{"id":"F2024L00681","name":"CASA EX29/24 — Dangerous Goods (2-yearly Training Requirement) Instrument 2024","slug":"casa-ex29-24-dangerous-goods-2-yearly-training-requirement-instrument-2024","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":105254,"registerId":"commonwealth-F2024L00681-current","compilationNumber":null,"startDate":"2026-04-03","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"CASA EX29/24 — Dangerous Goods (2-yearly Training Requirement) Instrument 2024","content":"Instrument number CASA EX29/24\n\nI, MATTHEW IAN BOUTTELL, Executive Manager, Regulatory Oversight, a delegate of CASA, make this instrument under regulations 11.160, 11.205 and 11.245 of the Civil Aviation Safety Regulations 1998.\n\n\\[Signed Matt Bouttell\\]\n\nMatt Bouttell  \nExecutive Manager, Regulatory Oversight\n\n14 June 2024\n\nCASA EX29/24 — Dangerous Goods (2-yearly Training Requirement) Instrument 2024\n\n1 Name\n\nThis instrument is CASA EX29/24 — Dangerous Goods (2-yearly Training Requirement) Instrument 2024.\n\n2 Duration\n\nThis instrument:\n\n(a) commences on the day after it is registered; and\n\n(b) is repealed at the end of 31 May 2027.\n\n3 Definitions\n\n(1) In this instrument:\n\n> Australian freight forwarder means a freight forwarder carrying on business in Australia on behalf of an Australian aircraft operator.\n\n> Australian ground handling agent means a ground handling agent carrying on business in Australia on behalf of an Australian aircraft operator.\n\n> exempted person means a person exempted under section 4.\n\n> screening authority has the meaning given by regulation 1.03 of the Aviation Transport Security Regulations 2005.\n\n(2) An expression used in this instrument that is defined in subregulation 92.010(1) of CASR has the meaning given by the subregulation, including: Australian aircraft operator, freight forwarder, ground handling agent, shipper of dangerous goods, Technical Instructions.\n\n4 Exemptions\n\n(1) An Australian aircraft operator is exempt from compliance with paragraph 92.095(2)(b) of CASR.\n\n(2) An Australian ground handling agent is exempt from compliance with paragraph 92.100(1)(b) of CASR.\n\n(3) An Australian freight forwarder is exempt from compliance with paragraph 92.105(1)(b) of CASR.\n\n(4) A screening authority is exempt from compliance with paragraph 92.115(2)(b) of CASR.\n\n(5) A shipper of dangerous goods is exempt from compliance with paragraph 92.120(1)(b) of CASR.\n\n(6) Each exemption mentioned in this section is subject to the conditions in section 5.\n\n5 Conditions\n\n(1) Subject to subsection (2), the exempted person must ensure that each of the person’s employees undertakes the recurrent training within the period commencing at the end of the month in which the employee last undertook the training, whether initial or recurrent, and ending after 24 months (the extended validity period).\n\n(2) If an employee undertakes a course of recurrent training within the final 3 months of the extended validity period (the final quarter), then the subsequent extended validity period does not commence until 24 months after the end of the previous extended validity period.\n\n> Note 1 This section gives effect to ICAO provision Part 1; 4.3, in the Technical Instructions (2023‑2024 edition) and section 1.5.1.3 of the IATA Dangerous Goods Regulations (65th Edition 2024).\n\n> Note 2 Examples of use of, or failure to use, an extended validity period:\n\n-   If an employee successfully completes their initial training course on 14 May 2024, their training validity would normally expire on 14 May 2026. Under the exemption and the condition in subsection 5(1), it would expire at the end of May 2026.\n-   If recurrent training of an employee was required by 14 May under the normal “every 2 years” validity period, and the training is completed between 1 March 2026 and the end of May 2026, and where the end of the next training validity period would normally expire 24 months from the date that the recurrent training occurred, under the exemption and condition in subsection 5(2) it would expire at the end of May 2028.\n-   If recurrent training of an employee who has previously used an extended validity period is required before the end of May 2026, and the training is completed between 1 March 2026 and the end of May 2026 (within the final quarter), the end of the next extended validity period occurs 24 months after the end of May 2028.\n-   If recurrent training of an employee is required before the end of May 2026 but that training is completed more than 3 months before the end of May 2026 (before the final quarter), the new expiry date is the end of the month, including the second anniversary of the day they completed that training. For instance, if the extended validity period is due to expire at the end of May 2026 but they complete recurrent training on 28 February 2026, under the exemption it would expire at the end of February 2028.\n\n6 Direction\n\n(1) If an exempted person chooses to make use of the extended validity period mentioned in subsection 5(1), the exempted person must, in writing, provide CASA with details of the training given to the exempted person’s employees, including dates of commencement and completion, on request by a CASA officer.\n\n(2) This direction ceases to be in force at the end of 31 May 2027.","sortOrder":0}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":3,"scope_assessment":{"changed":false,"description":"This instrument maintains its original narrow purpose: temporarily modifying the recurrent training interval calculation for dangerous goods handling personnel. It does not expand beyond this specific administrative exemption."},"complexity_factors":["Short instrument (6 sections, ~2 pages)","Only 4 defined terms in section 3, plus incorporated definitions from CASR","Simple structure: definitions → exemptions → conditions → direction","Complexity arises from subsection 5(2) which contains a conditional rule about 'final quarter' training that shifts the calculation baseline, requiring careful date arithmetic","Four worked examples in Note 2 assist interpretation but indicate the underlying rule is non-intuitive","Cross-references to 5 external regulatory provisions (CASR regs 11.160, 11.205, 11.245, 92.095, 92.100, 92.105, 92.115, 92.120 and subreg 92.010(1)) plus ICAO Technical Instructions and IATA DGR"],"plain_english_summary":"This temporary CASA rule lets airlines, ground handlers, freight forwarders, screening authorities and shippers use more flexible timing for 2‑year dangerous‑goods refresher training: expiries fall at the end of the month the 2‑year period ends, and retraining in the last three months preserves the original expiry so staff don’t lose certification time.\n\nIt reduces administrative burden, aligns with ICAO/IATA, requires businesses to keep records for CASA on request, and automatically expires 31 May 2027."},"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":true,"description":"This instrument temporarily modifies who must meet particular CASR training expiry paragraphs by exempting listed persons and substituting an end‑of‑month 24‑month validity regime with a final‑quarter carry‑over rule (s4–s5). It narrows operational timing obligations for a defined period and adds conditional record‑sharing to CASA (s6), thereby changing compliance scope and administrative duties for affected businesses until the instrument repeals on 31 May 2027 (s2)."},"complexity_factors":["Time‑limited, temporary exemption that expires 31 May 2027 (s2) — requires administrative tracking of sunset.","Multiple categories of regulated persons are covered (operators, ground handlers, freight forwarders, screening authorities, shippers) (s3, s4).","Changes the way training validity is calculated (end‑of‑month alignment and 24‑month ‘extended validity’) and adds a special ‘final quarter’ rule that affects the start of the next validity period (s5(1)–(2)).","Requires provision of training details to CASA on request, creating record‑keeping and disclosure obligations (s6(1)).","Direct cross‑references to several CASR paragraphs (listed in s4) mean interpretation depends on unchanged provisions elsewhere.","Notes reference ICAO/IATA materials (informative) which may influence implementation expectations but are not themselves normative in the instrument."],"plain_english_summary":"This instrument temporarily exempts Australian aircraft operators, ground‑handling agents, freight forwarders, screening authorities and shippers from certain CASR dangerous‑goods training expiry rules so recurrent training can be aligned to an “end‑of‑month” 24‑month validity window with special treatment if recurrent training occurs in the final three months (see s4, s5 and s2).  \n\nAffected employers must schedule and fund employee training, apply the extended‑validity timing rules in s5, and supply training details to CASA on request (s6); CASA retains inspection and disclosure direction powers."}},"importantCases":[],"_links":{"self":"/api/acts/casa-ex29-24-dangerous-goods-2-yearly-training-requirement-instrument-2024","history":"/api/acts/casa-ex29-24-dangerous-goods-2-yearly-training-requirement-instrument-2024/history","analysis":"/api/acts/casa-ex29-24-dangerous-goods-2-yearly-training-requirement-instrument-2024/analysis","conflicts":"/api/acts/casa-ex29-24-dangerous-goods-2-yearly-training-requirement-instrument-2024/conflicts","importantCases":"/api/acts/casa-ex29-24-dangerous-goods-2-yearly-training-requirement-instrument-2024/important-cases","documents":"/api/acts/casa-ex29-24-dangerous-goods-2-yearly-training-requirement-instrument-2024/documents"}}