight forwarders, training organisations and regulators. Regular updates on the progress of the working group is provided to the Australian Dangerous Goods Air Transport Council.
Some of the things proposed in the PIR
- Proposals to align and update Part 92 with ICAO Standards and Recommended Practices and the ICAO Technical Instructions, such as:
- All operator DG Training courses proposed to be CASA approved - this would broaden the proportion of an operator’s employees requiring an approved training course to include ramp, customer check-in and security screening staff courses. Most of these employees already complete an approved course. There have been a number of examples where un-approved courses are not being kept up to date.
- Failure of a DG recertification course exam is proposed to in future to preclude the employee from continuing to accept dangerous goods.
- A requirement that persons who open packages for inspection, including regulatory authorities and Customs Officers, return the package to a proper condition for carriage (in alignment with the ICAO Technical Instructions).
- Occurrences of hidden or mis-declared dangerous goods being reported in accordance with the requirements of the ICAO TIs.
- Proposals to clarify Regulations which are the source of confusion:
- DG Manual - when is an operator required to have a DG Manual.
- Clarifying that DG Instructors under training are required to hold an instructing approval.
- Proposals to improve tools for enforcement:
- Introduction of complementary offences and penalties in the CASRs for the unlawful carriage and consignment of DGs to those that exist in the Civil Aviation Act 1988.
- The authority for certain CASA inspectors and other certain persons to open packages to ensure that:
- dangerous goods are packed in accordance with the ICAO TIs; and that
- General cargo does not contain hidden or misdeclared DGs.
- A proposal to clarify and document certain standards and common practises, without imposing additional regulatory burden
- The development of a Manual of Standards relating to DG Training, DG Courses, and DG Instructor Development.
Some of the things completed during the course of the PIR
- AC 92A-01 - The consignment and carriage of dangerous goods on all aircraft in Australian territory and on Australian aircraft overseas. An overview of the legislative framework and procedures. This Advisory Circular provides an overview of the dangerous goods legislation in the aviation environment and its application in Australia.
- AC 92-03(0) - Dangerous Goods Training Courses and Instructor Approvals. This provided indicative guidance to DG course producers with an expansion on the syllabus items and examples of what should e covered in a DG course for various types of employees. This new AC also articulated the process and form of application to be undertaken when developing and submitting a course.
- AC 92-04 - Dangerous Goods Permissions. The legislation and the articulation of how to apply for a permission to carry dangerous goods in Australia, where those goods are not packaged in accordance with the ICAO TIs.
- AC 92-05 - Use of Compressed Oxygen: Carriage of Live Aquatic Animals in Air Transport was produced, based on an update of existing material in CAAP 262A-1, in order to reflect contemporary practices and improvements.
- AC 92-07 - Radioactive, Class 7; An Overview To Transport By Air In Australia was produced to provide a general overview to the transport of radioactive materials and how to obtain competent authority approval for radioactive packagings.
- Publication of the Part 92 PIR
- Development of a Notice of Proposed Rule Making which will be made available for consultation.
- Development of a Manual of Standards on Dangerous Goods Training.
- Development of additional Advisory Circulars; in particular:
- AC 92-06 - Dangerous Goods Incidents - Preparation, Management, Investigation And Reporting
- AC 92-08 -Dangerous Goods that may be carried by Passengers and Crew
- AC 92-09 - UN specification packaging
- AC 92-10 - Statement of Contents - Dangerous Goods
- AC 92-11 - Operators that do Not Carry Dangerous Goods
- AC 92-12 - Private Pilots and Dangerous Goods
You should look at the current version of CASR Part 92 and associated advisory circulars.