Some Key Takeaways from the Labelmaster Dangerous Goods Symposium 11

DGS-11

Hazmat Professionals Need to be Competent

The future standard for hazmat professionals will be competency-based training (CBT).

  • Competency is a set of behaviors built on the components of knowledge, skills, attitudes.
  • Competence is a personal ability in the context of the workplace setting.
  • Competency-based training  refers to a system whereby tasks or competencies are identified to define the content of training. Competency-Based Training may also be known as “Performance-Based Training”, “Criterion-Referenced Training”, “Mastery Learning”, or “Instructional Systems Design”.
  • The steps in competency-based training are: (1) competency identification, (2) determination of competency components and performance levels, (3) competency evaluation, and (4) overall assessment of the process.

See Introduction and Definitions (opens in .PDF) for a basic overview of CBT.

More Hazmat Shipping Changes

Hazmat shippers and carriers should be aware of recent DOT PHMSA updates.

Dr. Robert “Bob” Richard, PhD

  • Relying solely on supplier’s/shipper’s paperwork can lead to problems.
  • Train employees to recognize noncompliant inbound shipments, establish processes for correcting deficiencies, and hold suppliers/shippers accountable.
  • Customize training tailored to employee responsibilities and the products a company ships can be presented in e-learning platforms for more efficient employee training and assessments.
  • There is a Certified Dangerous Goods Professional (CDGP) credential offered by the Institute of Hazardous Materials Management (IHMM).

Dr. Bob’s DOT Audit Advice:

  • Before inspections happen—Designate staff to interact with inspectors, conduct internal compliance assessments and create a centralized file with copies of commonly requested documents.
  • During an inspection—Ask questions, take notes, invite designated employees to an exit briefing with the inspector, and read the exit briefing before you sign it.
  • After the inspection—Determine broader implications of any violations, make sure problems aren’t repeated, and document your improvements. Also, draft a response to any enforcement action.
  • Stay informed. Automated compliance processes are the best way to make inspections rarer and more manageable.

Fight Back!

“Even a dog knows the difference between being kicked and being stumbled over.” Oliver Wendell Holmes

“The US Department of Transportation doesn’t always distinguish between those who intentionally flout hazmat regulations and those who commit violations without the knowledge that they’ve done anything wrong.” Jerry Cox, Esq. and author of Transportation of Hazardous Materials 2016.

Final Thoughts . . .

Day Three of DGS11 (today) deals with  lithium battery consignments and a general Q&A session.

In a nutshell, if you’re dealing with hazmat (and who isn’t, even inadvertently?), know what you are doing, make sure your employees know what they are doing . . . and be prepared to prove it.

Thank you for reading this and much thanks to Labelmaster and all the presenters in the 11th Annual Dangerous Goods Symposium.

Managing Space = Managing Time

Montreal A40 crash

Trucker attempts to save driver before Highway 40 truck explosion.

Chain Collision

On Aug 10, 2016, Carol Bujold was in a chain collision involving several trucks on an elevated portion of Highway A-40 in Montreal. He immediately went to check on the tanker driver who stuck his truck from behind.

Bujold noticed two things: the driver was trapped inside and the truck was on fire. He got a crowbar from his truck and attempted to pull open the door, cutting his hand.

In a matter of seconds the truck was engulfed and there was nothing more Bujold could do. The tanker driver perished in the inferno. The collision is under investigation, but the incident began with a stopped vehicle in the lane.

The Key to Defensive Driving

The key to defensive driving is in managing time and space. More space gives you more time and more time gives you more space and more options. This is a fundamental rule of safe driving, no matter your age or level of experience.

Basic driving practices are such as those of the Smith System:

  • Aim High In Steering ® — Look further ahead than other drivers
  • Get The Big Picture ® — See more around you than other drivers
  • Keep Your Eyes Moving ® — Be more aware than other drivers
  • Leave Yourself An Out ® — Position better in traffic than other drivers
  • Make Sure They See You ® — Make yourself more visible than other drivers

Here is a video of the aftermath of the Montreal Highway A-40 crash that shows how quickly the vehicle was engulfed.

GRAPHIC CONTENT WARNING!

A Special Note to New Truck Drivers and Hauling Hazmat

When training new truck drivers, I am always asked if they need their hazmat endorsement?

My answer has always been the same: Get three to five years experience before hauling hazmat.

Why do I say that? For several reasons.

Note in the video above, only one person made an attempt to help the trapped driver. What if several people had fire extinguishers and attempted to aid the driver? Would it have made a difference? Would there have been a few extra seconds to help the driver?

The facts are these: In the event of a hazmat collision, it is likely that no one is obligated to help a truck driver in harm’s way. No one is going to rush in and see if they can help. It doesn’t work that way. It’s not that they don’t care . . . but there are special rules in place at the scene of a hazmat crash.

Secondly, fire and smoke are a big red flag to first responders, hazmat or no hazmat. Years ago I taught driver’s ed. We had a video that talked about “The Rule of Thumb,” when smoke or fire are present at an accident scene. The Rule of Thumb tells first responders (and everyone else) to stay back far enough to literally cover the scene of the accident with your thumb, if you see smoke or fire coming from a vehicle.

So there you have it. There is a reason hazmat is called dangerous goods. Get some experience, a lot of experience, if you decide to haul it, in my opinion.

Thanks for reading this.

 

What Are Materials of Trade?

unsecure

Materials of Trade

Sometimes in the course of our work we have to carry in our vehicles certain things like caulking, paint, solvents, etc. that are considered by the DOT to be hazardous materials.

A hazardous material is “a substance or material which has been determined by the U.S. Department of Transportation (DOT) to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce.”

Materials of Trade (MOTs) are hazardous materials (other than hazardous waste), that are carried on a motor vehicle and used in the course of a person’s daily work. MOTs might include gases for a welder, paint for a painter, fuel for a landscaper, or caulk for a carpenter. As such, the quantity of materials will be limited, but the driver will not need to have a hazmat endorsement (and a CDL license) or need to have hazmat placards on the vehicle, shipping papers, emergency response information

Note that MOTs are carried on a motor vehicle. Placement of the materials in the vehicle

One client was stopped at a roadside inspection and ticketed for having a box of caulking on the front seat of his pickup.

Top Tip: Keep MOTs out of the cab of the vehicle.

Never carry acetylene tanks in a cab or cargo van! 

And don’t just toss a cylinder in the back of a truck or have the MOTs piled loosely on a flatbed or in a cargo vehicle as a van or enclosed trailer.

Top Tip: Properly secure any and all MOTs you carry or haul.

Knowledge about MOT is important.

The regulations that apply to MOTs are found in 49 CFR Section 173.6. They include:

• general knowledge of MOTs regulations;

• quantity limitations;

• packaging requirements; and

• marking and labeling requirements.

Know the MOT quantity limits . . .

With the exception of tanks containing diluted mixtures of Class 9 materials, no more than a combined gross weight of 200 kg (440 lbs) of Materials of Trade can be transported on any one vehicle. Size limits for individual packages apply to Materials of Trade as described below: • If a hazardous material is a high-hazard material (Packing Group I), the maximum amount of material in one package is 0.5 kg (one lb) for solids, or 0.5 L (one pt) for liquids.

• If the hazardous material is a medium or lower hazard – that is, if it belongs to Packing Group II or III, other than division 4.3, or is a consumer commodity (ORM-D) – the maximum amount of material in each package is 30 kg (66 lbs) for solids, or 30 L (8 gal) for liquids.

• For Division 4.3 materials (only Packing Group II and III materials are allowed) the maximum amount of material in each package is 30 ml (one oz.)

• Each cylinder containing a gas (Division 2.1 or 2.2) may not weigh more than 100 kg (220 lbs.)

• A diluted mixture of a Class 9 material (not exceeding 2% concentration) may be transported in a tank having a capacity of up to 1500 L (400 gal.)

Hauling MOT quantities beyond these limits means the organization and driver need to meet the regulatory requirements of hauling hazardous materials.

And you don’t really want to go there if you don’t have to . . .

Thank you for reading this.

The Hazmat Quizmaster — Is That Hazmat?

hazmat testTake the Hazmat Quiz

Here’s a fun way to challenge yourself and learn a little more about hazardous materials — take the The Hazmat Quizmaster — Is That Hazmat?

Drivers and motor carriers are presented with all kinds of freight and at times have to quickly determine if what they are hauling is hazardous materials or ‘hazmat,’ also known as dangerous goods. Hazmat haulers, loaders, handlers, packagers, labelers and markers of hazardous materials have to have specific training under 49 CFR 172.700.

With high fines and penalties, no one can afford to haul a hazmat load that they are not licensed or qualified to do so. But the average non-hazmat driver is left to his own devices in determining if a shipment is hazmat or not.

Hazardous materials are products that pose a risk to health, safety, and property during transportation.

How to Identify Hazardous Materials

Look for Consumer Product Safety Commission (CPSC) labels with the following signal words:

• Caution
• Danger 
• Poison
• Warning

Look for any of these words on the label or package.

Look for Hazardous Materials Identification System (HMIS®) labeling.

HMIS®

 

 

 

 

 

 

 

 

 

 

Look for National Fire Protection Association (Health Hazard, Fire Hazard, Specific Hazard & Instability) labels.

NFPA

 

 

 

 

 

 

 

 

 

 

 

Look for a UN number, an Identification Number on the DOT Hazardous Materials Table. UN numbers range from UN0001 to about UN3518.

Look for any kind of “hazard” label, that can be an indication it is a hazardous material.

Tip: DOT guidelines for properly labeling and marking non-bulk and bulk containers are similar, but they are not the same.

Check the Hazardous Materials Table (49 CFR 172.101)

The Hazardous Materials Table identifies and classifies hazardous materials.

A DOT Hazardous Material? Yes— if listed in the DOT Hazardous Materials Table (Over 5,500 pages long)

Hazardous Materials Table . . .
Columns 1 – 5: identify and classify the material on the shipping papers.

Columns 6 – 10: proper packaging, labeling, marking, placarding and mode-specific requirements. The modes of transportation are air, water, rail and highway.

Top Tip: If you believe that you might have a hazardous material, you need to check the above indicators and seek more information before you accept it for shipment.

So how did you do on the hazmat quiz? While that one was for fun, the real quiz happens everyday when you might be presented with goods, materials or freight that could be considered hazardous materials by the DOT.

Summary

When presented with freight that could be potentially classified as hazardous materials, carefully examine the container for labels that contain signal words, special formatting showing NFPA or HMIS® labeling, UN numbers, hazard labels, or if the materials or product is listed on the Hazardous Materials Table (49 CFR 172.101). Never knowingly accept hazmat freight that is mislabeled, missing proper shipment papers, mispackaged, leaking, or for which you are not properly licensed, trained, or other qualified to handle, convey, or otherwise transport.

Thank you for reading this.

Dangerous Goods Symposium (DGS XI) – Free Registration Until April 15th

 Dangerous Goods SymposiumLablemaster

Founded in 1967, Lablemaster is a privately held company based in Chicago, IL that offers software, products, and services for compliance with all dangerous goods regulations.

‘Dangerous goods’ are materials or items with hazardous properties, also known as hazardous materials or hazmat.

DGS XI

Every year for the past decade, Labelmaster has sponsored a Dangerous Goods Symposium for instructors and professionals involved in the shipping of Dangerous Goods.

The 11th annual Dangerous Goods Symposium (DGS XI) will be held September 7th – 9th at the new Loews Chicago Hotel on 455 North Park Drive. Normally running around $300 a night, mention Code ALC906 to secure the group rate of $199/night, if you stay at Loews.

This Dangerous Goods Symposium is for anyone involved in the training, transporting or handling of Dangerous Goods/Hazardous Materials.

Registration  for the 11th annual Dangerous Goods Symposium is free until April 15th.  Topics will cover topics as Dangerous Goods 101, to training best-practices to the latest lithium battery regulations, as well as updates in the ever moving world of Dangerous Goods/Hazardous Materials.

Register here: DG Symposium Registration.

Each person attending needs to register separately.

If you are involved in involved in the training, transporting, or handling of Dangerous Goods/Hazardous Materials, want to learn more or want to build your industry network, then don’t miss the the 11th annual Dangerous Goods Symposium.

Follow Labelmaster on LinkedIn, Twitter, G+, YouTube, or their blog.

Thank you for reading this.

 

 

 

 

Hazardous Materials vrs. Dangerous Goods

danger

Many times in transportation we hear the terms hazardous materials and dangerous goods. In hauling goods we should know what these terms really mean.

What are hazardous materials?

Hazardous materials is a term used by the U.S. Department of Transportation (DOT). Hazardous materials (sometimes called hazmat, for short) means a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under Section 5103 of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous Materials Table (see CFR 172.101), and materials that meet the defining criteria for hazard classes and divisions in Part 173 of Subchapter C of this chapter.

What are dangerous goods?

“Dangerous Goods” is an international term used by aviation organizations: International Civil Aviation Organization (ICAO) and International Air Transport Association (IATA).

IATA defines dangerous goods as articles or substances which are capable of posing a risk to health, safety, property or the environment and which are shown in the list of dangerous goods in these regulations or which are classified according to the Regulations.

A Hazmat Employee is an individual who “directly” affects hazardous material transportation safety. Examples of hazmat employees include:

  • Individuals who prepare hazmat shipments (including classifying, packaging, marking, labeling, and documenting)
  • Individuals arranging hazardous materials shipments that are prepared by contractors
  • Medical Personnel
  • Radiation Safety Officers
  • Material handlers who load and unload hazardous materials
  • Truck drivers
  • Individual filling containers
  • Packers
  • Documentation clerks
  • Engineers or technicians that use FedEx or other carriers from field locations
  • Field engineers
  • Administrative assistants assisting with paper work
  • Individuals that design, fabricate, recondition, or test certified packaging

Driver Requirements

Drivers need a Group A or B CDL with a hazardous materials endorsement to haul hazardous materials in amounts requiring placarding. If the vehicle is small, a Group C CDL is required.

“H” — HAZARDOUS MATERIALS: To carry hazardous materials in amounts requiring placarding (includes small trucks, pickup trucks and passenger vehicles)

“X” — An X Endorsement will appear on the license instead of the H and N codes when an applicant receives both the tanker and hazardous materials’ endorsements.

Training: Periodic hazmat training is required for all hazmat employees, including drivers. (49 CFR §177.800 (c) Responsibility for training. A carrier may not transport a hazardous material by motor vehicle unless each of its hazmat employees involved in that transportation is trained as required by this part and subpart H of part 172 of this subchapter.)

Training Elements

  • General Awareness
  • Function Specific
  • Safety Training
  • Security Training (General Awareness and/or In-Depth depending on the type and quantity of materials shipped)

When is training required?

  • By DOT regulations, after a change in job function, after a regulation change and every three years. (Employees may perform functions for up to 90 days if under direct supervision of a trained employee)
  • By ICAO/IATA requirements, training is required before performing a regulated job function and every two years.
  • Under 49 CFR §177.816 (c) The training required by paragraphs (a) and (b) of this section (specific driver’s requirements) may be satisfied by compliance with the current requirements for a Commercial Driver’s License (CDL) with a tank vehicle or hazardous materials endorsement.

For any placardable amount of hazardous materials, intrastate or interstate, the shipper or transporter must register with the U.S. DOT/RSPA. Registration information can be obtained by calling 202-366-4109. States may have additional requirements, depending on the nature of what is being hauled.

Shipping Paper” is a document used to identify hazardous materials during transport. With few exceptions (see Material of Trade), shipping papers must accompany all shipments, even if the materials are for your own use.

Know that certain routes may be restricted or prohibited to shipments of flammable liquids or explosive materials or other types of hazmat. Michigan law (Section 257.669) requires any vehicle that is marked or placarded to stop prior to crossing a railroad grade.

Any handler of hazardous materials knows how complex regulations for hazmat shipments can be. Protect yourself by knowing the restrictions and regulations for shipping or hauling hazmat or dangerous goods.

un3065

 

Labelmaster put together an infographic of 2015 regulatory changes here.

 

 

Thank you for reading this.

 

Just The FAQs

Just the facts . . .

Just the Facts . . .

The U.S. DOT is very concerned about bridge strikes (topping a trailer, van box or load) and use (or  improper use) of Global Positioning Systems (GPS). At least these topics are the first things listed under “Carrier & Vehicle Safety” on the DOT’s Federal Motor Carrier Safety Administration (FMCSA) FAQs page.

“The Agency views bridge strikes as a serious safety hazard resulting in injury and loss of life, damage to infrastructure, interruption of commerce, and delays in travel times.”

Their solution: drivers need to increase awareness of route selection by paying attention to signs and using only proper GPS systems, designed for trucks and buses. And by the way, The DOT reminds us that the maximum penalty for failing to comply with a posted route restriction, such as a sign along a roadway, is $11,000 for a company and/or $2,750 for a driver, and, of course, a bad CSA score.

But they are doing their part, too:

  • The FMCSA will work with its State and local partners to ensure they understand their enforcement authority against motor carriers and drivers that fail to abide by roadway signs.

They have a GPS brochure for drivers (opens in .pdf file).

The DOT admits it does not know if topping a trailer or load on a bridge or overpass due to improper GPS is really a problem.

FMCSA’s information systems do not have crash statistics associated with the use of electronic navigation systems. However, even one truck or bus striking an overpass is one too many . . .

The DOT’s FMCSA FAQs page looks like this:

faqs

Thank you for reading this.

 

Understanding Hazardous Materials Registration

inspector, investigator

Are you required to register with the DOT as a hazmat shipper, or carrier?

Is your company an “offeror and/or transporter” of certain quantities and types of hazardous materials?

Any business (intrastate or interstate) shipping hazardous materials requiring a U.S. DOT placard must register each year and pay the registration fee. The fees for year 2015-2016 are $250 (plus a $25 processing fee for each registration form submitted) for small businesses and non-profit organizations, and $2,575 (plus a $25 processing fee for each registration form submitted) for all others. PHMSA allows one, two and three year registrations.

The current hazardous materials certificate (here is an example for FedEx) needs to be kept in the cab of each HAZMAT vehicle at all times. If you are subject to a roadside inspection or DOT audit and do not have a current certificate, then your authority to operate will be revoked and your company could be fined up to $32,500 per each day of violation.

Register your company here.

Check your company registration if it’s current here.

Click here for more hazmat registration information.

June 30, 2015 was the registration deadline for all new and expiring hazardous materials registration certificates.

Quick Tip: Dealing with hazardous spills

fuel2

The Hazard

Dripping fuel or other vehicle fluids can present a hazard to other motorists and could result in liability for the spill. More than half of spills or leaks involve the diesel fuel from either a puncture in the truck’s fuel tank or a leak in the fuel crossover lines.

A Quick Solution

One quick and effective way to contain leaks is by putting an inflatable kiddie pool under the leaking truck. This will keep the leak from spreading or soaking into the ground or roadway.

Check the label to determine the area of the pool itself. Sizes can range from 37 inches for a small pool, up to over 80 inches. An inflatable kiddie pool will not take up much storage space in a truck.