Duties & Responsibilities

What Does a DGSA Do?

A DGSA carries multiple ongoing responsibilities to keep your business legally compliant and operationally safe.

1. Ensuring the business remains compliant with the law and associated regulations
2. Writing an Annual Audit Report for the business owners and the Department for Transport — a legal requirement — on the organisation's performance
3. Giving advice on the safe transportation of dangerous goods, including documentation, packaging and ad hoc queries
4. Delivering general awareness training to staff, and monitoring other training activities
5. Investigating any accidents or regulatory infringements and maintaining records through formal reports
6. Reporting incidents and accidents involving dangerous goods to the Department for Transport

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Talking to many DGSAs, the phrase above is one commonly shared within the DG community, but the reality is actually very different!

The DG regulation adopted by the Channel Tunnel is RID (being a rail tunnel), with those pertaining to ADR for their LeShuttle Freight service, since this is defined as a "rolling motorway".

Perhaps one key point to note is that whilst many DGs are permitted through the Tunnel, there are many restrictions that relate to the QUANTITY of a substance that is being transported, as well as its packaging type.

The next section has been copied straight from the Eurotunnel's Dangerous Goods Guide 2023 (available to download from their website and far better than me trying to re-write their text!):

Quantities

The quantities of goods are divided into three categories:

• 1) Carried with no restriction on quantity.
• 2) Carried subject to restriction on quantity: product may be carried but maximum unit package size is restricted — no restriction on the quantity carried per unit of transport but must be in unit packages of 250 litres, 400 Kgs, or 1,000 litres (for gases with a Classification Code of 1O or 2O).
• 3) Not permitted / prohibited.

Maximum quantity per transport unit: Carriage is only permitted on the premise that the maximum quantity per transport unit is not exceeded. The number of packages and their volume is unrestricted provided that their overall volume or weight does not exceed the limit of the relevant class for each transport unit, as shown in the list of dangerous goods accepted. If several products of the same class in any one transport unit fall into the same category, the sum of all their quantities must not exceed the limit of the relevant class for each transport unit.

Other maximum quantities allowed: the authorised limit is the net weight per transport unit unless otherwise indicated.

Prohibited

Yes, there are some absolute "no no's" concerning the carriage of DG, so let's start with these before diving into specific classes to see what is allowed through the tunnel.

• Anything assigned to Packing Group 1.
• Goods with two or more danger labels (Classes 1–9), with some exceptions to Class 2 & Class 6.2.
• Class 1 (Explosives), unless 1.4S with a net explosive mass no greater than 15 Kgs per transport unit.
• Class 4.2 (Spontaneous Combustion) and Class 4.3 (Dangerous When Wet).
• Class 5.2 (Organic Peroxides).

Yes, there are some Classes and Packing Groups that are strictly prohibited, but you may be surprised by how many are permitted. The purpose of this article is to shed some light on what is permitted, as well as how LQ is dealt with, how to "pre-declare" your consignment and provide some useful information.

So, let's take a look at each of the Classes to see what can and can't be sent through the Tunnel:

Limited Quantities

The good news here is that Dangerous Goods in Limited Quantities DO NOT need to be declared in advance or on arrival, so "yes" you can transport these without any additional paperwork! Dangerous Goods being carried under the ADR/RID limited quantity, excepted quantity or any other special provisions, which do not need documentation, do not need to be declared to Eurotunnel.

If, however, these Dangerous Goods are declared, a full ADR/RID declaration must be provided.

Pre-declaration

Any vehicle transporting DG can make a "pre-declaration" submitted in advance to confirm acceptance (similar to informing a shipping line with all of the relevant DG information before sailing).

To make life a little easier for Consignors, Shippers and Hauliers, LeShuttle Freight have put together a very useful section on their website to help you check if what you want to transport via the Tunnel is actually permitted. To do this, you simply open up an account (which provides you with a Username, Password and account number), and click on to www.eurotunnelfreight.com.

By clicking on the "Dangerous Goods" tab, followed by the "Check my dangerous goods" link, it is possible to enter the UN number, packing group / classification code, quantity, units and packaging type details.

If the product is permitted, you can then add additional lines of information for each UN number you wish to transport. The system will automatically indicate if you are trying to transport something that's prohibited, either by UN number, packing group / classification or quantity, and immediately prevent completion of this data field. If this occurs, then you simply delete the line of data (using the "-" symbol on the screen) and continue entering the data for the next product or products.

Once you have entered all the information relating to the DG, it will request the registration number of the vehicle carrying the goods; if you don't know the registration number at this point in time, there is an option to "save for later", so that it can be added at a later date. This function also enables the editing of the products, should there be any changes to the actual load.

Having confirmed the information, there is a 96 hour "window" when further changes can still be made to the declaration, after which it is "locked". If subsequent changes are necessary, the pre-declaration would need to be deleted and a new one created (but the original one can still be viewed under the "history" tab).

The completed form can be printed off as a PDF and given to the respective Driver as part of their documentation pack. When the Driver arrives at the terminal, they should report to the FREIGHT INFORMATION CENTRE, where their paperwork is checked before being issued with a bright orange "DG" sticker for display on the windscreen.

The website also includes a wealth of information to assist and guide both Drivers and Hauliers before they even arrive at the Terminal, so definitely worth taking a look at, even if you're not transporting DG.

Why Use the Channel Tunnel?

In the 30 years since the Channel Tunnel was constructed, it has demonstrated an exemplary safety record, as well as offering Hauliers with a fast, reliable and efficient service.

When compared to using traditional ferry crossings between the UK and France, the significant savings in transit time are an important factor, especially when the goods must be delivered "just in time" or are urgently required.

The typical journey time of approximately 35 minutes each way is rarely impacted by adverse weather conditions (unlike car ferries), with trucks clearing the security checks and French Customs prior to embarking on to the train. Within minutes of arriving in Calais, they are straight off the train and on to the French motorway network.

Next time you need to send your DG to Europe, why not consider using the Channel Tunnel — you may be pleasantly surprised.

The DG team at LeShuttle Freight is very experienced and helpful, so if you have any specific queries about your next consignment, contact them via the details below.

Article by Ian Hancock, written for the British Association of Dangerous Goods Professionals (BADGP). Reproduced here with the author's permission.

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The World Before Containers

Before the advent of containerisation, moving goods across oceans was surprisingly inefficient. Cargo was typically shipped as "break-bulk" freight. Individual items or small packages were loaded manually onto ships, unloaded at ports, sorted, and then reloaded onto trucks or trains. This process required large numbers of dockworkers and could take days or even weeks.

Shipping was expensive, not primarily because of transportation itself, but because of handling costs. Goods often suffered damage, theft, and delays while passing through ports. Ports were crowded with warehouses and labour-intensive operations. Businesses had difficulty predicting delivery schedules, and transportation costs limited international trade. Many regions of the World remained economically isolated because moving products was simply too expensive and complicated. Manufacturers generally located production close to their customers, and international supply chains were relatively uncommon.

Malcolm McLean and the Birth of an Idea

The central figure in the development of what we commonly refer to as a "Cargo Transport Unit" (CTU) is Malcolm McLean, an American trucking entrepreneur.

McLean became frustrated by the inefficiencies involved in transporting goods from trucks to ships. He envisioned a system in which entire trailer loads could be transferred directly onto vessels without unpacking and repacking their contents.

Rather than simply improving existing shipping methods, McLean sought a complete redesign of the transportation system. His insight was that efficiency would come not from faster ships, but from eliminating unnecessary cargo handling. In April 1956, McLean launched a converted tanker called the Ideal X, which carried 58 standardised containers from Newark to Houston. This voyage is widely regarded as the beginning of modern container shipping. The experiment demonstrated that containers could drastically reduce loading times and labour requirements while improving reliability and security.

Building a System, Not Just a Box

Some people advocate that the real innovation was not the container itself, since containers had existed in various forms for many years before Malcolm McLean converted his tanker, the Ideal X. The breakthrough was the creation of a complete intermodal transportation system.

The container needed to move seamlessly among ships, trucks, trains, ports, and warehouses. Achieving this required coordinated investments across multiple industries. Ports needed new cranes and terminals. Rail networks needed specialised freight cars. Trucking companies required appropriate trailers. Manufacturers and distributors had to redesign logistics operations.

Containerisation succeeded because it standardised the movement of cargo across these different transportation modes. The box became a universal unit that could travel almost anywhere without its contents being touched.

Resistance and Conflict

It is worth noting that the path toward containerisation was not smooth. Many groups resisted the changes it threatened to bring.

Dockworkers (and their Unions) viewed containerisation as a direct threat to their jobs. Traditional cargo handling employed thousands of people in ports around the world. Since containers dramatically reduced labour requirements, Unions often fought against their adoption.

Shipping companies also hesitated because containerisation required enormous financial investment. Existing facilities and vessels became obsolete. Port authorities faced similar dilemmas, as upgrading infrastructure demanded substantial financial commitments.

Government regulations further complicated matters. Shipping, railroads, and trucking were often governed by separate regulatory systems, making coordination difficult. There were numerous battles involving regulators, businesses, the Unions, and political leaders. These conflicts delayed adoption but could not ultimately stop the spread of the technology.

The Importance of Standardisation

A critical turning point came when the shipping industry agreed upon standards for container sizes and specifications. Without standardisation, different companies would have used incompatible boxes, undermining the advantages of the system.

International standards allowed containers manufactured anywhere in the World to be handled by ships, trucks, railways, and cranes everywhere else. Standardisation encouraged investment because businesses knew their equipment would remain compatible with broader industry practices.

This standardisation is regarded as one of the hidden foundations of globalization. The efficiency of international trade depends on countless common standards that make complex coordination possible across national borders.

The Vietnam War as a Catalyst

One of the most surprising insights is the role of the Vietnam War in accelerating containerisation.

The U.S. military faced enormous logistical challenges in supplying troops overseas. Containers offered a way to move massive quantities of supplies more efficiently than traditional methods. The military became an important early customer for containerised shipping, providing demand that helped justify large investments in the technology.

The war effectively served as a testing ground for large-scale container operations. Lessons learned during military logistics later contributed to the expansion of commercial container shipping, with many new routes added by shipping lines to link Europe, the Americas, Asia and Africa together.

The Transformation of Ports

Containerisation fundamentally altered the geography of global trade.

Traditional ports often occupied central urban locations because break-bulk cargo required numerous warehouses and large labour forces. Container terminals, however, needed vast areas of land, deep-water access, and room for trucks and cranes.

As containerisation spread, many historic waterfronts declined. Ports that failed to modernise lost business, while others that invested heavily in container facilities flourished.

Cities such as New York experienced dramatic changes as cargo operations moved away from traditional docks. Similar transformations occurred around the world. Entire neighbourhoods and local economies were reshaped by the changing needs of maritime commerce.

The Rise of Global Supply Chains

Perhaps the most significant consequence of containerisation was its effect on manufacturing and trade.

By dramatically reducing transportation costs, containers made it economical to produce goods far from where they would ultimately be sold. Companies no longer needed to locate factories near consumers. Instead, they could seek the most advantageous combination of labour costs, skills, resources, and regulations.

This shift contributed to the emergence of global supply chains. Components could be produced in multiple countries, assembled elsewhere, and shipped Worldwide at relatively low cost.

Asia, particularly East Asia, benefited enormously from this transformation. Lower transportation costs helped manufacturers in countries such as Japan, South Korea, China, and others reach consumers throughout the World. Meanwhile, some industrial regions in Europe and North America experienced factory closures and job losses.

The concept of containerisation was a crucial enabler of globalisation. While trade agreements and technological advances also mattered, the movement of goods would not have expanded so dramatically without cheap and reliable transportation.

Just-in-Time Manufacturing

Containerisation also enabled new management practices.

Because transportation became more predictable, companies could reduce inventory levels and adopt "just-in-time" production systems. Instead of maintaining large stockpiles of materials and products, firms could arrange for supplies to arrive precisely when needed.

This approach reduced costs and improved efficiency but also increased dependence on transportation networks. Businesses became more vulnerable to disruptions affecting ports, ships, or logistics systems.

Boom, Bust, and Competition

The container shipping industry experienced cycles of growth and instability. As the technology proved successful, companies invested heavily in larger ships and expanded capacity. Competition intensified, leading to periods of overcapacity and financial strain.

It should also be noted that shipping companies repeatedly pursued larger vessels in hopes of reducing costs further. Yet bigger ships required even more infrastructure investment from ports and terminals.

The quest for scale produced tremendous efficiencies but also increased risks. Companies sometimes struggled with debt, fluctuating trade volumes, and changing economic conditions.

These developments reveal that technological revolutions do not eliminate economic cycles. Even highly successful innovations generate new competitive pressures and challenges.

The Broader Meaning of the Container

Unlike inventions such as computers or airplanes, shipping containers attract little public attention. Few people think about the logistics systems that keep shops stocked and factories supplied. It should be considered that containerisation has had a greater impact on everyday economic life than many more visible technologies.

The container changed not only how goods move but also where they are produced, how businesses operate, where people work, and how cities develop. It altered patterns of trade, investment and economic growth on a global scale.

Malcolm McLean died in May 2001 at the age of 87. Following his death, Norman Minato (American politician and former Army officer) stated:

Article by Ian Hancock (Principal of Hancock's Technical Services, DGSA, BADGP member & Accredited Trainer for Cargo Securing), written for the British Association of Dangerous Goods Professionals (BADGP). Reproduced here with the author's permission.

Note: this article is based upon the book "The Box – How the Shipping Container made the World Smaller and the World Economy Bigger", written by Marc Levinson.

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Every Wednesday morning, 10–15 shipping containers designated as containing "Dangerous Goods" are selected at random at Felixstowe Docks for inspection by the local Cargo Surveyors. A similar exercise is carried out at all of the major UK Ports.

Over 50% of those inspected are "rejected" for not complying with the IMDG Code of Practice, with in many cases the reason for rejection being "inadequate or non-existent cargo securing".

The consequence of this situation usually results in at least one of the following:

• 1. Additional costs to the Consignor / Freight Forwarder to pay for a 3rd party to re-secure the goods at the Port. These charges usually range from £1,500–£2,000 + VAT, per CTU.
• 2. Possibility of the container not being loaded aboard a ship on time, thus delaying delivery to the End User / Customer.
• 3. Risk that the CTU will be prevented from leaving the Port (via road transport) to be returned to the Consignor, if the goods are deemed too dangerous to be moved in their current condition.
• 4. Additional demurrage charges levied by the Port for storing the CTU until another vessel can be used at a later date for the onward journey.

The latest figures from London Gateway indicate that 68% of the D/G CTUs inspected there are "rejected" as Shipping Lines seek to minimize the impact of poorly secured cargo aboard their vessels.

According to the Cargo Incident Notification System, 50% of all accidents and incidents at sea are caused by either "Poor Packing" or "Incorrect Packing":

So Why Are So Many CTUs Rejected in the First Place?

Real-life experience has indicated that there is a significant lack of knowledge and understanding in the logistics industry of the need for compliance when transporting Dangerous Goods by sea. Many Consignors are oblivious of the International Maritime Organisation's "CTU Code of Practice" and how it relates to the IMDG Code of Practice (assuming they are familiar with both publications, which often is not the case).

When a CTU is "rejected" at the Port for inadequate or non-existent cargo securing, a common response from the Consignor is "but we've always done it this way for the last 20 years and never had a problem before".

The reason for this is simple: shipping lines cannot inspect every shipping container, so only 5–10% will be inspected; if you have not had an issue during the last 20 years, you've been "lucky" and managed to evade inspection!

Below are five of the most common mistakes made by Consignors / Packers:

• 1. Not securing the cargo at all, thinking that the container side and end walls are strong enough to prevent the cargo from shifting.
• 2. Not securing the cargo, thinking that because there is a small gap or no gap between the cargo and the doors, it doesn't need securing. (Example: 80 steel drums in a 20' CTU completely fill the available space, front to back, side to side and floor to ceiling).
• 3. Securing the cargo only from transverse (sideways) movement (e.g. with dunnage bags) but not securing in the longitudinal (front / back) direction.
• 4. Distributing the cargo weight incorrectly inside of the container (i.e. more weight at one end than the other, so the Centre of Gravity is not in the middle of the container).
• 5. Using lashing systems with insufficient capacity to prevent longitudinal movements and/or using friction lashings instead of direct lashings.

An example of a "friction lashing" is a ratchet strap as used on a road truck, where the cargo is "pulled down" by the ratchet strap, creating an increased level of friction between the cargo itself and the floor of the truck, thus preventing any movement. The key element here is the degree of tension achieved by the ratchet strap.

On the other hand, a "direct lashing" utilises the full strength of the lashing / ratchet strap by directly opposing the force exerted on the cargo in a specific direction; think of a car seat belt which prevents your body moving in a forwards direction under harsh braking conditions (if the seat belt was placed over your head as a friction lashing, it would not prevent your body from exiting the vehicle via the windscreen, headfirst!).

Based on the above, direct lashings are the preferred method of cargo securing in shipping containers, rather than friction lashings as widely used in road transport.

There are also many Consignors who believe they can simply use dunnage bags (inflatable "pillows") to prevent cargo movement, however this is only partially correct. Dunnage bags are designed to fill voids either side or between cargo in the sideways (transverse) direction, when any gap or series of gaps between the cargo and the side walls of the CTU exceed 15cms, as stated in the CTU Code of Practice.

Placing dunnage bags between the cargo and the CTU doors is not a recommended procedure, since the bags are not designed to withstand the entire weight of the cargo from moving towards the doors (plus the doors are only designed to take up to 40% of the payload weight).

The IMDG Code doesn't specify exactly how goods in shipping containers should be secured in the first place. Instead, it cross references to the IMO CTU "Code of Practice", which goes in to far more detail and offers industry "best practice" for many different types of cargo, irrespective of whether or not they are classed as hazardous.

Anyone who has signed a Dangerous Goods Note (DGN) will have noticed a small footnote on the form that references the IMDG Code (section 5.4.2), and the signatory confirms the CTU has been properly packed and loaded "in accordance with the applicable provisions".

What's Wrong With an "X" Lashing?

Another common mistake is to use two straps in the form of an "X" between the cargo and the CTU doors: this is completely WRONG (unless you're shipping toilet paper!).

The four steel lashing points welded to the CTU have a strength of 2,000 daN each (i.e. two metric tonnes of force), but this is downgraded by the concept of "MSL" (Maximum Securing Load). MSL is a safety factor used in the shipping industry to prevent lashings, steel cables, ratchet straps and even the lashing points being subjected to the maximum forces they are capable of enduring.

This means an "X" of lashings will not be sufficient to prevent 20,000 Kgs of cargo sliding into the doors of the CTU (as either the straps will break, or the lashing points will fail).

The photograph above shows the "X" type of lashing which is considered unsuitable as a method of cargo restraint; all it really achieves is the prevention of "fall-out" when the CTU arrives at its final destination and the doors are opened by the Consignee. (On the plus side, the Consignor has used dunnage bags between the pallets to prevent transverse movement of the cargo…!).

The other photograph (steel drums falling out of a CTU) clearly illustrates the reason why cargo securing is so important. The CTU Code states that the Consignor has a "duty of care" to the Consignee and there have been many injuries (including fatalities) initiated by the cargo moving whilst in transit and "leaning" against the CTU doors, causing the doors to open violently during the un-loading operation.

Best practice would be to use a rope or chain across the doors, preventing them opening more than 30cms, so that the doors can be opened carefully, before checking the status of the cargo.

Alternatively, if someone "knocks" on the doors (before opening the first one) a "thud" type sound may indicate the cargo has moved and is now pressing against the doors — exercise caution when opening the doors.

Training — What Training?

Each of the statutory regulations references "training" of personnel involved in the movement of dangerous goods, whether it be "awareness" and/or "function specific".

It is extremely concerning that many organisations fail to carry out this activity correctly, or at best, are relying upon the more experienced individuals within the organisation to perform this task with new colleagues. This attitude only works as long as there are no incidents or accidents, but as we all know, sooner or later things WILL go wrong, which is when awkward questions are asked.

As Dangerous Goods Professionals, we all have a responsibility to work in the safest way possible, and this is as relevant to cargo securing as it is to any other aspects of Health & Safety.

Article by Ian Hancock, written for the British Association of Dangerous Goods Professionals (BADGP). Reproduced here with the author's permission.

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