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GHS Situation and Gap Analysis – Transport Sector May 2006 Office of the Permanent Secretary, Ministry of Transport Study conducted by Mahidol University and Pongnarin Petchu Overview of the Study GHS Transport of DG Situation Gap Classification Hazard Communications Trainings Classification - Physical hazards - Health hazards - Environmental hazard Hazard Communications: - Labelling - Safety Data Sheet (SDS) Trainings of target audiences 15-17 May 2006 List of dangerous goods most commonly carried and their identification and Classification; Consignment procedures: Labelling, Marking and Transport Documents; Standards for packagings, test procedures and approval; Standards for multimodal tankcontainers, test procedures and certification; National Background Information Legal/regulatory Infrastructure National Institution/Adminitrative Infrastructure Programs conducted by Industry, Labor/Public/Environmental Interrest Groups and Research Institutes Programs conducted with support of international organizations Summary of Situation Analysis Summary of Gap Analysis Training of persons involved in transport GHS Situation and Gap Analysis – Transport Sector 2 A. Globally Harmonized System for Classification and Labelling of Chemicals (GHS) Overview of the GHS 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 4 Overview of the GHS Part General Physical 1 2 Hazard Communication Classification 1.1 Health Envi. Labelling SDS 1.4 1.5 1.4 6 6 1.3 1.2 Training 2.1-2.16 3 3.1-3.10 4 4.1 1 2 2 2 2 3 4 5 Annexes 6 7 8 8 8 9 10 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 5 GHS Classification PHYSICAL HAZARDS 1 Explosives 2 Flammable gases 3 Flammable aerosols 4 Oxidizing gases 5 Gases under pressure 6 Flammable liquids 7 Flammable solids 8 Self-reactive substances and mixtures 9 Pyrophoric liquids 10 Pyrophoric solids 11 Self-heating substances and mixtures 12 Substances and mixtures which, in contact with water, emit flammable gases 13 Oxidizing liquids 14 Oxidizing solids 15 Organic peroxides 16 Corrosive to metals 15-17 May 2006 HEALTH HAZARDS 1 Acute toxicity 2 Skin corrosion/irritation 3 Serious eye damage/eye irritation 4 Respiratory or skin sensitization 5 Germ cell mutagenicity 6 Carcinogenicity 7 Reproductive toxicity 8 Specific target organ systemic toxicity – Single exposure 9 Specific target organ systemic toxicity – Repeated exposure 10 Aspiration hazard ENVIRONMENTAL HAZARDS 1 Hazardous to the aquatic environment GHS Situation and Gap Analysis – Transport Sector 6 GHS Classification – Physical Physical Hazard Classes Hazard Category Unstable Explosives Div 1.1 Flammable Gasses 1 2 Flammable Aerosols 1 2 Oxidizing Gases 1 Explosives Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6 3 4 Type C Type D Type E Type F Type G Type D Type E Type F Type G Pressurized Gasses Compressed Gasses 1 Liquefied Gasses 1 Refrigerated Gasses 1 Dissolved Gasses 1 Flammable Liquids 1 2 Flammable Solids 1 2 Type A Type B Self-Reactive Substances Pyrophoric Liquids 1 Pyrophoric Solids 1 Self-Heating Substances 1 2 Water Reactive Flammable Gases 1 2 3 Oxidizing Liquids 1 2 3 Oxidizing Solids 1 2 3 Type A Type B Type C Organic Peroxides Corrosive to Metals 15-17 May 2006 1 GHS Situation and Gap Analysis – Transport Sector 7 GHS Classification – Health & Envi Health Hazard Classes Hazard Category Acute Toxicity, Oral 1 2 3 4 5 Acute Toxicity, Dermal 1 2 3 4 5 Acute Toxicity, Inhalation 1 2 3 4 5 Skin Corrosion/Irritation 1 1A/B/C 2 3 Eye Damage/Irritation 1 2 2A/B Respiratory Sensitization 1 Skin Sensitization 1 Germ Cell Mutagenicity 1 1A/B/C 2 Carcinogenicity 1 1A/B/C 2 Reproductive Toxicity 1 1A/B/C 2 Target Organ ST – Single Dose 1 2 3 Target Organ ST – Single Dose 1 2 Aspiration Hazard 1 2 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector Lactation 8 GHS: Hazard Communications Labelling Safety Data Sheet Pictograms from Cradle to Grave Workplace including pesticides and Labels and Safety Data Sheets pharmaceuticals Consumers Labels Transport Labels, Placards, Transport Documents Emergency responders Labels, Placards 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 9 GHS Training 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 10 B. International Regulations for Transport of Dangerous Goods The UN System 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 12 International Regulations Structure Sub-Committee of Experts on the Transport of Dangerous Goods > 25 “Expert” Countries Observer Countries: Unlimited IGOs Committee of Experts on the Transport of Dangerous Goods NGOs ECOSOC United Nations Economic and Social Council IAEA Transport Regulations (Radioactive material) UN Recommendations on the Transport of Dangerous Goods (Model Regulations or Orange Book) International Regional/National UNEP ICAO IMO Control of hazardous waste movement AIR SEA Chicago convention Annex 18 Governments European Union UN Regional Commissions National legislations EC Directives (94/55/EC and 9649EC) ECLAC, ESCAP, ECA, ESCWA UN/ECE IATA Solas/Marpol Inland Transport Basel convention ICAO TI IATA Regulations IGC code IBC/BCH codes BC code IMDG code Road Rail UN/ECE UN/ECE OTIF Inland waterway UN/ECE / CCNR / Danube Commission ADR 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector RID ADN/ADNR 13 International Regulations for Dangerous Goods Transport System System of Linkage http://www.unece.org/trans/danger/danger.htm 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 14 International Regulations for Dangerous Goods Transport System Multi-modal Transport: UN Recommendations on the Transport of Dangerous Goods: a so-called “UN Model Regulations” or “Orange Book” Road: The Restructured ADR of UNECE in Geneva, Rail: The Restructured RID of OTIF in Bern, Inland Waterways: The Restructured ADN of UNECE in Geneva, Sea: IMDG Code of IMO in London, Air: IATA-DGR of ICAO-TI of ICAO Montreal http://www.unece.org/trans/danger/danger.htm 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 15 European and German Rules & Regulation of DG Transport: “History/Road Map” ADR 2003 was put into force Modification of Regulation about the Dangerous Cargo Officer in respective companies according to the EU-Regulation 96/35 concerning the appointment and qualification of Safety-Advisor Requirement of training for driver of dangerous goods in package form according to ADR Introduction of training for driver of dangerous goods in packaged form in Germany Requirement of training for driver of liquid bulk transport according to ADR 1983 1998 2001 German Regulation about the control of dangerous cargo transports on road (EU 94/50) German Regulation of the exceptions of dangerous goods (GGAV) 1995 1997 1991 1993 2003 1989 Regulation about the 1st German Regulation Dangerous Cargo Officer 1st German (technical specification) in respective companies Notification about the transport of (GbV) regarding the dangerous goods on road Introduction of training for driver of (GGVS) transport of liquid bulk transport (mainly class 3 dangerous goods on products) in Germany road and publishing of the ADR including 1st German Law about the transport of the annexes A and B dangerous goods of all mode of transport (GBeGG) Restructured ADR 2001 Introduction of the ADR-legal framework regulation according to the EU-Regulation 94/55 in order to harmonise the various int’l regulations 1979 1981 1969 1957 15-17 May 2006 1975 Germany signed the European Agreement concerning the international carriage of dangerous goods by road (ADR) with annex A and B GHS Situation and Gap Analysis – Transport Sector 16 Development of the Classification System of Chemicals Past Workplace aspect • Risk Phrases – Acute and long-term effects • Storage classes Present Future 15-17 May 2006 – Segregation and separation of dangerous goods and dangerous substances • Transport aspect Transport classes – Acute effects (Closed packagings, Contact only in case of incident) Globally Harmonised System (GHS) • Harmonisation of classification and labelling systems • Same criteria but different limit values for handling and for transport GHS Situation and Gap Analysis – Transport Sector 17 Workplace aspect : Risk (R) - Phrases Physicochemical Properties Toxicological properties Property Risk phrase Property Risk phrase Explosives R2 R3 Toxic effects Oxidising R7 R8 R9 R28 R27 R26 R39 R25 R24 R23 R39 R48 R22 R21 R20 R65 R68 R48 Flammability R12 R11 R15 R17 R10 R30 Corrosive effects and other effects on skin R35 R34 R38 R36 R41 R37 Explosive reactions R1 R4 R5 R6 R16 R18 R19 R44 Sensitation R42 R43 Fire R7 Liberation of toxic gases R29 R31 R32 Water reactive R14 Other effects R33 R64 R66 R67 Specific effects on human health Specific effects on environment Property Risk phrase Property Risk phrase Carcinogenic substances R45 R49 R40 Toxic or harmful effects on the aquatic environment R50 R51 R52 R53 Mutagenic substances R46 R68 Toxic flora, fauna, soil organisms and bees R54 R55 R56 R57 Substances toxic to reproduction R60 R61 R62 May cause long-term adverse effects in the environment R58 Dangerous for the ozone layer R59 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 18 Workplace aspect : Storage classes Storage class 1 2A Description Storage class Explosive substances 5.2 Compressed, liquefied and dissolved gases 6.2 7 2B Pressurized small gas containers (aerosol cans/aerosol containers) 3A Flammable liquids 3B Flammable liquids 9 4.1A Flammable solids 10 4.1B Flammable solids 8B 11 4.2 Spontaneously combustible substances 4.3 Substances that emit flammable gases in contact with water 5.1A Oxidising substances 5.1B Oxidising substances 5.1C Oxidising substances 15-17 May 2006 8A 12 13 Description Organic peroxides Infectious substances Radioactive substances combustible corrosive substances Non- combustible corrosive substances (not used) Combustible liquids unless classified in storage class 3 A or 3 B Combustible Storage Non- combustible liquids Non- combustible solids GHS Situation and Gap Analysis – Transport Sector 19 Transport Aspect: Transport classes Class Description 1 Explosives 2 Gases Packing Group (PG) 1.1 1.2 1.3 1.4 1.5 1.6 Flammable gases Gas under pressure Toxic gases 3 Flammable liquids I II III 4 Flammable solids Spontaneous combustible substances Dangerous when wet I II III 5 Oxidizing agents Organic peroxides I II III 6 Toxic substances Infectious substances I II III 7 Radioactive material 8 Corrosive substances I II III 9 Miscellaneous 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 20 Comparison of GHS vs. Transport Explosives Class 1 Acute Toxicity, Oral Class 6.1 Flammable Gasses Class 2 (2.1) Acute Toxicity, Dermal Class 6.1 Flammable Aerosols Class 2 (2.1) Acute Toxicity, Inhalation Class 6.1 Oxidizing Gases Class 5.1 Skin Corrosion/Irritation Class 8 Pressurized Gasses Class 2 (2.2) Eye Damage/Irritation Compressed Gasses Class 2 (2.2) Respiratory Sensitization Liquefied Gasses Class 2 (2.2) Skin Sensitization Refrigerated Gasses Class 2 (2.2) Germ Cell Mutagenicity Dissolved Gasses Class 2 (2.2) Carcinogenicity Flammable Liquids Class 3 Reproductive Toxicity Flammable Solids Class 4.1 Self-Reactive Substances Class 4.3 & Class 1 (for category 1) Target Organ ST – Single Dose Pyrophoric Liquids Class 4.2 Pyrophoric Solids Class 4.2 Self-Heating Substances Class 4.2 Water Reactive Flammable Gases Class 4.3 Oxidizing Liquids Class 5.1 Oxidizing Solids Class 5.1 Organic Peroxides Class 5.2 Corrosive to Metals 15-17 May 2006 Target Organ ST – Single Dose Aspiration Hazard Acute Toxicity, Oral Class 9 Acute Toxicity, Dermal Class 9 Class 8 GHS Situation and Gap Analysis – Transport Sector 21 Hazard Communications Example of existing Danger Labels of Workplace and Transport 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 23 Example of Pictograms and Labels of GHS 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 24 Example of transport labels (still the same except Class 5.2) 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 25 Documents for Transport (1) The following documents shall be carried on the transport unit (truck) • transport documents • container packing certificate if appropriate • instructions in writing • driver’s training certificate • certificate of approval for tank vehicles and vehicles transporting tank containers Documents for Transport (2) Transport documents must bear the following information • Name and address of consignor • Name and address of consignee • UN-number • Proper Shipping Name • Class (number of label model for primary and secondary property) • Packing group • Number and description of packagings • Total quantity • Declaration concerning special agreement Documents for Transport (3) Instructions in writing (tremcards = transport emergency cards) • for each substance, if the limits of 1.1.3.6 are exceeded • information for driver and emergency services (fire brigade) • language of the driver • language of country of departure • language of country of destination • languages of transit countries • certain information Documents for Transport (4) Contents of instructions in writing • name of the substance or group of goods (load) • nature of danger • personal protection • general actions to be taken by the driver • additional and/or special actions to be taken by the driver • fire • first aid • additional information Training of Persons involved in the Carriage of Dangerous Goods Persons employed by the participants referred to in Chapter 1.4, whose duties concern the carriage of dangerous goods, shall receive training in the requirements governing the carriage of such goods appropriate to their responsibilities and duties. The trainings undertaken should be documented and supplemented with refresher training. 1. General Awareness training: to be familiar with the general requirements of the provisions for the carriage of dangerous goods 2. Function – specific training: to receive detailed training according to their duties and responsibilities 3. Safety training: to receive training covering the hazards and dangers presented by dangerous goods (aiming to make personnel aware of the safe handling and emergency response procedures) 4. Training for class 7: receive appropriate training concerning the radiation hazards involved and the precautions to be observed in order to ensure restriction of their exposure 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 30 Transport & GHS Training GHS Transport GHS Chemicals life cycle Transport Transport of Dangerous Goods 15-17 May 2006 Import Transport Storage Production Storage Consignor Transport End users Consignee Packer/Loader/ Filler Driver Carrier GHS Situation and Gap Analysis – Transport Sector 31 Safety obligations of the participants of the transportation process Prior to transport During transport - Consignor (1.4.2.1) - Carrier (1.4.2.2) - Loader (1.4.3.1) - Driver (Chapter 8.2) After transport - Consignee (1.4.2.3) - Packer/Filler (1.4.3.2) & 1.4.3.3) - Tank-container / portable tank operator (1.4.3.4) Take appropriate measures to reduce or minimize the risk from transport Receive training in the requirements governing the carriage of such goods appropriate to their responsibilities and duties (Chapter 1.3) 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 32 Situation & Gap Analysis A) Legal/Regulatory Infrastructure B) National Institution/Administrative Infrastructure C) Programs Conducted by Industry, Labor / Public / Environmental Interest Groups and Research Institutes D) Programs Conducted with Support of International Organizations Statistical Model for Transport of Dangerous Goods by Modes of Transport and Classes 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 34 Overview of Problems from exposures to chemicals • Acute effect most concern for transport sector • Packagings/containment system will get UN Marks to certify that they passed the required tests and can take for transport 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 35 Disaster from Dangerous Goods Incidents in Thailand 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 36 Disaster from Dangerous Goods Incidents in Thailand Substance involved: Liquefied Petroleum Gas : LPG) UN 1075 Incident Place: Petchburi Road, Bangkok Date: 24 Sep 1990 Time: around 22:00 hrs. 54 Death with 97 injury Cause: Careless driving, too fast driving and incomplete equipment (low standard) 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 37 Disaster from Dangerous Goods Incidents in Thailand Substance involved: Explosive Substances of Class 1 Incident Place: Phang-Nga Province (South) Date: 15 Feb 1991 Time: around 15:00 hrs. 171 Death with 99 injury Cause: Careless driving, too fast driving and incomplete equipment (low standard) 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 38 Disaster from Dangerous Goods Incidents in Thailand Substance involved: Acrylonitrile (UN1093) Incident Place: 2ND stage Express Way, Bangkok Date: 4 Sep 2001 Time: around 05:00 hrs. Cause: Careless driving 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 39 Legal/Regulatory Infrastructure – existing regulations Hazardous Substance Act B.E. 2535 for control of production, import, export, and possession of hazardous substances Land Transport Act B.E. 2522 control transportation of man, animals and substances by land (by carriers of designated and undesignated routes) for the safety purposes to public Land Traffics Act B.E. 2522 concerns about safe transport on land traffic (enforced by the National Police Office) Navigation in Thai Water Act B.E.2456 and amended B.E.2535 controls all navigation in Thai waters Air Traffics Act B.E.2497 controls air traffics according to the international agreement on civil aeronautics, which Thailand is a member (Chicago/December 1944 to facilitate air transport accidents and qualifications of personnel) The Railway Act of Thailand B.E.2494 and Fifth Amendment BE. 2530 concerns all activities of train transport including all relevant regulations Other regulations concerning transportation of hazardous substances as announced by other agencies 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 40 National Institutional / Administrative Infrastructure DIW chemicals hotline 1564 and www.diwsafety.org Pollution control Department (PCD) hotline 1650 and www. http://www.pcd.go.th The Thai-FRID (Thai First Response Information Database) - a joint development program between the Information and Communication Technology Center, Office of the Permanent Secretary Ministry of Transport and GTZ developed during the Thai-German Dangerous Goods Project Implementation in 1998-2003 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 41 National Institutional / Administrative Infrastructure http://gis.mot.go.th/motcgtz/index.cfm http://www.pcd.go.th/info_serv/er/defaultthai.cfm 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 42 Programs conducted by Industry Responsible Care Management Committee of Thailand (RCMCT) under the Federation of Thai Industries (FTI) 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 43 Programs conducted by Industry 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 44 Programs conducted with Support of International Organizations Year Bi-lateral development cooperation Type of Program 1998-2000 GTZ Drafting of TP-I (NESDB) Train-the-trainer of driving license class 4 (DLT) Train-the-trainer of inspection of dangerous cargo vehicles (DLT) Training of Thai officials for packagings and tanks approval Train-the-trainer Hazmat Course 1 2000-2003 GTZ Drafting of TP-II (ADR) and TP-III (ADN) Training – Classification of Dangerous Goods including GHS Train-the-trainer Hazmat Course 2 Thai – German Dangerous Goods Project Thai – German Technical Cooperation 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 45 Achievements of the Project Transport System Emergency Response System Thai Provisions Volume I (TP-I) HazMat Training Courses The Multi-modal Transport of Dangerous Goods based on UN Recommendations for Transport of Dangerous Goods or the “Orange Book” : approved by the cabinet on May 23, 2000 with Handbooks and Instructor Manuals as well as the coaching and supporting of “train-the – Trainer” Courses to ensure the professional know-how transfer and the most appropriate qualification of First Response Teams Thai Provisions Volume II (TP-II) The Transport of Dangerous Goods by Road based on the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR2003) : ready for seeking approval from the cabinet Thai Provisions Volume III (TP-III) Thai First Response Information Thai-FRID): a database for the preparedness, planning and response to the incident involving dangerous goods: available at MoT and can be downloaded from the website: www.mot.go.th The Transport of Dangerous Goods by Inland Waterways based on the European Agreement Concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN2003) still on-going process by Marine Department Storage / Handling Guideline for Safe Storage of Dangerous Goods and Dangerous Substances: approved by the IEAT’s Governor in November 2002 Various trainings for core team of the government officials involved How to Use the Guideline, How to Get Appropriate Information, Classification of DG & DS, Using guideline for accident prevention Various trainings for core team of the government officials involved Driving License Class IV, Inspection of DG Cargoes vehicles, Transport of Dangerous Goods by Inland Waterways, Tanks Inspection and Certification, Approval of Packagings, Classification of DG & DS 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 46 International Regulations for Dangerous Goods Transport System adopted to Thai Provisions Thai Provisions Vol. II Thai Provisions Vol. II Thai Provisions Vol. III 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 47 Protocol 9: Agreement for transport of DG in transit in ASEAN Countries 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 48 Summary of Situation and Gap Analysis Classification: Already in line with the international transport regulations (UN Recommendations and ADR) but laboratories for testing of chemicals and consulting companies are still opened for establishment with facilitating of the government sector, Hazard Communication: Already inline with the international transport regulations (UN Recommendations and ADR) but required a clear competent authority to supervise, control and check of the whole transport system with all modes of transport and training of persons involved in the transport life cycle is strongly required, Training system: according to the TP-II (drivers and persons involved) is not fully in line with the international regulations and lack of information and support to SMEs as well as more awareness raising to relevant sectors and authorities, Enforcement is still needed to be tightening by training of responsible authorities and polices 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 49 Domestic Transport of Dangerous Goods – Processes and Persons Involved Start of Transport Process During Transport Process End of Transport Process Possible Transport Modes Ports Factories (IE/IP) Possible Transport Origins Warehouses Distribution Center Refineries Road Ports Factories (IE/IP) Rail Warehouses Inland waterways Distribution Center Possible Transport Destinations Refineries Coastal shipping Gas Stations Transport by pipelines Trans-shipment Trans-shipment End users Drivers Persons involved Custom officers Vehicle crew Custom officers Port operators Transport associations Port operators Consignors Transport operators / Carriers Consignees Loaders / Fillers / Packers Labor union Persons who unload / empty / unpack Transport operators Transport operators Chemical Industry Chemical Industry Emergency Responders Chemical Industry Transport associations Municipalities Polices / Highway polices Transport associations Labor union Labor union Persons involved Training of persons involved in the transport life cycle • Persons involved in the transport process are • Custom officers, • port operators (if the dangerous goods are imported from abroad and unloaded at a ports), • industrial provincial officers, • industrial estate officers, • loaders, fillers, packers, • drivers, • vehicle crew, • master of vessel, • others involved, like administrative staff of forwarding agent, carriers, etc. • These people involved have to be trained in order to gain knowledge about • • • • • • 15-17 May 2006 classes of dangerous goods and the inherent hazard properties, pictogram of each class, labelling of the packages, placarding of the transport units, Safety Data Sheet (SDS), written instruction or Transport Emergency Card (TREM Card), GHS Situation and Gap Analysis – Transport Sector 51 Next step and recommendations • • • • • • • • There is a need to make a clear cut about the competent authority and responsibilities of agencies involved, To establish a transport of dangerous goods committee to supervise and coordinate among the parties locally and internationally, The update and drafting of the relevant ministerial regulations and department notifications should be made, For a long run, drafting of a new Transport of Dangerous Goods Act is strongly recommended, The action of the government and responsible agencies on the facilitation of the service on classification and training of the target audiences in the transport related sector in regard to the GHS should be initiated to simplify the national implementation process of GHS, The incentive for encouraging private consulting to open up the markets in the training and consulting to SMEs should be considered, The stimulation of the awareness program and campaign made by the civil society and NGOs should be initiated and implemented to the whole life cycle of the transport because very often the civil society can be acting as magic eyes for the government and societies Some training curriculum should be introduced in the school or universities to ensure sustainable development 15-17 May 2006 GHS Situation and Gap Analysis – Transport Sector 52