The Safety Adviser's Annual Report: Content, Deadline, Retention

Of all the obligations attached to the dangerous goods safety adviser, the annual report is the easiest to forget and the easiest to check. Easy to forget because no external recipient asks for it. Easy to check because it only has to be requested.

It is also, when done properly, the only document that gives a consolidated view of what a company actually ships that is dangerous, and how it goes about it.

What the rules say

Chapter 1.8.3 of the ADR lists writing an annual report among the safety adviser’s duties, alongside checking compliance with the applicable rules, advising the company and drawing up a report in the event of an accident.

The report covers the company’s activities relating to the transport of dangerous goods and is intended for company management — or, where applicable, the local public authority concerned.

On the French side, article 6 of the arrêté TMD of 29 May 2009 organises its availability and retention: the report relating to a given year is available before 31 March of the following year, and is kept for five years.

Two points are often misread. The report does not have to be sent to the administration on the company’s initiative: it must be available, that is, produced on time and producible on request. And the five-year retention means that at any moment a covered company should be able to produce five successive reports.

What an annual report should contain

No template is imposed. That is a freedom, and it is where reports differ: three generic pages copied over from year to year, or a genuine operational review.

A useful report covers at least the following.

Scope. The company’s activities in the sense of 1.8.3 — consigning, carriage, packing, loading, filling, unloading — and the sites concerned. This is the reminder that lets you measure, next year, what has changed.

Flows. Types and volumes of dangerous goods consigned, received or handled: hazard classes, main UN numbers, transport modes, packaging types. This consolidation exists nowhere else in the company.

Checks carried out. What the adviser actually reviewed during the year: classification of substances, packagings and labelling, transport documents, securing of loads, equipment, subcontractors. Together with the gaps found.

Incidents and near misses. Including those that did not lead to an accident report. These are the most useful signals, and the quickest to be forgotten.

Training of the people involved. Who was trained, in what, when — and what remains to be done.

Corrective actions. Those started, those closed, those overdue. A report that does not follow up on the previous year’s actions is not a management tool.

Regulatory changes taken on board. The ADR, RID and ADN are revised on a two-yearly cycle; part of the adviser’s job is to pass those revisions through.

The report as a decision tool, not an archive

There is a substantive reason to take this document seriously. The risk of transporting dangerous goods is not managed through documentary compliance alone: it is managed through concrete decisions taken from data. That is precisely the argument of B. Fabiano, F. Currò, E. Palazzi and R. Pastorino in “A framework for risk assessment and decision-making strategies in dangerous good transportation”, published in 2002 in the Journal of Hazardous Materials, which builds a decision-oriented risk assessment framework — route choices, flow management, local aggravating or mitigating parameters (see the study).

The data those decisions require are exactly what the annual report consolidates. A well-kept report answers questions nobody otherwise asks: are our dangerous flows growing? in which classes? do our incidents cluster on one operation, one site, one subcontractor? does our training actually cover the people exposed?

The value of that consolidation is clearer against what is at stake. In a study published in 2006 in the Journal of Hazardous Materials, A. Oggero, R. M. Darbra, M. Muñoz, E. Planas and J. Casal analysed 1,932 accidents occurring during the transport of hazardous substances by road and rail, showing that road accounts for the majority of recorded cases and that release of substance is the most frequent event type (see the study).

Not to be confused with the accident report

The annual report is a periodic exercise. The accident report is a conditional one: the adviser draws it up when an accident has affected people, property or the environment during carriage, loading, filling or unloading.

The two feed each other. An accident occurring during the year belongs in the annual report as a review and a set of corrective actions — but the accident report itself cannot wait until 31 March.

Three mistakes to avoid

The retrospective report. Written at the time of an inspection, from memory. It ticks the box without producing any value, and the mismatch shows.

The duplicated report. The same document year after year with the date changed. It signals, unintentionally, that the role is not being performed.

The report with no follow-through. Gaps identified, no action, the same gaps next year. This is the scenario that exposes a company most, because it documents that the problem was known.

One simple good practice: use the writing of the report to check two related compliance points — that the adviser’s online declaration is up to date, and that the scope of the certificate still covers the company’s real flows, a question addressed in our article on the CSTMD examination and the scope of the certificate.

Take action

Put two dates in the company diary now: gathering the year’s data in January, and delivering the report to management before 31 March. While you are at it, check that previous years’ reports are archived and retrievable over five years. Our full page on the dangerous goods safety adviser certificate places this obligation within the whole scheme, from appointment to certificate renewal.