Competency-Based Training and Assessment (CBTA) coming in 2021.
As many of you may have heard, IATA and ICAO are implementing a Competency-Based Training (CBT) and Assessment requirement as part of the 2021 regulations.
For customers in the United States this is merely a recommendation. All training in the US has to comport with the requirements in 49 CFR and those requirements, found in Subpart H of Part 172 of 49 CFR are already (in a way) “competency-based” in that they require the employer to match up the employee’s job functions with the topics covered in their training. No more and no less than what they need to be fully competent in their responsibilities of shipping DG’s or preparing or transporting DG shipments.
The term CBT includes an “assessment” component which requires the employer to determine not only if the person was trained but to assess their competency at the end of the training and to ensure ongoing competency in their job function. The recurrent training interval of 2 years (in the international rules) isn’t changing but there is the implication that employers could and should utilize ongoing competency-assessments in the interim.
The challenge of CBTA as it’s laid out here in IATA (or ICAO) is that it really places the burden on the employer to know subjects in which they really might not be competent to begin with. Furthermore, they’ll have to spend some time analyzing the work function of each employee to determine the areas of competency (as it relates to DG transport) that they must assess.
The IATA guide published with this Knowledge Base article includes a reprint, furnished by IATA, of Appendix H of the DGR laying out the plan for CBTA in the 2021 DGR.
You might think this is complicated. You might be right. However, the US DOT has and (probably) always will, put the burden of competency-based training and assessment squarely on the shoulders of the employer as theoretically, they’re the only ones who really know the job roles and tasks of their DG employees.
We, here at Transportation Development Group (TDG), can help you navigate the existing requirements and help you understand the new CBTA guidelines in IATA. Just give us a call with any questions or send an email to email@example.com and we’d be glad to assist you.