Dangerous Goods Officer
ADR, IMDG and IATA documentation, transport-safety checks, annual report to the operator. Appointed where transport volumes cross the § 3 GbV thresholds.
§ 3 GbV · ADR · GGVSEB
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What is a dangerous goods safety adviser under German law?
The dangerous goods safety adviser (Gefahrgutbeauftragter, DGSA) must be appointed in text form under § 3 Abs. 1 Satz 1 of the German DGSA Ordinance (GbV) as soon as an undertaking takes part in the carriage of dangerous goods and carries participant duties under the German road, rail, inland waterway or maritime ordinance. The GbV works alongside the modal rulebooks ADR (road), RID (rail), ADN (inland waterway), the IMDG Code (sea) and IATA-DGR (air). § 2 Abs. 1 GbV exempts, among others, undertakings whose quantities stay within the maximum permitted quantities of ADR 1.1.3.6, plus pure drivers and consignees. Class 7 radioactive material and transport category 0 goods under ADR 1.1.3.6.3 fall outside that quantity exemption.
Only a holder of a valid certificate of training under § 4 GbV for the transport mode concerned may be appointed (§ 3 Abs. 3 GbV). The Chamber of Industry and Commerce issues it; § 4 Satz 2 GbV makes it valid five years, renewable for five more once the examination under § 6 Abs. 4 GbV is passed. Under § 8 Abs. 5 GbV the adviser writes an annual report within six months of the business year end; the operator, not the adviser, keeps it five years and presents it to the competent authority on request (§ 9 Abs. 3 GbV). Under § 8 Abs. 4 GbV the adviser ensures an accident report under ADR 1.8.3.6 is produced. Breaches of the GbV are administrative offences under § 10 GbV in conjunction with § 10 Abs. 1 Nr. 1 Buchst. b of the Dangerous Goods Transport Act (GGBefG), fined up to 50,000 euros under § 10 Abs. 2 GGBefG.
Appointing a DGSA does not transfer the duties. The obligations under the modal regulations fall on the participants themselves, meaning the consignor, loader, packer, filler and carrier each in their own role. The adviser monitors those duties and works towards remedy; the role does not absorb them. Anyone who carries, consigns, packs or loads dangerous goods in breach of administrative duties and thereby endangers another person's health or property of significant value commits an offence under § 328 Abs. 3 Nr. 2 StGB.
A company may appoint several advisers or, under § 3 Abs. 2 GbV, use a person outside the undertaking, provided that person really is able to perform the tasks. Someone who has never watched a loading process cannot supervise it.
DGSA duties under § 8 GbV
- Performing the tasks of ADR 1.8.3.3 under § 8 Abs. 1 GbV and keeping records of the monitoring activity under § 8 Abs. 2 GbV, naming date, persons and business transactions monitored.
- Advising on consignment, packing, filling, loading and unloading of dangerous goods.
- Preparing the annual report under § 8 Abs. 5 GbV within six months of the end of the business year; the five year retention is the operator's duty under § 9 Abs. 3 GbV.
- Checking transport documents and written instructions under chapter 5.4 ADR.
- Supervising labelling and placarding under chapters 5.2 and 5.3 ADR.
- Ensuring 1.3 ADR awareness training of involved staff and driver training under chapter 8.2 ADR.
- Lithium battery shipping under special provisions 188, 230, 310, 376 (UN 3480, 3481, 3090, 3091).
- Cargo securing under VDI 2700 and CTU Code for container stuffing.
- Investigating incidents and ensuring the accident report under § 8 Abs. 4 GbV and ADR 1.8.3.6 is produced.
- Drafting the security plan under chapter 1.10 ADR for high consequence goods.
Appointment of the dangerous goods safety adviser
Appointment is made in text form under § 3 Abs. 1 Satz 1 GbV. Where several advisers are appointed, Satz 2 requires their tasks to be delimited against one another, again in text form; where the operator performs the function personally, Satz 3 dispenses with an appointment. Under § 3 Abs. 2 GbV the function may be performed by the head of the undertaking, by a person with other tasks inside it, or by a person outside it, provided that person really is able to perform the tasks; the name must be made known to all staff in text form. Only a holder of a valid certificate of training under § 4 GbV for the transport mode concerned may be appointed (§ 3 Abs. 3 GbV). Training takes place under § 5 Abs. 1 GbV in a course recognised by the Chamber of Industry and Commerce under § 7 Abs. 1 Nr. 2 GbV, and covers at least 22 hours 30 minutes for one transport mode plus at least 7 hours 30 minutes for each further mode (§ 5 Abs. 4 GbV). The Chamber runs the examination under § 7 Abs. 1 Nr. 4 GbV. On request from the competent authority the operator names the adviser under § 9 Abs. 4 GbV. Even with an external adviser the operator's duties under § 9 GbV remain, and management that omits the necessary supervisory measures is exposed under § 130 OWiG.
- Involvement in carriage of dangerous goods above the maximum permitted quantities of ADR 1.1.3.6, which removes the exemption in § 2 Abs. 1 Nr. 5 GbV.
- Carriage of class 7 radioactive material or transport category 0 goods under ADR 1.1.3.6.3, where the quantity exemption does not apply.
- Filling or unloading of tanks, tank containers, tank wagons or MEGCs under chapter 4.3 ADR.
- Packing of dangerous goods in UN approved packagings under chapter 6.1 ADR.
- Sea shipment of dangerous goods under the IMDG Code from German ports.
- Lithium battery shipments under UN 3480/3481/3090/3091 as cargo, in or packed with equipment, including air freight under IATA-DGR or ICAO-TI.
Sectors with DGSA obligation
- Chemical and petrochemical industry
- Pharmaceutical manufacturing and wholesale
- Mineral oil trade and fuel logistics
- Battery manufacturers (UN 3480/3481/3090)
- Freight forwarding and parcel services
- Electroplating and surface treatment
- Paint and printing industry
- Waste management and hazardous waste transport
- Food chemistry (CO2, ammonia)
- Research laboratories and hospital logistics (class 6.2)
How CIVAC supports the DGSA function
CIVAC stores the appointment letter, the section 1.8.3 ADR certificate and the transport mode profile in one role record with automated renewal alerts 90, 60 and 30 days before expiry. The annual report under § 8 GbV is generated from shipment data; transport documents and written instructions are version-controlled. 1.3 ADR awareness training, driver ADR certificates and lithium battery training are linked to staff records and scheduled automatically. Incident reports under section 1.8.5 ADR are captured in BALM compliant fields. A link to the GefStoffV substance register and to safety data sheets under REACH Annex II avoids duplicated master data. CTU Code conformity and cargo securing under VDI 2700 are stored as inspection checklists.
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