WHAT IS TMGD AND WHAT DOES TMGDK MEAN?

TMGD, Dangerous Goods Safety Advisor. Today, Dangerous Goods Safety Consultancy, which is described as a new business line and a new sector, has become a completely special and complicated profession. Having the knowledge and skills of many activities such as receiving, sending, packaging, filling, transporting and organization of dangerous goods and managing these processes perfectly are the complex basic features that a Dangerous Goods Safety Consultant should have. In addition, being able to communicate effectively, being effective in management and organization and management skills are indispensable for a TMGD. A successful Dangerous Goods Safety Advisor is a person who can transfer his knowledge to the manager or blue-collar personnel in front of him, and facilitates the applicability of the information he conveys with his skills and guidance. When it comes to dangerous goods, there are not many substances that come to mind, but in fact, there are 9 classes and nearly 4 thousand dangerous goods. We can understand how well-equipped a complex Dangerous Goods Safety Advisor should be and should have a good grasp of the subject by acting according to the class, content and degree of danger of a wide variety of dangerous goods.

In addition, as an organization that has provided and continues to provide Dangerous Goods Safety Consultancy services in France, it is not easy to get the title of Dangerous Goods Safety Consultancy in Europe. In France, the person who is successful after the necessary training on ADR is given the title of ADR Specialist, the person who is successful after the necessary training on Maritime and Railroad is given the title of IMDG / RID specialist, and the person who is successful after the necessary training on Airline is given the title of DGR Specialist. Hazardous Goods Safety Advisor title is given to people who have expertise in all transportation modes and gain the ability to provide service. There are many ADR Experts in our country, but the number of real Dangerous Goods Safety Advisors is too few to exceed the fingers of one hand. As TMGD TR Engineering, the number of our personnel who successfully completed their training in all transportation modes has reached 4. We are able to provide services to our companies in all transportation modes with our team of engineers who are competent in all transportation modes and are competent in their fields.

TMGDK, Dangerous Goods Safety Consultancy Institution. It is a competent institution that employs full-time Dangerous Goods Safety Advisors within the framework of the authorization received from the Ministry of Transport and Infrastructure, and provides services to organizations dealing with dangerous goods with its consultants. There are nearly three hundred authorized institutions in Turkey. Some of these authorized institutions have recently been closed due to their illegal activities.

When choosing an Authorized Dangerous Goods Safety Consultancy Organization, companies should first ask for at least 3 references from the company and question the service it provides. In addition, it is one of the responsibilities of the service buyer to inquire whether the consultants who make the visits after they start to receive service have full-time insurance in the company. The vision, knowledge-skill and honesty of the companies outsourcing services are very important in order not to experience non-compliance in the audits. Organizations that only serve with commercial concerns unfortunately put companies in a difficult situation. Large organizations should not be put at risk for small costs, this work should be delivered to organizations that adopt quality service as a principle, not as an individual.

TMGD TR Mühendislik Ltd. Sti., which has the authority of TMGDK as Turkey's first corporate Dangerous Goods Safety Consultancy firm. We trust our references very much, and we would like to state that we will be proud to include you in our references.

What is the Annual Dangerous Goods Activity Report?

It is a reporting system in which the amount of activity that companies have done in all branches of activity (consignee – unloader – Consignor – filler – packer – carrier) in a 1-year period (1 January / 31 December) is declared.

Every year until the end of March, year-specific reports are prepared by the Dangerous Goods Safety Consultants serving the company and they are entered into the system.

WHAT ARE THE PARTIES OF DANGEROUS GOODS ACTIVITY IN ADR LEGISLATION?

Consignee: The enterprise to which the dangerous substance specified in the transport document, delivery note, transport note or transport document will be delivered or, if the transport operation is carried out without a transport contract, the enterprise that will take over the management of the dangerous goods at the destination,

Unloader: Unloading dangerous goods container, multi-element gas container, tank-container, portable tank from a vehicle; unloading packaged dangerous goods and portable tanks from a vehicle or container; an enterprise that unloads from a battery-vehicle, multi-element gas container, vehicle or bulk container,

Filler with: Dangerous goods; establishments that fill in bulk into tankers, tanks, portable tanks or tank-containers, cylinder gas tankers, multi-element gas containers or containers,

Consignor : The business that sends dangerous goods on its own behalf or on behalf of a third party, or the person specified as "Consignor" in the contract, if the transportation process is carried out in accordance with a transportation contract,

Packer: Businesses that place dangerous goods in different types of containers, including large packages and medium-volume containers, and make the packages ready for transport when necessary,

Tank-container/portable tank operator: Operators of tank-container or portable tanks, on whose behalf it is registered or operating them on a contractual basis,

Carrier: Holders of C1, C2, C3, K1, K2, K3, L1, L2, M1, M2, N1, N2, P1, P2, R1, R2 and TIO authorization certificates according to the Road Transport Regulation,

Loader: It refers to businesses that load packages, containers or portable tanks containing packaged or bulk dangerous goods into or on a vehicle or into a container.

I HAVE ENVIRONMENTAL CONSULTANT SHOULD I GET TMGD SERVICE?

Environmental Consultancy service, just like Dangerous Goods Safety Consultancy, is a legal regulation implemented in our country within the scope of the European Union Harmonization Law.

However, Dangerous Goods Safety Consultancy is not within the scope of Ministry of Environment, Urbanization and Climate Change of Turkey, to which Environmental Consultancy is affiliated, but is a consultancy and expertise operating under the control and competence of the Ministry of Transport and Infrastructure of Turkey.

The fact that the company has an Environmental Consultant is not a reason for not having a Dangerous Goods Safety Consultant. If the company operates a total of 50 tons or more of dangerous goods in all branches of activity, it should have a Dangerous Goods Safety Advisor, regardless of whether it has an Environmental Consultant or an Occupational Safety Specialist, or it should receive Dangerous Goods Safety Consultancy services from authorized institutions.

HOW WİLL I DETERMINE MY COMPANYS DANGEROUS GOOS ACTIVITY PARTIES?

First of all, it should be considered which operations your company carries out with dangerous substances. 

If the company purchases dangerous goods, the CONSIGNEE unloads these dangerous goods to his own address, the CONSIGNOR if he sends dangerous goods and puts his own name on the waybill, his own personnel do the loading of the products he sends, or the LOADER if this process takes place at his own address. CARRIER, if it carries or transports dangerous goods via its own chauffeurs or with rental vehicles, PACKERS if it changes the packaging of dangerous goods or packs them; TANK-CONTAINER / PORTABLE TANK OPERATOR parties are selected and an application is made if the company is registered in its name or in the position of an enterprise that operates them on the basis of a contract.

FROM WHICH ORGANIZATIONS CAN I GET THE FLOUR APPROVED PACKAGING CERTİFİCATE?

All substances must be packed in UN approved packages. This sign; Test Details, Date of Manufacture, Approving Country etc. is located behind a coding system that includes

After the type of packaging is determined, the strength of the packaging according to the materials planned to be transported, in other words, at what level the performance tests will be applied, is determined by looking at the relevant section of the regulation. The most important criterion here is the Packaging Group, which shows the danger level of the substance. Packing groups are denoted by roman numerals and have 3 scales, I (very dangerous), II (moderately dangerous) and III (less dangerous).

More stringent test levels are applied to packages that are planned to carry high-hazard substances. For example, in the drop test, the package that will carry a PG I substance is dropped from 1.2 m, while the package that will carry a PG III substance is dropped from 0.8 m. The tests to be applied to the packaging types and the levels related to these tests are specified both in the dangerous goods transport regulations and in the TS EN ISO 16104 and TS EN ISO 16106 standards. In general, tests that can be applied to packages are drop test, leak test, internal pressure (hydraulic) test, stacking test, chemical compatibility test, permeability test and water absorbency determination by Cobb method.

A Design Approval Certificate valid for 5 years is issued to products that pass the tests positively. With this certificate, which is valid for 5 years, the company obtains the right to print the UN (UN) marking on its products, and then international dangerous goods transportation can be carried out with these products within the scope.

HOW CAN I APPROVE THE DANGEROOUS GOODS SAFETY CONSULTANT APPOİNTMENT AS COMPANY OFFİCİAL?

Access to the e-government system will be made by the authorized signatory defined in the U-Net automation system or by the insured company employee who has been authorized by the authorized signatory and is defined in the U-Net automation system.

After logging into the system by the authorized person defined in the U-Net automation system, “TMGD Transactions” will be written in the search section and searched.

After the TMGD Transactions search, the "Ministry of Transport and Infrastructure / Enterprise - TMGDK - TMGD Transactions (Operation/TMGDK Entry)" option will be entered.

* Your company's tax number will be written in the Enterprise / TMGDK Tax No / TR Identity No section,

*Type option will be selected as BUSINESS and Continue button will be pressed.

As the last step, the Dangerous Goods Safety Consultant assignment will be approved from the "Approval Procedures" option.

WHY ARE SAFETY DATA SHEETS IMPORTANT FOR DANGEROUS GOODS SAFETY CONSULTANT?

1-) There are “Safety Data Sheets (MSDS)” that contain information such as identity, composition, first aid measures, physical and chemical properties of all substances. MSDSs consist of 16 sections in total and the 14th section is the section related to transportation. If a substance is assigned a UN Number in section 14 of the MSDS, that substance is defined as dangerous goods under ADR. 

2-) Dangerous Goods Safety Advisors use the 14th Section of the Safety Data Sheets, Transportation Information section of the Safety Data Sheets to understand whether the raw material and product information of the company is a Hazardous Substance or Non-Hazardous Substance. For this reason, it is of great importance that the Safety Data Sheets reach the consultants in a short time. In addition, keeping the Safety Data Sheets up-to-date is another important aspect. Because outdated Safety Data Sheets may contain false information, it puts companies at risk both legally and operationally.

DOES GETTİNG DANGEROUS GOODS ACTIVITY CERTIFICATE REQUIRED TO RECEİVE CONSULTANT SERVİCE TOO?

With the regulation on the transportation of dangerous goods by road dated April 24, 2019, all companies dealing with dangerous goods, regardless of the amount, must obtain a dangerous goods activity certificate.

There is no obligation to receive Dangerous Goods Safety Consultancy services if the company is not engaged in class 1, class 6.2 and class 7 and if the total activity is below the 50 tons limit. In this case, it is necessary to work with the Dangerous Goods Safety Consultancy Institution and make an exemption study within the first 3 months of each year.

WHAT KIND OF SANCTION WILL WE FACE IF WE DON’T ENTER THE DANGEROUS GOODS ACTIVITY REPORT?

The responsibility of "Preparing the annual activity reports of the enterprise regarding the transportation of dangerous goods within the first three months as of the end of the year and submitting them to the administration in electronic environment", which is stated in the regulation on the transportation of dangerous goods on the road published by the Ministry of Transport and Infrastructure of Turkey, will be violated and your business will be in breach of the current highest TMGD of that day. punishable by punishment.

At the same time, prestige-damaging negativities may occur in the future for this situation where non-compliance is given.

WHAT IS EXEMPTION REPORT?

With the regulation on the transportation of dangerous goods by road dated April 24, 2019, all companies dealing with dangerous goods, regardless of the amount, must obtain a dangerous goods activity certificate.

There is no obligation to receive Dangerous Goods Safety Consultancy services if the company is not engaged in class 1, class 6.2 and class 7 and if the total activity is below the 50 tons limit. In this case, it is necessary to work with the Dangerous Goods Safety Consultancy Institution and make an exemption study within the first 3 months of each year.

IS A SUBSTANCE THAT IS DANGEROUS ACCORDING TO ENVIRONMENTAL LEGISLATION ALSO ACCORDING TO ADR LEGISLATION?

According to the ADR Legislation, whether a substance is dangerous or not is defined in the 14th section of the safety data sheet for the chemical or mixture.

If there is a UN number for the substance or mixture in this section, it is considered dangerous under ADR. There is no obligation that a substance that is dangerous for the environment will be dangerous according to ADR, and a substance that is dangerous according to ADR may not be dangerous according to environmental conditions.

DOES TMGD CONTRIBUTE TO ENVIRONMENTAL PRACTICES?

Today, TMGD and Environmental consultancy can be carried out in an integrated manner.

While the waste declaration, which is the responsibility of the environmental consultant, is used in the annual reports prepared by TMGD every year, environmental consultants also benefit from the annual activity reports of TMGD in the BEKRA declarations they make for the facilities that use, produce and store chemicals.

Working together with TMGDs in BEKRA Statements provides faster and easier access to the right information. The integrated work of the environment and TMGD teams makes great contributions in terms of facility health and easy access to information.

CAN I DO THE TASK OF TMGD OWN IN THE COMPANY?

In order for an employee with a TMGD certificate to serve on behalf of the company and carry out the necessary work, the insurance must be made full-time with the TMGD profession code 2263.06.

If the insurance code condition is met and the personnel is not insured elsewhere, the personnel can be appointed on behalf of the company. However, if the company personnel do not have a previous TMGDK background, it will be difficult for both parties to manage the process. Following the current regulation process requires serious knowledge and field experience, as well as making the necessary documentation in addition to field visits.

When you receive service from a TMGDK, although you have a consultant appointed, the constant exchange of ideas and knowledge among our team members will ensure that you are more beneficial as an outside eye towards the company.

In addition to hiring a full-time TMGD personnel as the addressee instead of a company, it also creates more costs with situations such as salary, insurance, and seniority accumulation to occur.

For these reasons, getting professional service is much healthier and more beneficial for companies.

WHAT IS TRANSPORT DOCUMENT?

It is the document issued during the shipment of dangerous goods subject to ADR by road.

It should be completely independent from the waybill and should include all the content information about the dangerous goods, as well as the vehicle and driver information that will carry out the transportation.

WHAT HAPPENS IF I DO NOT RECEIVE CONSULTANCY SERVICE?

Penalty sanctions are separately 1707 TL per month for businesses that do not have TMFB (Dangerous Goods Activity Certificate), and 4409 TL per month for businesses that do not have TMGD (Dangerous Goods Safety Advisor), for a total of 6.116 TL, and the penalty is repeated every 29 days.

Since it does not have a Dangerous Goods Safety Consultant the company will be deficient in applications and will also face many risks and penalties.

HOW CAN I CHECK IF MY COMPANY HAS AN APPOINTMENT?

You can check this control at www.tmkt.gov.tr from the List of Authorized Organizations / TMFB Owner Enterprises.

Zero (0) in the Active TMGD Number tab indicates that you do not have a TMGD assignment. It is very important for you to follow up whether the consultancy firm you are working with is playing in the assignments.

CAN WE FILL PACKAGES, INCLUDING LARGE PACKAGINGS AND IBCs, TO THE BRIM WHILE FILLING THE LIQUID?

According to the 4.1.1.4 reference of the ADR Legislation, enough space will be left against the possibility of expansion of the packages.

IBCs cannot be filled more than 98% and Filling rates vary according to their Boiling Points.

I HAVE MORE THAN ONE BRANCH, IS ONE DANGEROUS GOODS ACTIVITY CERTIFICATION ENOUGH?

The dangerous goods activity certificate must be taken at the address where the company's activity takes place. The company with the same title must have a separate dangerous goods activity certificate for the location where each activity takes place and appoint a consultant on each document.

WHAT IS THE OPENING OF ADR?

Meaning in Turkish; It is the European Convention for the Carriage of Dangerous Goods on International Roads. It is referred to as “ADR” for short in the international arena.

The abbreviation ADR comes from the initials of the words in the original French name of the contract: “Accord européen relative au transport international des marchandises Dangereuses par Route”

How Does the Resident Only Representative Provide Service ?

A natural person or legal entity established physically in TURKEY Equipped with sufficient knowledge in the practical handling of the substances and information related to them (CICR/KEK, CLP/SEA, SDS/GBF, TURKEY-REACH/KKDIK, BPR, PPPR, related TR )

Appointed by a mutual agreement with a manufacturer, formulator or article producer, established outside Turkey Responsible for complying with the legal requirements for importers under TURKEY-REACH (KKDIK)

Only representatives can represent more than one non-TR supplier, but must keep the information related to each of them. The non-TR company has to inform the importer (s) within the same supply chain of your appointment as an only These importers are then regarded as downstream users for TURKEY-REACH.

What are the Valid Deadlines?

Pre-registration within the scope of KKDIK had to be made by 31 December 2020. Since the system is not closed, pre-registration and master registration can be done together. The deadline for this is 31.12.2023. The registration date is not affected by the tonnage band.

Who Can Register ?
  • Manufacturers
  • Importers
  • Non-Turkey manufacturers can appoint an “Only Representative (OR)” similar to EU REACH for the pre- registration and registration
How can we certify that our company is exempt from TMGD service?

Companies whose total activity of dangerous goods in all branches of activity (consignee – loader – Consignor – filler – packer – carrier) is less than 50 tons and does not engage in Class 1, Class 6.2 and Class 7; In agreement with a TMGDK, first of all, it should obtain a Dangerous Goods Activity Certificate and report that its activity is below 50 tons with official documents and submit this report to the Regional Directorate of the Ministry of Transport and Infrastructure.

This process should be repeated in January of each year and the exemption should be updated. Only authorized TMGD institutions can carry out these reporting and transaction follow-ups, and companies that have TMGD within their structure must also receive services from TMGDKs.

If the activity is 50 tons or more, or if there is an activity in one of Class 1, Class 6.2 and Class 7 regardless of the amount, a Dangerous Goods Safety Advisory assignment should be made and service should be obtained instead of exemption.

ARE TMGD U-NET AUTOMATION SYSTEM AND OHS-KATIP DIFFERENT SYSTEM?

It is an automation system established by the Ministry of Labor and Social Security of Turkey on the OHS - Katip E-Government system for Occupational Health and Safety transaction entry and follow-up.

U-Net, on the other hand, is an automation system established by the Ministry of Transport and Infrastructure of Turkey on the E-Government system for transaction entry and follow-up within the scope of Dangerous Goods Security transactions. Although the two are similar but affiliated to different ministries, they are automation systems established for the purpose of transaction entry and follow-up.

DO I NEED TO COMPLY WITH TUNNEL RESTRICTION IN DANGEROUS GOODS TRANSPORT?

According to the dangerous substance transported, in the ADR legislation, each product either has a tunnel code as A / B / C / D / E or there is a - sign in the tunnel code tab. The presence of a “–” sign here indicates that the product can pass through all tunnels. For example, if C is written in the tunnel code tab, the product cannot pass through the C, D, and E tunnels while passing through the A and B tunnels.

In tunnel constraints, A represents the best tunnel and E represents the lowest quality tunnel. However, tunnel restrictions are not yet implemented in our country and the passage of dangerous goods through tunnels is currently completely prohibited.

Note; Although it is stated in the regulation that the tunnels will be lettered until the end of 2019 (regulation provisional article 3), we expect the issue to be extended again.

HOW CAN I MAKE 50 TONS OF DANGEROUS GOODS ACTIVITY ACCOUNT?

The amount of 50 tons mentioned here is the sum of the transactions made in all activity partıes. In other words, in order to understand whether a company has exceeded the 50-ton limit, first of all, it has to identify the dangerous substances within the scope of ADR and determine what activities it carries out with these substances.

Afterwards, the amount of dangerous goods that it receives, unloads, consignor, packer, filler and carrier separately will be calculated and collected separately for each item and it will be determined whether it exceeds the 50 tons limit.

Another issue that should not be overlooked here is that all hazardous wastes from the company should be included in the calculation of the amount, including the parties.

All parties whose annual declaration is made in the dangerous goods activity reports should be included in the calculation of the 50 tons limit.

WHAT SHOULD I DO IF I DO NOT OPERATE WITH TOTAL 50 TONS OF DANGEROUS GOODS IN ONE CALENDER YEAR?

Companies whose total dangerous goods activity in all branches of activity (Consignee - Unloader - Consignor - Loader - Filler - Packer - Carrier) is below 50 tons in a calendar year and does not operate in Class 1, Class 6.2, Class 7; First of all, a Dangerous Goods Activity Certificate (TMFB) should be issued together with the Annex-3 report to be prepared by a Dangerous Goods Safety Consultancy Organization (TMGDK) authorized by the ministry.

After reporting that the company's activity is below 50 tons per year with official documents, it should gain the right to exemption by submitting this report to the Regional Directorate of the Ministry of Transport and Infrastructure. This process should be repeated in January of each year and the exemption should be updated.

Only authorized TMGD institutions can carry out these reporting and transaction follow-ups, and companies that have TMGD within their structure must also receive services from TMGDKs. If the annual activity is 50 tons or more, or if the company is dealing with Class 1, Class 6.2, Class 7, a Dangerous Goods Safety Consultancy assignment should be made and service should be obtained instead of exemption.

IS THERE A TIME REQUİREMENT FOR THE VISITS OF TMGDS TO COMPANIES?

Although there is no obligation in the legislation, it is shaped according to the company's capacity and demand in general. Dangerous Goods Safety Consultant  can start the process by making the most appropriate decision on this issue.

I USE THE NATURAL GAS I BUY WITH THE CENTRAL SYSTEM ( MUNICIPAL SERVİCES) IN THE HEATING, KITCHEN AND THE REQUİRED PRODUCTİON PROCESS WILL I MEET THE LEGISLATİON REQUİREMENT FOR THE NATURAL GAS PURCHASE?

The natural gas we purchase from the municipality at the service point is not subject to the legislative requirements.

Or even the stored gas and fuels purchased from a company for heating or kitchen purposes are exempted only as the Consignee, but if these substances are purchased for use in the production process, you are subject to ADR legislation requirements. The first thing you need to do is to make an agreement with a TMGDK and apply for TMFB and get the necessary consultancy service.

HOW MUCH WILL I NOT PAY AVERAGE TO AUTHORIZED ORGANIZATİONS FOR TMGD SERVİCE?

The main factor is that the number of appointments allowed to TMGD by the ministry over the E-Government system is 8, although the company's demands vary according to the workload and the number of service days.

Of course, you can understand whether this TMGDK organization is a certificate leasing organization by multiplying your price by 8 and considering TMGD and company expenses.

WHY SHOULD I CHOOSE TMGD ORGANIZATIOON INSTEAD OF FULL TİME TMGD?

The fact that the enterprise employs full-time individual TMGD within its own structure brings higher responsibilities to the enterprise in terms of cost and workload, while at the same time, issues such as the individual TMGD's other responsibilities in the enterprise, the obligation to deposit the insurance code with the TMGD professional code, for the full-time individual TMGD, the enterprise also has compelling effects.

On the other hand, in the service received from an externally authorized TMGDK, the fact that the institution can fulfill legal obligations more actively thanks to its expertise in ADR and its sectoral diversity provides convenience to the enterprise, while it is in the interest of the enterprise to take legal responsibility over the enterprise and protect it against possible problems.

TMGDKs will be in contact with the ministry and follow the renewed legal regulations and raise the awareness of the business, while at the same time, they will be a third eye for the business with monthly visits and will eliminate many legal obligations by taking quick precautions against possible problems. 

In addition to their responsibilities in an individual full-time TMGD business,

-Complete the notifications of the Annual Dangerous Goods Activity Amount Report, which should be made every year,

-Business must follow ADR party obligations,

-Continue the documental dimensions such as Transport Document, Vehicle Control Form, Accident report,

-Plan and implement annual trainings and exercises,

- It should ensure the follow-up of legal regulations and prepare the business against audits, etc.

Instead, businesses prefer to receive services from TMGD organizations as professional support, which will fully protect the business against possible problems.

WE DON’T KNOW WHO IS OUR COMPANY’S E STATE U-NET AUTOMATION OFFICER. WHAT SHOULD WE DO?

Information and support can be obtained about the e-Government authority by reaching the regional directorates of the Ministry of Transport and Infrastructure of Turkey.

DO LOGISTICS AND TRANSPORT COMPANIES HAVE OBLIGATION OF DANGEROUS GOOD SAFETY CONSULTANT?

In logistics and transportation companies that transport dangerous goods, those with a vehicle carrying capacity of 50 tons or more must have a dangerous goods safety consultant within their structure or must get service from a dangerous goods safety consultancy company.

In the past, only the companies operating in transportation were not required to obtain a Dangerous Goods Activity Certificate, but it was sufficient to make their TMGD assignments on the transportation authorization documents. However, within the scope of the regulation published on April 24, 2019, shipping companies are also required to apply to the regional directorates with an Annex-3 report and obtain a Dangerous Goods Activity Certificate and assign or have a Dangerous Goods Safety Consultancy assigned to this document.

I’AM AN ENVIRONMENTAL OFFICER. CAN I CONSULT ON DANGEROUS GOODS SAFETY?

Persons who have obtained an Environmental Officer Certificate from the Ministry of Environment, Urbanization and Climate Change of Turkey; In accordance with Article 10 of the Regulation on Environmental Officer, Environmental Management Unit and Environmental Consulting Firms; Except for the obligations defined in this regulation, they cannot be employed in other works and transactions within the enterprise.

Likewise, TMGDs can provide full-time services to companies with only 2263.06 occupational code and cannot do two jobs at the same time.

SHOULD I TAKE RENEWAL TRAINING AFTER I BECOME A DANGEROUS GOODS SAFETY CONSULTANT?

All TMGDs; They will receive refresher training in the year the new version of ADR, RID and IMDG Code Agreements is published (For example, between 01.01.2019-31.12.2019 for ADR and RID, 01.01.2020 to 31.01.2020 for IMDG Code).

Renewal trainings must cover national legislation and ADR, RID, IMDG Code changes. The registration of the refresher trainings will be made by the training institutions through the UNET Automation System. The duration of the training will be 16 hours each.

WHAT IS THE INSTRUCTIONS IN WRITING?

It contains short and clear information about what to do in case of an accident or emergency that may occur during transportation.

It is obligatory to have color printing in vehicles carrying dangerous goods.

HOW CAN I UNDERSTAND A SUBSTANCE IS HAZARDOUS ON THE SCOPE OF ADR?

In the current SDS of the article (Safety Data Sheet), in the section 14th section of the transportation information; If the substance is assigned to any UN number, we can understand that it is dangerous according to the ADR legislation, if it is not assigned to any UN number and is reported to be non-hazardous, we can understand that it is not dangerous according to the ADR legislation.

The most important thing here is whether the SDS checked is up-to-date and approved.

CAN I WORK BOTH AS A DANGEROUS GOODS SECURITY CONSULTANT AND IN ANOTHER BUSINESS?

The Dangerous Goods Safety Consultant must be a full-time consultant who only has insurance with the 2263.06 TMGD SGK code in the company he works for and does not work in any other business.

Or As a full-time Dangerous Goods Safety Consultant in a TMGDK (Authorized Dangerous Goods Safety Consultancy Institution) authorized by the Ministry of Transport and Infrastructure of Turkey, he can advise 8 businesses under the control of his Coordinator.

I CARRY DANGEROUS GOODS, SHOULD I REFER TO CHECK POIINTS?

Vehicles carrying dangerous goods must stop by the European (Uskumruköy) and Anatolian (Riva) dangerous goods vehicle checkpoints, make the necessary notifications, and if the vehicle pass is deemed appropriate, they must cross the Yavuz Sultan Selim Bridge in company with the vehicle convoy.

As it is known, the passages of vehicles carrying dangerous goods without stopping by the control points pose an irreparable risk of damage for the safety of both the bridge and highway, as well as the driver and passengers crossing the bridge.

In addition, the relevant legislation and the General Directorate of Highways and ICA IC İÇTAŞ A.Ş. Administrative fine by the General Directorate of Highways and ICA IC İÇTAŞ A.Ş., in case vehicles carrying dangerous goods, whether full or empty, cross the Yavuz Sultan Selim Bridge without notification, appropriate to the contract between the parties. In addition to this penalty, a penalty is accrued by adding 10 times the amount of penalty to the special pass fee.

WHAT IS THE DIFFERENCE BETWEEN DANGEROUS GOODS ACTIVITY REPORT AND WASTE DECLARATION?

Dangerous goods activity report is created by entering the annual activity of the dangerous goods used in the business in all branches of activity (Consignee - Unloader - Loader - Consignor - Packer - Filler - Tank-Conyetner Operator and Carrier) by the Dangerous Goods Safety Advisor assigned to the company via the U-Net Automation system.

The waste declaration, on the other hand, is created by the Environmental Consultant assigned to the company, through the software system of the Ministry of Environment, Urbanization and Climate Change of Turkey, of the wastes, which are polluting the environment, resulting from the activities of the facilities.

I DO NOT CARRY ANY DANGEROUS GOODS ON THE HIGHWAY, WHY DO I HAVE TO TAKE THIS SERVICE?

In the ADR Legislation, the dangerous goods parties, including "Consignee-Unloader-Loader-Consignor-Packer-Carrier-Tank Container/Portable Tank Owner Operator", and these parties have certain obligations. Even if a company does not transport any dangerous goods, "dangerous goods transportation" as a result of the dangerous goods it has taken to the company for use in its own operation; and likewise, as a result of the hazardous wastes released in the company as a result of the production process, it can become a party to this legislation as "Loader-Consignor-Packer". As a result, businesses involved in any activity from the parties specified in the ADR legislation must receive Dangerous Goods Safety Consultancy service.

What is KKDIK ?

On June 23, 2017 the Turkish Ministry of Environment and Urbanization (MoEU) published a regulation named Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması Hakkında Yönetmelik (Bylaw on Registration, Evaluation, Authorization and Restirction of Chemicals) on Official Gazette Rep. No: 30105 for the management of substances, very similar to the EU REACH

Regulation, (EC) No 1907/2006.

The KKDIK regulation came into effect on December 23, 2017.

What is KKDIK Scope ?

KKDIK covers manufacturing, placing on the market or use of the substances on their own, in a mixture or in an article and placing the mixtures on the market unless they are:

  • Wastes
  • Radioactive materials and wastes
  • Substances used in defense industry
  • Non-isolated intermediates
  • Substances under transport and subject to customs
  • Substances in freezones or temporary storage waiting to be re-exported
What is the Purpose of KKDIK ?

To regulate the administrative and technical procedures and principles regarding the registration, evaluation, authorization and restriction of

To ensure a high level of protection of human health and the

To promote use of alternative methods for assessment of hazards of substances while enhancing competitiveness and

Why Is This So Important ?

All substances that are in scope of KKDIK have to be registered and pre-registered if they are produced or imported more than 1 ton per year unless they are exempt. Substances that are not pre-registered until the deadline will not be allowed to be placed in the Turkish market until their registration is complete. Substances that are not registered in time will not be allowed to be placed in the market