Dangerous Goods — Other Appointed Person
Support function alongside the dangerous goods safety adviser: classification checks, packaging and labelling, transport-document review, and driver instruction under ADR 1.3 — without the formal Gefahrgutbeauftragter role.
§ 9 GbV · ADR 1.3
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What is a dangerous goods appointed person?
The dangerous goods appointed person (German: sonstige beauftragte Person im Gefahrgut) is a support role alongside the dangerous goods safety adviser (Gefahrgutbeauftragter). The appointed person performs the practical tasks of safe dispatch: checking classification, ensuring correct packaging and labelling, reviewing the transport documents and instructing drivers and handlers, but without holding the formal, examined role of the safety adviser.
The legal background sits in the Gefahrgutbeauftragtenverordnung (GbV), which rests on the Gefahrgutbeförderungsgesetz (GGBefG). Under § 1 Abs. 1 GbV the ordinance applies to every undertaking whose activity includes the carriage of dangerous goods by road, rail, inland waterway or seagoing vessel. Under § 3 Abs. 1 Satz 1 GbV an undertaking must appoint at least one safety adviser in text form as soon as it takes part in that carriage and carries participant duties. The GbV creates no separate appointment duty for the appointed person. What § 9 GbV governs are the operator's obligations: no detriment to the safety adviser, and the information, documents and means the adviser needs to perform every task under § 8 GbV properly. That is the frame the appointed person works inside.
The everyday training basis is chapter 1.3 ADR, the training of persons involved in the carriage of dangerous goods. It requires that all persons whose duties concern that carriage, other than those needing the safety adviser qualification or driver training, receive training appropriate to their responsibilities: general awareness, function-specific training and safety training, with records kept and refreshed.
The appointed person is therefore the operational hand that keeps consignments compliant on the ground, while the safety adviser carries the monitoring and reporting duties of § 8 GbV. In practice the role lives at the loading dock and the dispatch desk. The appointed person checks consignments before they leave, confirms classification, packaging, labelling and documents, instructs drivers and handlers and reports deviations to the safety adviser. Keeping the 1.3 ADR training aligned with the regular ADR amendment cycle is what keeps the whole operation compliant, and none of it replaces the appointment under § 3 GbV.
Core duties of the dangerous goods appointed person
- Check the classification of dangerous goods before dispatch
- Ensure correct packaging and use of approved packagings
- Verify labelling, marking and placarding of packages and units
- Review the transport documents for completeness and accuracy
- Instruct drivers and handlers under ADR 1.3 within their responsibilities
- Support segregation and loading rules and the prevention of incompatible co-loading
- Keep records of consignments and of ADR 1.3 training
- Report deviations and incidents to the dangerous goods safety adviser
- Assist the safety adviser with checks, the annual report and corrective measures
- Stay current on ADR amendments relevant to the undertaking's goods
Appointment and qualification
The appointed person is not the formal safety adviser and does not replace the appointment required in text form under § 3 Abs. 1 Satz 1 GbV. Only a holder of a valid certificate of training under § 4 GbV for the transport mode concerned may be appointed as adviser (§ 3 Abs. 3 GbV); the Chamber of Industry and Commerce issues that certificate and it runs for five years. The appointed person works alongside the adviser, taking on the operational tasks the undertaking delegates.
The qualification for the appointed person rests on chapter 1.3 ADR. The training has three elements: general awareness training so the person understands the provisions, function-specific training matching the actual duties, and safety training on the risks and on first response. The training must be documented and kept available, and it must be refreshed, in particular after amendments to the ADR. Unlike the safety adviser, the appointed person does not sit the examination under § 6 GbV.
The undertaking should define in writing which tasks the appointed person carries out, so that the boundary to the adviser's monitoring role under § 8 GbV is clear. The appointed person needs access to the current ADR provisions, the packaging and labelling specifications and the transport-document requirements relevant to the goods handled. Under § 9 GbV the operator remains responsible for giving the safety adviser the information, documents and means to perform the tasks properly, and management that omits the necessary supervisory measures is exposed under § 130 OWiG. Training records and the task assignment should be verified periodically.
- Involvement of the undertaking in carriage, packing, loading, filling or unloading of dangerous goods
- Duty to appoint a dangerous goods safety adviser under § 3 Abs. 1 GbV, requiring operational support
- Persons whose duties concern dangerous goods needing chapter 1.3 ADR training
- Dispatch of consignments requiring classification, packaging, labelling and document checks
- Amendments to the ADR requiring refreshed instruction and updated procedures
- Driver and handler instruction obligations under chapter 1.3 ADR
Where dangerous goods appointed persons are needed
- Logistics, freight forwarding and parcel services
- Chemical manufacturing and distribution
- Warehousing and distribution centres handling hazardous goods
- Manufacturing plants shipping hazardous materials
- Waste management and hazardous-waste transport
- Wholesale and retail of paints, solvents, gases and batteries
- Pharmaceutical and laboratory supply distribution
- Fuel, lubricant and gas trade
How CIVAC supports the dangerous goods appointed person role
CIVAC keeps the operational dangerous goods duties traceable next to the safety adviser's responsibilities. Each appointed person is a record with their assigned tasks and their ADR 1.3 training status, and CIVAC raises a task before a refresher is due, especially around ADR amendment cycles, and routes it to the responsible person. Classification, packaging, labelling and transport-document checks can be tracked as recurring tasks, and deviations flow to the dangerous goods safety adviser. The written task assignment, the ADR 1.3 training records and the link to the safety adviser appointment under the GbV sit in the documentation pillar, so the operational chain stays auditable when an authority or the safety adviser reviews it.
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