A few weeks ago, the FlyingTypers
exclusive report, “I
Want You Harmonized" offered our global audience an updated overview
and opinion of how the Global Harmonized System (GHS) is finally maturing
and impacting the ways of international trade and commerce.
So far, there has been significant progress
toward greater harmonization in most areas of the world; 49 CFR (the U.S.
legal foundation for the transport of dangerous goods—or hazardous
materials, as they’re called here) especially has seen a great amount
of changes, including a move to universal language as a driver toward
harmonizing with UN Model Regulations.
But Germany
Is Different
Across Europe, the European modal framework
for transport by road, rail, and inland waterway are ADR, RID, and ADN.
Likewise, application of the IMO’s IMDG code is mandated for maritime
shipping.
Theoretically, this should warrant a uniform level of training and implementation
of the rules--but not in Germany.
Watch Your
Language
Although the ADR has three official languages--English,
French, and German, which are equally acceptable--dangerous goods departing
Germany or Austria or transported domestically by road must be declared
by law on the shipping paper in German.
So elsewhere where the rule is harmonized,
with regulations, uniform terms, language, and multi-modal training streamlined
and simplified in English, that is simply not the case in Germany.
Most everywhere else in the world packaging
utilizes markings, packaging specification markings, hazard labels and
placards, and handling labels that are reviewed and updated regularly.
But in Germany, the surface mode transport
manual translations have for decades been maintained and updated by the
same three gentlemen and—putting it bluntly—their command
of the English language must be seriously called into question.
Baseline
Problem Is Training
While every trainer worth his salt emphasizes
that there is no such thing as an “Excepted Quantity Label”
or “Limited Quantity Label," but only an “Excepted Quantity
Mark” and “Limited Quantity Mark”, the German Manuals
use the term “Kennzeichen” (meaning “label”) not
only for the Excepted Quantity and Limited Quantity marks but also for
the required marking of the UN-Number.
Likewise, German surface transport manuals
come with abbreviations that contradict international accepted rules--such
as KG for kilogram instead of “kg” and “l” for
liter instead of “L.”
This actually causes greater difficulties
in air transport training as instructors have a problem explaining to
students--most of whom have undergone surface transport training beforehand—that
they must not apply the term “Kennzeichen” (label) to the
required package markings or the Excepted/Limited quantities mark as is
instructed in the surface manuals, but instead stick to the precise terms
mandated in the German version of the IATA Dangerous Goods Regulations.
While the IATA Gefahrgutvorschriften, as
the IATA DGR is called in German, is not a grammatically pleasing and
exact translation, these important matters are absolutely clear even in
the German IATA DGR.
Still, it makes little sense that under
German law, Excepted quantities and Limited Quantities bear “labels”
in the surface transport modes but “marks” in air transport.
Training, of course, is a much greater issue
because these important terms have been muddled and at times lost in translation
as regulators actually approve—perhaps unwittingly—such translations
without verification.
The Regulator's
Role
A part of the problem is that regulators
as well as a multi-governmental coordination group tasked with “harmonizing”
the languages in the Swiss, Austrian, and German DG surface manuals and
other regulatory publications refuses to acknowledge the issue at hand.
Their position simply is that according
to the Merriam-Webster, Oxford Unabridged, and other standard dictionaries,
the terms “Excepted” and “Exempt” are synonyms.
That, however, is true only grammatically speaking; in the fine-tuned
language of DG professionals, a unique but different meaning has been
assigned to either term.
Making the Grade
It’s an almost logical result of these
issues that the pass mark required to obtain DGSA (Dangerous Goods Safety
Advisor) qualifications is a mere 50 percent in Germany.
In the UK, a pass mark of 75 percent is
required. However, if the German pass marks were raised any higher, it
is likely almost nobody would pass.
The following excerpts were taken from the
German official DGSA questionnaire:
“Question 69: Which writing must be
applied to a package containing UN 1805 for the maritime transport?
"Correct answer: UN 1805, Correct technical
name in English: Phosphoric Acid Solution, Orientation labels where applicable."
The word “writing” in the question
of course is not defined in any handbooks, so a DGSA candidate is left
to figure what he’s supposed to answer—are labels or marks
asked for, or both?
"Question 75: Which additional labeling
is required on a Package containing substances in Class 7 in non-excepted
form? The UN Number with the prefix 'UN' has already been applied.
"Correct answer: Official name for
transport, address Identification for shipper and consignee."
The reader should note that the clumsy English
above is an exact translation from the clumsy German in the questionnaire.
In case one wonders what a “correct technical name” is, it
is the expression used throughout the four surface mode manuals in German
language for the English term “Proper shipping Name.”
IATA To The
Rescue?
IATA quite correctly translates the “Proper
Shipping Name” into the term “Richtige Versandbezeichnung.”
Because most of the so-called “generic”
or “n.o.s.” (not otherwise specified) proper shipping names
(a generic proper shipping name is one used to describe substances not
specifically listed by name, such as “Flammable liquid, n.o.s.”)
require the indication of a technical name in brackets, using this term
in lieu of a proper shipping name within the surface mode manuals was
probably the worst idea.
German air transport trainees are notorious
for having difficulties to distinguishing the “Proper Shipping Name”
from the “Technical Name” in brackets required for most generic
and n.o.s. substances.
For the reader’s ease of understanding:
Both Ethanol (UN 1170) and Methanol (UN 1230) are listed by name.
However, a 50/50 mixture needs a generic
name assigned (in this case, Flammable liquid, toxic, n.o.s.).
The regulations also require that the two
substances most predominantly contributing to the risk of such solutions
or mixtures be identified in brackets where so indicated, in this case
(Mixture of Methanol and Ethanol).
Self Imposed
English Test
Last but not least, it must be said that
for the sake of European harmonization, Germany has permitted the DGSA
test be administered in the English language (at least, theoretically)
since 2011.
The Chambers of Industry and Commerce—who
are in charge of DGSA certifications in Germany—require that where
the DGSA exam is administered in the English language, the official DGSA
test questionnaire must be translated into English at the sole expense
of the person or institution requesting the test.
The fact that there is an excellent DGSA
test questionnaire in English created and maintained by the UK DoT has
seemingly flown under the radar of the good Germans.
Deutsche
Pride?
No one denies that the culture for cargo
is advanced on a teaching and apprenticeship basis in Germany, and most
agree even grudgingly that the German logistics education foundation for
learning transportation arts is the best in the world.
But may we gently suggest that Germans insisting
on their use of DG-relevant wording and markings is inconsistent and misses
the point that the rest of the world is the common denominator, especially
given the fact that there is a considerable number of nations who do not
have the benefit of translations into their national language and simply
have to make do with the English, French, Russian, Arabic, or Spanish
base regulations.
Therefore, Germany has much more to gain
by adapting to the common usage (like it or not) to better streamline
itself with the rest of the world; in today's globalized economy, where
the industrial workbenches are more often than not outsourced to states
where human labor is cheaper than in the developed regions, any deviation
from the standardized language developed by the UN—with considerable
contribution from Germany as well—may come at a great expense in
terms of training efforts, unclear requirements applicable to shipments,
and possibly non-compliance.
Jens
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