When Should You Appoint a DGSA? Triggers, Timing and Practical Guidance

Knowing when to appoint a DGSA is a mix of legal triggers, operational scale and practical risk management. For many companies, the correct time to obtain DGSA support is well before hazardous goods enter day-to-day operations — ideally during planning, procurement or when designing storage and transport processes.

Legal requirements are often the first trigger. In jurisdictions that implement ADR and similar frameworks, undertakings involved in the transport, loading, unloading or packing of dangerous goods must nominate a DGSA. The specific duties and thresholds vary by country, but the general principle is consistent: if your business regularly deals with hazardous shipments you will likely need a DGSA.

Practical triggers to appoint a DGSA include:

1. Starting to move dangerous goods: When a new product is introduced that is classified as hazardous, appoint a DGSA early to advise on classification, packaging and labeling.
2. Scaling up volumes: Increased frequency or batch sizes of hazardous shipments often creates new risks and regulatory obligations, making a DGSA necessary.
3. Entering new transport modes or routes: Shipping by sea, air or across borders introduces additional regulations. A DGSA helps ensure mode-specific rules are followed.
4. Opening a new facility or warehouse: A DGSA can design storage, segregation and emergency plans before operations begin.
5. After an incident or near-miss: Appointing or involving a DGSA after an event helps investigate root causes and prevent recurrence.
6. Regulatory change: New or updated regulations often require expert review to ensure existing procedures remain compliant.

Timing matters. Appointing a DGSA at the last minute—after the first shipment or following an accident—limits their ability to prevent harm. Early involvement during product selection, procurement or process design allows the adviser to influence choices (like selecting safer packaging or alternative transport options) that reduce risk and cost downstream.

How long does a DGSA need to be in place? Many organizations appoint a DGSA on an ongoing basis because dangerous goods handling is continuous. Some small businesses share a DGSA on a part-time or consultancy basis if their needs are intermittent. Where regulation requires an annual report or registration, appointing a DGSA at least a few weeks before report deadlines ensures adequate time for audits and documentation.

Another practical question is who should be the named DGSA. The person should be suitably qualified, either through recognized exams or through documented experience and training, depending on national rules. If you use a consultant, ensure they have relevant sector experience and access to your operational teams.

Finally, appointing a DGSA is not a one-time event. Regular reviews, refresher training and audits help keep advice aligned with changing operations and regulations. Businesses should treat the DGSA as a strategic partner: involve them in procurement decisions, route planning, and emergency planning to get the most value.

In summary, appoint a DGSA before hazardous goods become part of routine operations, when volumes or complexity increases, when regulatory obligations start to apply, or whenever there is a safety incident or regulatory change. Early and sustained involvement delivers better safety, smoother operations and reduces legal risk.