No Reason to Change Current Dangerous Goods Training!
The ICAO Dangerous Goods Panel (DGP) has recently developed a new proposal for competency-based dangerous goods training.
The Panel, with IATA playing a contributing role, went as far as publishing possible new criteria for the training and assessment of those who ship dangerous goods by air.
The Panel’s objective is the following:
“The objective of competency-based training and assessment is to use the necessary tools to clearly establish the training needs for a specific job function and then ensure that employees acquire the level of knowledge and demonstrate the right skills to perform that function. In order to support this objective, the ICAO Dangerous Goods Panel (DGP) has developed a new proposal for competency-based dangerous goods training and guidance material to support the approach.”
They have also posted this white paper from the IATA Dangerous Goods Training Working Group (DGTWG) – IATA White Paper IATA is encouraging active participation from DG training organizations and has requested their feedback by March 31, 2017. CIFFA will provide feedback and state that there is no rationale to support that the current IATA/ICAO air dangerous goods (ADG) DG training is inefficient.
Is there a good reason to move to competency-based training?
It is very difficult to support any change to the design and delivery of any training without knowing if the current training method is flawed or ineffective.
IATA declared in a recent webinar that competency-based training has worked best in other training programs offered by IATA and /or ICAO. However, this in itself is not a sufficient reason to change ADG training, IATA and ICAO should determine if there is any problem with the current training approach, model and results.
For example, are there statistics on mis-declared or improperly packed, labelled or documented shipments? Can these errors be linked to a fault in the current training program? Or are there other contributing factors?
Is it possible that mid-year compliance changes, operator or state variations added each year inhibit the ability for competent employees to be informed in time? If there are errors in shipments, could the issue be that there is a lack or motivation on the part of employees to properly pack and document the shipment? Are the incentives and disincentives strong enough to ensure compliance? If we can discount these and other factors, then, and only then would I recommend altering the training approach.
Before embarking on a monumental shift in the way training schools deliver training, and in the way employers must train and assess under a new system, it is imperative to first answer the questions posed above.
What is competency-based training (CBT)?
If it’s determined that competency-based training become the requirement, the freight forwarding industry would face myriad issues in changing to CBT. Aside from the obvious time and money commitment to alter the training, will it even be effective for freight forwarders?
The chart below is taken from the IATA white papers, and defines the difference between traditional training and CBT as follows:
The current IATA/ICAO model of training already allows for a narrower scope of knowledge, and is not job title-driven but aims to fit the role of an individual (forwarder, shipper, operator and their key responsibilities). It should be made clear that the current training model does not fit this definition of traditional training. I would argue it already leans towards CBT.
Let’s define competency-based training. It is training that is designed to demonstrate that a learner can do something….anything. Make a cup of tea, complete a load of laundry, or teach your dog to retrieve your slippers. But to be deemed successful, you must demonstrate the actual act of doing this, and perform it consistently over time on your own.
For example, I recently taught a friend how to complete an online e-mail transfer of funds. A CBT approach to learning this task would involve more than showing her or telling her how to do this on her smartphone. CBT training would require me to assess that my friend can complete each step in the transfer of funds, and be able to do this multiple times with success. This would make her “fully competent” at this task.
Competency-based training requires the following support system to be successful:
- Multiple trainers or coaches
- Time commitment to follow up with the learners as they complete an actual task
- Organizational commitment to CBT requirements including coaching and mentoring and analysis on the job
- Materials to simulate real world competencies if they cannot be assessed on the job
In the freight forwarding industry, there will be a heavier onus on employers to train and CONTINUALLY coach and mentor individuals working with DG, as is seen in the change listed below from their August 2016 document.
“Inclusion of reference to continuous assessment aims to confirm that the employee can continue to demonstrate the required level of competence to perform the job function. Currently a final test upon completion of the training is useful in terms of confirming understanding however may not identify or measure the employee’s ability to perform the real job.”
Also from the white papers, the DGTWD lists:
Two major positive impacts of CBTA proposal are:
- Closer involvement of the employer in determining the needs and measuring performance in a more precise way,
- An increase in employee’s engagement as a result of a closer correlation between the training content and job performance assessment
If you are employed by an airline, regulator or shipper, and your organization has an internal training team where there is the ability to implement coaching standards throughout the organization, then this form of training is optimal.
However, a large number of employers and their employees rely on certified ICAO and IATA training schools for their DG compliance training. They come from small, medium and large firms. A training school like CIFFA would have no way to follow up with on the job training, or confirm if it is being complimented by an employer. We would also be unable to offer a wide selection of training programs geared to specific competencies, as we could not fill classes to cover expenses.
In summary, the objective of ICAO and IATA is to include these changes to the dangerous goods training requirements as part of the 2019-2020 edition of the Technical Instructions. I would ask again, is this change necessary? Has there been proper analysis to justify this change? If this change is to occur, how will this affect training schools supporting small to medium employers? If true competency-based training cannot be enforced, implemented and evaluated at the employer level, then it should not be attempted.
The current training offered by certified IATA schools is comprehensive, updated and approved yearly, and includes testing standards that are difficult and that aim to mirror circumstances encountered on the job. So why change these?
Post script: If ICAO/IATA choose to move forward with the change to competency-based training, the 2019/ 2020 timeline for such an implementation is unrealistic given the scope of change required.