October 04, 2021
The Ministry of Internal Affairs of Ukraine, in accordance with the Procedure for Public Consultations on the Formation and Implementation of State Policy, approved by the Resolution of the Cabinet of Ministers of Ukraine of November 03, 2010 No. 996, conducted electronic consultations with the public on the draft order of the Ministry of Internal Affairs of Ukraine “On Approval of Certain Norms legal acts on the organization of special training of workers in the transport of dangerous goods” (hereinafter - the draft order), which was published On August 17, 2021, in the subheading “Draft regulations” of the “Normative base of the Ministry of Internal Affairs” of the official website of the Ministry of Internal Affairs of Ukraine: here.
Information about proposals received during electronic consultations with the public on the draft order and on the results of their consideration is given in the table.
No. of sales/n |
Offer Information |
Author of the proposal |
Offer Consideration Information |
! 1 |
In the definition of “Commissioner for the Safety of Carriage of Dangerous Goods by Road” in paragraph 2 of Section I of the Draft Requirements, the word “shipment” must be added before the word “packaging”. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 2 |
The requirement to have at least two teachers in the Special Training Center provided for in subsection 1 (2) of section VI of the draft Requirements is not appropriate. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. The provisions on the mandatory presence of at least two teachers in the special training center are excluded |
! 3 |
The Draft Requirements provides for a final knowledge control to be carried out by the Center for Special Training. However, such control is not provided for by the legislation of Ukraine in the field of transportation of dangerous goods, the provisions of the DOP and does not comply with the practice of training drivers of vehicles transporting dangerous goods and authorized persons for the safety of dangerous goods in the countries of the European Union. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. The provisions on final control in special education centers are excluded |
! 4 |
Paragraph 12 of Section I of the Draft Procedure provides for the entry into the Unified State Register of the Ministry of Internal Affairs of information about the persons who passed the exams and the results of the examinations. However, the draft Procedure does not provide for the inclusion in the Unified State Register of the Ministry of Internal Affairs of information about persons who have not passed the exam. |
Public Union “Union of Special Road Traffic Participants” |
It has been taken into account. |
! 5 |
The duration of exams from the retraining course and specialized courses according to the requirements of DOPNV should be 30 minutes. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 6 |
Clause 1.8.3.16.2 of Appendix A to the DOPNV provides for a separate procedure for passing exams in case of extension of the Certificate of Training of the Commissioner for the Safety of Dangerous Goods. However, in the draft Order, these provisions of the DOPNV are not taken into account. |
Public Union “Union of Special Road Traffic Participants” |
Partially taken into account. The |
! 7 |
In paragraph 6 of section I of the draft Procedure, replace the word “variables” with the word “removable”, determine that the capacity is taken from the registration data of the vehicle. |
Public Union “Union of Special Road Traffic Participants” |
Not taken into account. Paragraph |
! 8 |
In paragraph 1 of Chapter III of the Requirements add a requirement for the availability of “Procedure for conducting special training of employees of hazardous cargo transportation entities, approved by the Resolution of the Cabinet of Ministers of Ukraine dated October 31, 2007 No. 1285.” |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 9 |
In paragraph 6 of Section VI of the Requirements, the word “complies” is replaced by the word “complies”. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 10 |
Paragraph 3 of Section VII, paragraph 2 Requirements to replace the words “if available” with “in case of exchange or retraining” or “in the presence of a previous one”. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 11 |
In paragraph 9, Section VII Requirements, replace the number 8 by 10. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 12 |
Paragraphs 4 and 5 of Section I of the Procedure do not provide for the submission of an identification code that does not make it possible to fully identify the person. Also provide an identification code in the application. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account.
|
! 13 |
In paragraph 5, subparagraph 2 of Section I of the Order, after the word “training”, add the words “(in the case of training)” |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 14 |
In paragraph 5, subparagraph 3, section I of the Procedure, the words “if available” are replaced by “in case of renewal or exchange” or “in the presence of a previous one”. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 15 |
In paragraph 6 of Section I of the Procedure, the words “as well as persons deprived of the right to drive and drive vehicles for the purpose of being temporarily limited in this right” shall be excluded and added: |
Public Union “Union of Special Road Traffic Participants” |
It is taken into account editorially. Paragraph 6 of Chapter I of the Procedure is proposed in the following version: |
! 16 |
Paragraph 13 of Section 1 of the Procedure specifies the creation of a commission. Which is impractical. To take the exams, one examiner is enough to take this exam. |
Public Union “Union of Special Road Traffic Participants” |
It is taken into account editorially. Paragraph 13 of Chapter I of the draft Procedure is proposed in the following version: |
! 17 |
Paragraph 18, section I of the Rules of Procedure. In accordance with paragraph 4 of the Resolution of the Cabinet of Ministers of Ukraine No. 1285, the tests are approved by the Ministry of Internal Affairs. |
Public Union “Union of Special Road Traffic Participants” |
It is taken into account editorially. |
! 18 |
In paragraph 4 of Chapter III of the Procedure, after the words “to it” add “and the Rules for the carriage of dangerous goods”. After the word “execution” add “theoretical and”. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 19 |
In paragraph 4 of Chapter III of the Procedure, add a paragraph: |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 20 |
In paragraph 4 of Chapter III of the Order, replace the last paragraph with the paragraph: |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 21 |
Paragraph 8 of Section III of the Procedure establishes a threshold of 60%, which is insufficient to determine the competence of the authorized person. |
Public Union “Union of Special Road Traffic Participants” |
Editorially taken into account. Paragraph 1 of |
! 22 |
Paragraph 3, subparagraph 2, section IV of the Order of the word “duplicated by letters of the Latin alphabet” shall be excluded. In paragraph 3, do the same. Such duplication is not established in other countries participating in the DPRV. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 23 |
In paragraph 3 of section IV, add a paragraph: |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 24 |
In Chapter IV of the Procedure, add the item |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 25 |
In paragraph 4 of Chapter IV of the Order, the words “and duplicated by letters of the Latin alphabet” shall be excluded. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 26 |
In paragraph 6 of Section IV of the Procedure. In Annexes A and B to the DOPNV, not in all cases, the validity of certificates is calculated from the day of the examination by the driver and the authorized person. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 27 |
In paragraph 7, Chapter IV of the Order, after the word “issued”, add “exchanged, lost and stolen” |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 28 |
In paragraph 10 of Chapter IV of the Procedure, add a paragraph: |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 29 |
In Section V of the Procedure add the item: |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 30 |
In paragraph 2 of subsection 5 of Section VI Requirements after the word “developed” add “and disclosed”. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 31 |
In paragraph 7, Chapter IV of the Requirements, the words “five working days” are replaced by “month”. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. |
! 32 |
Paragraph 17 of Chapter VII requirements to replace with: |
Public Union “Union of Special Road Traffic Participants” |
Partly taken into account. Paragraph 17 of Chapter VII of the draft Requirements is proposed to be stated in the following version: |
! 33 |
Paragraph 3 of Section I of the Requirements contradicts paragraph 13 of Section VII of the Requirements. |
Public Union “Union of Special Road Traffic Participants” |
Taken into account. Paragraph 13 of Chapter VII of the draft Requirements is proposed to be stated in the following version: “An authorized employee of the special training center shall immediately submit to the Unified State Department of the Ministry of Internal Affairs |
Based on the results of electronic consultations with the public on the draft order, it was decided to take into account, partially take into account and not take into account individual comments and suggestions of public representatives, to finalize the draft order and to publish its revised version on the official website of the Ministry of Internal Affairs and to resubmit for approval by the interested bodies.