Organisations involved in the transport of packaged dangerous goods by sea must ensure that their land-based personnel can adopt, implement and comply with the International Maritime Dangerous Goods (IMDG) Code. The Human Environment and Transport Inspectorate (ILT) oversees compliance with this in the Netherlands.
Relevant roles and training
Chapter 1.3.1.2 of the IMDG Code sets out the roles in which employees must be able to work in accordance with the provisions relevant to them. They must have completed training to increase general awareness of dangerous goods and role-specific training.
A VLG/VSG-opleiding (qualification for the transport of dangerous goods by road or rail) is not sufficient for application of the IMDG Code. Transport by sea involves different conditions, requirements and regulations than carriage by road and rail.
Required register of employees and training
In accordance with chapter 1.3.1.3 of the IMDG Code, you must maintain a register showing:
- Which employees are required to have completed training.
- The required level of training.
- The training methods used.
- Which subjects are covered in which training courses.
- When employees completed their training.
You may decide the format in which this register is kept. Employees must remain listed in the register for as long as they are employed.
You may provide the required training in-house or engage an external training organisation. There are no required government accreditations for these training organisations.
Oversight by the ILT
During company inspections, the ILT requests the information from the register of employees and training. You must be able to demonstrate that your employees have completed the training required for their roles. The ILT may question employees to test their knowledge.
In the event of dangerous situations, the ILT takes enforcement measures.