Is IATA “Certification” Mandatory? Or is it ICAO?
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There’s confusion in our industry as to whether IATA certified training is mandatory. It’s not but it is a recognized standard – so that’s great. It’s a choice, on the part of the employer – or should be.
Non-governmental organizations or trade groups can publish guidelines for their members but without intrinsic regulatory authority or governmental enforcement provisions.
There are trade groups like (in the US) the Airforwarders Association (AfA), The International Air Cargo Association (TIACA), FIATA (International Freight Forwarders) or the most well-known — IATA (The International Air Transport Association). But these are membership driven trade groups, not government entities.
We often hear “Well, if you need training for shipping DG by air then legally, that training must be IATA approved.” Is that true? No.
Your employer’s responsibility for training is to the competent authority in the country in which you operate. The FAA in the US or CAA in Canada will not enforce a trade association’s guidelines’ directly.
In the US, the DOT specifically permits ICAO , IAEA and IMO (as well as the Canadian TDGR) to be used as if it were US law; this authority is specifically granted in (Part 171, Subpart C of 49 CFR).
Why is IATA not mentioned in the federal rules?
Because as a trade association they can require adherence to their membership-specific guidelines (like “you must use a red hatched DG declaration”) but these are guidelines for their members and not a law. They carry the threat of cargo rejection or airline sanctions, but not from a law enforcement standpoint.
When an FAA inspector asks to see your employee training certification for dangerous goods, they are looking for one thing: a certification that complies with the national authority’s regulations and in most places that certification comes ONLY from the employer, who can have their choice of trainers.
At the front of the DGR, IATA assures users that their rules incorporate all the ICAO (intergovernmental) regulations. So, if the US FAA inspects you, you can show them the IATA book and that should suffice for the ICAO portion of your responsibilities. You can also show them an IATA certificate to satisfy parts of the DOT training rule, but it does not have to be issued by IATA.
In most of the world, only the employer can make that determination about who to use as a trainer. If you want a certificate issued by IATA or FIATA or any trade association, that’s up to the employer. The employer knows best and that is at the heart of CBTA training for Dangerous Goods.
For more information on competent authorities and regulating entities in our industries DGTA will be publishing a separate article.