MEMO: Amendment to training requirement for bunkering stations - ADN Chapter 1.3 instead of ADN certificate

Article 56(1) of the Dutch Inland Shipping Regulations has been amended. Personnel at bunkering stations are now required to hold ADN Chapter 1.3 training only. 

Background

Until recently, Article 56
(1) of the Dutch Inland Shipping Regulations required that during loading, bunkering and gas-freeing operations, at least one crew member at the bunkering station had to be trained as an ADN expert in accordance with ADN 8.2.1.2 (i.e. hold an ADN certificate). In practice, this proved difficult to achieve: the ADN training was considered too extensive and demanding, and the training requirements were disproportionate to the tasks performed and the substances handled at bunkering stations.

Based on signals from the industry, we raised this matter with the Dutch Ministry of Infrastructure and Water Management. Following consultation, it was recognised that the training requirement was not proportionate to the hazards and tasks at bunkering stations, particularly in comparison with loading and unloading terminals, where operators are also not required to hold an ADN certificate — ADN Chapter 1.3 training is sufficient.

What has changed?

This resulted in an amendment to Article 56(1) of the Dutch Inland Shipping Regulations. The new article reads:

Article 56. Familiarity with safety matters 1. During loading, bunkering and gas-freeing operations, at least one of the crew members on board shall be trained in accordance with Chapter 1.3 of the ADN. This obligation does not apply if the bunkering station has a total capacity of not more than 30 m³ of gas oil, diesel oil or petrol.

It is therefore no longer necessary for a holder of an ADN certificate to be present at the bunkering station during loading and bunkering operations. Station personnel must be trained in accordance with ADN Chapter 1.3. This is a task-specific training tailored to the activities carried out by the individual employee.

Note: this does not apply to skippers of bunker vessels. An ADN certificate remains required for them.

Consequences and advice

Include ADN Chapter 1.3 training in the training matrix of your organisation. The personnel concerned must be demonstrably trained, and the training must be repeated every two years. Maintain proper training records, as compliance must be demonstrable during inspections by the competent authorities.

Transafe provides ADN Chapter 1.3 training for bunkering stations. The training is delivered on site and tailored to the specific situation and activities within your organisation.

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