The decision to review and amend regulations on the safe transportation of dangerous goods by air will significantly improve safety, even if the process is slightly more onerous.According to Elliot Molemi of the Professional Aviation Group, the new compliance pathway to dangerous goods by air instituted by the South African Civil Aviation Authority (SACA A) will align South Africa’s regulations with those of the International Civil Aviation Organization (Icao), ultimately delivering a safer air transportation environment.Speaking during a recent online event, he said the proposed SACA A amendments to Air Cargo Security Part 92 were currently still with a working group and it would be some time before they became law. “The working group ensures engagement between industry and the SACA A. Once completed it will move to the regulation subcommittee and from there to the minister for promulgation to law.”The regulations could still see some back-and-forth movement between the various entities and stakeholders before being finalised.“In my experience, this does take some time. I don’t foresee this process completed for at least another six to eight months.”According to Molemi, the amendments are an important development to improve safety.“Our regulations will now align with Icao’s annexe 19, while it also clarifies the requirements and processes for the movement of dangerous goods – as well as what necessary training is needed by the industry.”Molemi said one of the biggest changes to Part 92 was its applicability. “In the past, it was only applicable once the cargo arrived at an airport. The regulation is now extended to a far wider group. It will in future apply not only to the airports but also to the dangerous goods testing facilities, packaging companies, and drones. Shippers, freight forwarders, and couriers will have to comply and be regulated going forward.”He said this would require industry to engage and work together, as a shipper could be anyone – from a major exporter or importer to a granny sending a parcel from a suburb.“Entities will also, under these new regulations, be required to make an application to the SACA A to be approved to process and transport dangerous goods. These applications will have to be renewed every month. The approval certificate will also have to be displayed prominently either in the warehouse or reception area of the entity.”Another important change is that companies will be required to appoint a person within their organisation responsible for dangerous goods who has a risk management or safety management qualification, as well as a Dangerous Goods Category 6 or equivalent competency-based training qualification. “This employee will be responsible for overall compliance with the regulations, liaising with the SACA A, the reporting of accidents and incidents, and conducting quality and risk inspections for the company.”He said entities would also in future have to draft a procedures manual that must be approved by the SACA A detailing all processes of accepting, handling, storing and transporting dangerous goods. “The manual must also include detail of response procedures to any incidents, including spillage.”Another important change industry must take note of is the requirement for a designated dangerous goods area. “To date, outside of the airport this was not law, but this will now change. A designated area will be required and it must have a segregation chart. An emergency response procedure, contacts and a spill kit will also be a requirement for the dangerous goods area.”One of the more contentious items of the amended regulations is the statement that will be required for cargo movement. “A written statement declaring that cargo does not contain dangerous goods will be required from every place cargo is picked up from. This statement or declaration is to try and establish if any shipment contains undeclared dangerous goods,” said Molemi. “All incidents involving undeclared or misdeclared dangerous goods must, by law, be reported to the SACA A in writing within 48 hours.”
