It only took me about 19 years to finish college. Surprisingly, I did take some courses in most of those years. I’d enroll, go awhile, and then take some time off. I’d finish a class or two, drop a class or two, or even just not finish without dropping out. That last habit didn’t help my grade point average, and after about a decade one university told me that I was no longer welcome to re-enroll. I moved somewhere else, where my habits caught up with me, and I enrolled in a night class at a different university. I quit quitting classes, but still only puttered along one class at a time. P-chem with calculus and I didn’t get along real well, so it got dropped semi-regularly. I was like a lifelong student, but without accumulating multiple degrees. Of course, I worked quite a bit, too. Sometimes, I’d work one full-time job and one part-time job, or a couple part-time jobs while taking just one college class. But, eventually something had to change.
Impending fatherhood brought a major attitude adjustment. I, personally, was okay living paycheck to paycheck, in dumpy accommodations, with a variety of low-ceiling jobs. And it was quite a variety of jobs. I usually quit my jobs after nine months to return to being a summer camp counselor. So, I’ve quit jobs as a janitor, pumping petrol, managing fast food restaurants, sorting parcels, landscaping, and bussing tables. But nine month stints at these jobs doesn’t add much to the college fund of an unborn baby, so with one monster semester, taking so many classes I had to get special permission, I finally finished college, and earned multiple bachelor’s degrees. (Thanks, Dad, for paying my bills that semester). Those degrees allowed me to get a huge raise (thank you, Ray Goff), and helped me along the path to glorified magazine columnist (thank you, Peter). And the youngest of my children is now well on the way to joining her predecessors with college degrees of their own.
So, what does this have to do with Dangerous Goods (HazMat for transport)? Well, I’m also a bit of a packrat, which my wife might say is a bit of an understatement. I recently got back from a training trip with paper copies of the DG regulations in my backpack. As I complained about how heavy the backpack was, I happened to glance at an old chemistry textbook on my bookshelf and realized the regulations are bigger! I lined up my general chemistry, P-chem, and organic chemistry textbooks, threw in an analytical chem lab manual for good measure, and noted that they took up less space on my bookshelf than the combination of IATA, IMDG Code, and ground regs (you choose, ADR or 49CFR). And then the timeframes hit me. Sure, most people don’t take 19 years to finish a bachelor’s degree, but the ‘normal’, shorter time is four years. And how does that 4-19 year range compare to initial multi-modal training? There are a number of one week (5 day) multimodal classes available, but there are also a number of 1-day multimodal programs out there, especially on the Internet. So, 1-5 days versus 4-19 years!
Okay, okay, I concede that I wasn’t in general chemistry class eight hours a day, but I do remember an organic chemistry lecture Tuesday and Thursday nights from 7:00 pm to 10:00 pm. In just that one class, over the course of the semester, I received more hours of instruction than anyone gives in a 5-day DG course. There is a huge, order(s?) of magnitude difference in the time spent teaching chemistry versus teaching global transport safety, even though chemistry takes fewer pages.
“Ah”, one might say, “chemists have to know what’s on every page, while DG folk don’t need to know every single regulation”, and there is some merit to that argument. But flipping through my chemistry texts, there were pages and pages of exercises, and lots of pictures and drawings and illustrations. The DG regs have no exercises that I know of, and precious few pieces of non-text information. Plus, I found a couple of chapters in each chemistry book that we didn’t actually cover in class. There’re certainly more words in HazMat regulations that the chemistry texts, so to rephrase the objection, perhaps one might say “we can probably skip a lot more of the words in the regs than a chemistry professor can skip in the chem texts”.
Again, there’s some merit to that view, but I contend it’s not as big a difference as you might initially believe. Consider some of the following examples of DG trainees who thought that what they needed to learn was much less than what they actually need to learn. A pharmaceutical product customer thought they only needed to learn how to ship proper shipping names beginning with “Medicine…”, but they have aerosol asthma inhalers, dermal patches containing an explosive, a self-heating antibiotic ingredient, and zit medicine containing unique formulations of an organic peroxide. An alternative energy company thought they only had pieces of metals and plastics, with an occasional DG paint or lubricant, but they had radioactive materials in the smoke detectors in some of their products. A customer supplying a proprietary polish to the electronic manufacturing industry had only one regulated product, and that in Class 9 in small amounts, but had to re-ship some incoming IBCs of Class 8 raw materials that failed their QA/QC standards. A drum manufacturer puts a lithium battery powered RF communicator on a float inside a 208 liter steel drum, which allows accurate determination of the remaining volume of whichever liquid is inside the drum, but which also makes them an offeror of HazMat as well as a manufacturer of HazMat packaging. An environmental remediation company thought they only had a few small field analysis kits, but didn’t know their aerosols were DG, and eventually realized how many different HazMat/DG materials were in their mobile labs, from acetylene to alcohol wipes to compressor fuel to paints to cleaning compounds to…, well you get the idea.
Or perhaps I can make the point differently. How many of IATA’s ‘yellow pages’ of Packing Instructions will a DG trainer have to cover in a public class to have introduced packaging/packing/filling concepts for: aerosols, UN-specification cylinders, OP methods for 5.2 (and some 4.1) materials, Category A packaging (a 9-metre drop test!) and Category B triple packaging, liquids in combination packaging that do require absorbent and liquids in combination packaging that don’t require absorbent, drums marked for solids versus drums marked for liquids, PG II packaging for certain PG III materials, ID8000 (Consumer Commodity) packaging, additional leakproof requirement for most solids containing flammable liquids, dangerous goods in apparatus/machinery/equipment, lithium battery packing, and non-lithium battery packing? I suppose it would be piling on to add fireworks, construction explosives, explosive safety device components, ammunition, and radioactives whether excepted or not. I don’t think “function specific” means to just let a student later read an unfamiliar type of PI and teach it to herself/himself merely by reading it. So, a quality public class will have had to review each ‘type’ of packaging/packing potentially encountered. Similar argument can be made for classification, especially trying to teach about the relevant data needed and the associated tests, without using a UN Manual of Tests and Criteria. Or do all the good public courses in IATA also use the UN Manual of T&C?
And then there’s the Dr. Valet factor (name changed to protect the guilty). My worst professor merely read the textbook out loud, monotone, one time through, head down without even looking at his audience. We got no benefit of instructional techniques, such as reading information one way and hearing it reworded slightly differently, repetition, instructor-student interaction, demonstration, or just a chance to ask a question. Oh yeah, sometimes we got out of class a few minutes early because a day’s material had been covered, which, even as a teenager I had mixed feelings about. Fortunately, I had a lot of great professors who utilized a lot of great instructional techniques. Dr. Dresdner drew chalk drawings to accompany everything he said, sometimes with such speed and enthusiasm that his entire upper body would be covered with chalk dust at the end of a lecture. Dr. Horton would look students in the eye, one by one, to see if we were lying when he asked if we were ‘getting’ what he was teaching. Dr. Deyrup knew us all not just by name, but by interests, lab work, and which other classes we each had or hadn’t taken yet, and so he’d often explain how a concept could be applied to one of us in particular. Dr. Appledorn had a sense of humor that he wasn’t afraid to use in class. Dr. Knopp would ask us questions if we didn’t ask him any. Dr. Ryschkewitsch had demonstrations in each and every class. And, please forgive me for forgetting his name, but a professor got me through P-chem (with an A, no less) by explaining everything twice, using different words the second time through. And the good techniques worked, because I learned and retained.
How much emphasis do we put on instructional quality in a 5-day multimodal course or a one-day on-line multimodal training? Do we demand our instructors have a CDGT? No, we don’t. We don’t demand face-to-face training nor even insist on the possibility of trainer-trainee interaction. Do we insist on full coverage of the necessary information? Not if we, not just enforcement, but we as industry consuming such training, allow a full-scope, non-customized, one day long initial multimodal. Have we an appreciation for the importance of repetition in learning, even if we haven’t formally studied the “Law of Repetition”? Probably not, if we claim we’re training thousands of pages of regulations in just 40 hours. Do employers generally allow re-taking of classes until the material is truly understood, a la my boneheaded self and P-chem? I once suggested to an employer that a certain trainee didn’t ‘get it’ enough to work safely with HazMat yet, only to be told that productivity was too important to allow the employee to re-take the course with the next batch of students. Pass or fail is usually an employer decision, as is scope of training, but had it been an air class I think I would have notified HR/Legal/CEO in writing that the employee was unqualified and thus potentially unsafe. Still, based upon conversations with other instructors, many employers are very resistant to allowing any employee to be in a single minute of training above the absolute minimum. I do note an exception to this last observation, in those who operate aircraft, though this seems a fairly limited exception.
Extensive pondering hasn’t led me to any reasonable regulatory solutions to the problem of inadequate training, regardless of whether the inadequacy is from lack of time, poor instructor skills, lack of repetition, limited scope, or failure to use multiple instructional techniques. If the solution isn’t in changed regulations, where is it?
Might it start with the knowledgeable consumers of DG training? Might it be best to informally develop higher industry standards by selecting a highly qualified instructor, giving adequate (more than minimal) time for training, and letting chemistry develop? No, not the atoms, bonds, molecules, and ions type of chemistry, but trainer-trainee chemistry and consumer-service provider chemistry. Wouldn’t this chemistry foster more effective learning, greater long-term retention, a more compliant workplace, and a safer world? I think so.
I’ve got some chemistry. But so do lots of CDGTs, and so do lots of members of DGTA, and so do some others. Choose a highly qualified instructor, not just qualified as a subject matter expert but also as a deliverer of information, and then give her/him the time necessary to be maximally effective. Especially since the topic is Dangerous Goods, not chemistry.