Since Canada first created regulations on the transportation of dangerous goods, those who “handle, offer for transport or transport” dangerous goods must be adequately trained. The question, of course, is what does “adequately” mean? Section 6.2 of the Transportation of Dangerous Goods Regulations (TDGR) says that it means “the person has a sound knowledge of all the topics … that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport,” but that still doesn’t clarify how the employer should verify that the knowledge is “sound.” Now Transport Canada, in consultation with the Canadian General Standards Board (CGSB), has attempted to answer that question.
On August 30, the CGSB put out a draft of a proposed training standard that reflects current international work on “competency-based training.” This standard is not available on a website, but may be obtained by contacting Beata Hart of the CGSB at Beata.Hart@tpsgc-pwgsc.gc.ca for a PDF copy. Comments are due on October 24th, 2019.
The proposed standard would establish two levels of training. First, a “general awareness” segment, that should be approximately 2 hours long, which would cover the basics of how the TDGR works. Then, when employees are familiar with those concepts, they would receive “job specific” training, which would specifically address the job functions they do in that organization.
This would, of course, require the employer to perform a detailed job analysis before determining what needed to be covered in the training. What exactly does each employee do? Shipping papers? Packaging? Classification? The employer will not only have to evaluate each job, but keep records of how they established the “task descriptions and performance criteria” for each. Fortunately, the standard includes some detailed guides on how to do this.
Next, the employer would have to establish how they would evaluate competency of the employee. The standard allows written testing (indeed, the basic awareness section seems to imply it would be the standard method of evaluation), but it also offers alternatives, such as hands-on evaluation using a check sheet. However, the evaluation must be documented strictly, whether it is done by a quiz or by observation.
As a trainer, I feel this proposed standard has a mixture of good and bad features. Its stress on documenting exactly what a job entails, and directing training towards those aspects of the job, is something I like. Training without deciding first what you’re trying to achieve can be frustrating for employees, trainers and employers. The detailed charts in the standard should make it relatively easy for employers to figure out what each employee has to know. In the long run, this should make the job of planning your training a much simpler process.
I really like the options provided for training evaluation, since not all employees, even those quite competent in their duties, perform well on written evaluation such as quizzes. The standard encourages some creative solutions to evaluating the job-specific portion of the training.
If there’s a weakness in the standard, I think it lies in the general awareness, or “TDG 101” as some have informally called it. While the standard provide admirable flexibility in the job-specific training, the general awareness portion of the standard is very prescriptive. It describes not only how long the training should last but how it should be evaluated, what a passing mark should be and how to deal with those who don’t pass on their first attempt. This seems at odds with the rest of the standard’s admission that multiple methods of training as well as evaluation are best suited to the varied demands of Canadian workplaces. It also seems to demand that the awareness training be an entirely separate training session to the job-specific one, at least when training groups, since each attendee would have to pass the awareness session to move on to the job-specific one.
However, remember that this is the first draft of the standard. If you’re involved in training for your organization, we recommend you read through the standard and let the CGSB and Transport Canada know your thoughts. Should it become more flexible? Or would you like stricter guidance on how to verify employees are truly competent? What’s the best way to keep the Canadian transportation system safe? Keep that October 24th end date for submissions in mind.
Again, you can request a copy of the standard by contacting Beata Hart of the CGSB at Beata.Hart@tpsgc-pwgsc.gc.ca. If you have any questions about the implications of the standard, or how ICC could help you move ahead with it, please contact us here at 1-888-977-4834, and ask for a regulatory specialist. And if you have any comments about the standard, please send them in. This is a step into new territory for training in Canada, and your voice is important to making it a step in the right direction.