Federal Transportation Officer Training Program: Basic ... · Federal Transportation Officer Training Program: Basic (Level 1) Freight, Cargo, ... Knowledge Review ... Transportation

Basic (Level 1) Session 6: Hazardous Materials Transportation

Federal Transportation Officer Training Program: Basic (Level 1)

Freight, Cargo, and Household Goods

Session 6: Hazardous Materials Transportation

Basic

http://transbasic.knowledgeportal.us/session6

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What You Will Learn

The movement of hazardous materials (HAZMAT) is extremely regulated, as it affects public safety and the environment in several ways. It is also highly technical, and federal, state, and local guidance may apply. International movement of HAZMAT is governed by international standards and rules, and country-specific requirements. Finally, the movement of HAZMAT may have unique mode-specific requirements for packaging, marking, co-mingling of cargo, and quantity limitations.

This session will introduce you to federal and international bodies having responsibility to regulate the movement of HAZMAT, how HAZMAT is classified, and requirements for responding to and reporting HAZMAT emergencies, incidents, and accidents.

Basic

http://transbasic.knowledgeportal.us/session6/p1/

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Session 6 Outline

What Is HAZMAT and Why Is ItImportant?

What Organizations andRegulations Guide theMovement of HAZMAT?

What Should a FederalTransportation Officer Know?

What Is Required in the Eventof an Incident or Accident?

Glossary of Terms

Knowledge Review

Where to Go for More Information

Basic


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What Is HAZMAT and Why Is It Important?

CFR §102-117.25 defines HAZMAT as:

"Hazardous material (HAZMAT) is a substance or material the Secretary of Transportation determines to be an unreasonable risk to health, safety, and property when transported in commerce, and labels as hazardous under section 5103 of the Federal Hazardous Materials Transportation Law (49 U.S.C. 5103 et seq.). When transported internationally hazardous material may be classified as "Dangerous Goods." All such freight must be marked in accordance with applicable regulations and the carrier must be notified in advance."

By its nature or properties, HAZMAT can expose conveyance operators, handlers, the general public, or the environment to risks. When being transported, the type and attributes of the material may also effect the operation of the conveyance itself (hazard to navigation, fire risk), increasing the risk for harm in an incident or accident.

Furthermore, violation of HAZMAT regulations can result in serious penalties.

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How is HAZMAT classified?

International Maritime Organization (IMO), a branch of the United Nations (UN), classifies dangerous goods into 9 hazard classes.

U.S. Department of Transportation (DOT) and other international organizations also use these classification groups as the basis for further refining guidance for packaging, marking, shipping, and storing HAZMAT.

Class Description

Class 1 Explosives

Class 2 Gases

Class 3 Flammable Liquids

Class 4 Flammable solids; substances liable to spontaneous combustion; substances which, in contact with water, emit flammable gases

Class 5 Oxidizing substances and organic peroxides

Class 6 Toxic and infectious substances

Class 7 Radioactive material

Class 8 Corrosives

Class 9 Miscellaneous dangerous goods

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What Organizations and Regulations Guide the Movement of HAZMAT?

Multiple federal agencies have policy and enforcement responsibilities related to the movement of HAZMAT. These include:

U.S. Department ofTransportation (DOT)

Pipeline and Hazardous Materials Safety Administration (PHMSA)

Federal Motor Carrier Safety Administration (FMCSA)

Federal Aviation Administration (FAA)

Federal Railway Administration (FRA)

U.S. Coast Guard (USCG)

National Transportation Safety Board (NTSB)

Environmental Protection Agency (EPA).

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What Organizations and Regulations Guide the Movement of HAZMAT? (continued)

PHMSA issues and enforces the HMR, issues special permits, maintains incident reports, issues administrative determinations, and represents the U.S. DOT in international organizations related to HAZMAT.

FMCSA issues regulations concerning highway routing of HAZMAT, licensing and permit requirements, and financial requirements for motor carriers transporting HAZMAT. It enforces the Federal Motor Carrier Safety Regulations (49 CFR 350-399).

FAA enforces all regulations applicable to the transportation of HAZMAT by air under the Federal Aviation Act (49 USC Section 40101 et seq.).

FRA regulates the transportation of HAZMAT by rail, and enforces safety regulations issued under the Federal Rail Safety Act. Regulations include CFR 49 200-268.

USCG regulates the bulk transportation of hazardous materials loaded or carried on board a vessel without benefit of containers or label under the HMR, and enforces regulations related to water pollution and oil spills.

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What Organizations and Regulations Guide the Movement of HAZMAT? (continued)

National Transportation Safety Board (NTSB) is a federal agency charged by Congress with determining the probable cause of transportation accidents—including hazardous materials accidents or incidents. DOT's PHMSA is required by law to respond to Safety Recommendationsissued by the NTSB.

EPA issues regulations regarding environmental protection, including regulations for the classification, management, and transport of hazardous wastes. 40 CFR Parts 260-282 covers all of the Resource Conservation and Recovery Act (RCRA) regulations. Part 263 is Standards Applicable to Transporters of Hazardous Waste. If your agency generates and moves hazardous waste, you need to be familiar with these standards.

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What are the Hazardous Materials Regulations?

Collectively, the HMRs consist of various parts of CFR 49 which cover specific subject areas.

Subject Area Part

HAZMAT classification CFR 49, Parts 171,173

HAZMAT communication CFR 49, Part 172

Packaging requirements CFR 49, Parts 173,178,179,180

Operational rules CFR 49, Parts 171,173,174,175,176,177

Training and security CFR 49, Part 172 (subparts H & I)

Registration CFR 49, Part 171

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What Are The Major International Organizations That Deal With Hazardous Material?

There are many international organizations that provide hazardous material standards and guidelines for the transportation in general and for specific modes of transportation. Depending on where, what, and how you are shipping, these organizations may be good sources of information.

International Maritime Organization (IMO) Maritime Safety Committee publishesthe Maritime Dangerous Goods (IMDG) Code , providing for the safe transport ofdangerous cargoes and related activities in port areas.

International Civil Aviation Organization (ICAO) is a specialized agency of the UNthat sets standards and regulations for aviation safety, security, andenvironmental protection through the use of Technical Instructions.

International Air Transportation Association (IATA) is a trade group comprised ofair carriers and airlines that publishes the Dangerous Goods Regulations (DGR) ,available for purchase. ICAO and IATA closely follow each other, but variationsmay be seen between nations and air carrier participants.

United Nations Subcommittee of Experts on the Transport of Dangerous Goodsand on the Globally Harmonized System of Classification and Labeling ofChemicals issues the United Nations (UN) Recommendations on the Transport ofDangerous Goods. These recommendations are not binding, but form the basis forseveral international agreements and national laws.

International Atomic Energy Agency publishes the Safety Standard Seriespublications for movement of radioactive material and waste.

Basic


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What Should a Federal Transportation Officer Know?

The single most important thing to know is if your agency is shipping any freight or cargo that could be considered HAZMAT. This could be as simple as a device with a lithium battery within it.

For each shipment, the TO or transportation specialist must be cognizant of:

Shipment contents andquantities

Identification and classification of any HAZMAT

Quantities of HAZMAT involved

Compatibility of various HAZMAT items shipped together (can items be co-mingled, and in what amounts?), and

Packaging, marking, documentation, and permit requirements.

U.S. DOT HAZMAT Info Center can be contacted at 1-800-467-4922 Monday–

Friday, 9 AM to 5 PM Eastern Standard Time.

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Federal Hazardous Materials Transportation Law

As a TO, you also need to have knowledge of the Federal Hazardous Materials Transportation Law (49 USC Subtitle III, Chapter 51 Transportation of HAZMAT). Sections are shown below.

Sec. 5101. Purpose Sec. 5113. Unsatisfactory safety rating

Sec. 5102. Definitions Sec. 5114. Air transportation of ionizing radiation material

Sec. 5103. General regulatory authority Sec. 5115. Training curriculum for the public sector

Sec. 5103a Limitation on issuance of HAZMAT licenses

Sec. 5116. Planning and training grants, monitoring, and review

Sec. 5104. Representation and tampering Sec. 5117. Special permits and exclusions

Sec. 5105. Transporting certain highly radioactive material

Sec. 5119. Uniform forms and procedures

Sec. 5120. International uniformity of standards and requirements

Sec. 5106. Handling criteria Sec. 5121. Administrative

Sec. 5107. HAZMAT employee training requirements and grants

Sec. 5122. Enforcement

Sec. 5123. Civil penalty

Sec. 5108. Registration Sec. 5124. Criminal penalty

Sec. 5109. Motor carrier safety permits Sec. 5125. Preemption

Sec. 5110. Shipping papers and disclosure Sec. 5126. Relationship to other laws

Sec. 5111. Rail tank cars. [Repealed. Pub.L. 109-59, Title VII, § 7111, Aug. 10, 2005, 119 Stat. 1899]

Sec. 5127. Judicial review

Sec. 5112. Highway routing of hazardous material

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How do I Plan a Hazardous Shipment Move?

Hazardous shipments follow the same 5 steps as domestic shipments, but contain some additional considerations in Steps 1, 4, and 5.

Step Details

1. Identify Cargo Details The cargo type, quantity, and volume may determine some initial packaging and marking requirements, as well as special handling requirements. Determine if the shipment contains HAZMAT.

2. Determine Shipment Origin andDestination

You may not always be shipping from your physical location, and either origin or destination locations may have specific delivery requirements, such as special security procedures to be followed.

3. Identify Delivery Date Some shipments may have required delivery dates due to the urgency of the cargo, while others may have some latitude in delivery timeframe.

4. Evaluate and Select Mode(s) Taking into consideration the type and quantity of cargo, the origin and destination locations, and the delivery date needed, different modes will make sense. In many cases, more than one mode may be needed along the way from origin to destination. Determine if and how HAZMAT affects your mode decision.

5. Evaluate Carriers and AwardShipment

For each mode, evaluate carrier options, and select best-value carrier, based on your priorities and definition of best-value. Ensure your potential carriers have all necessary authorities and permits to move your HAZMAT.

Basic


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What's an Example of Hazardous Materials Movement?

You have been given 2 pallets of lithium batteries to ship from Boston, MA to Austin, TX. The consignee is expecting the cargo sometime within the next week.

Basic


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Step 1: Identify Cargo Details

Questions to Ask ... For the Example ...

What is being shipped? 2 pallets of lithium batteries.

Are the pallets standard dimensions (40" x 48")? The pallets are standard.

What are the pallet weights? The pallets each weigh 200 pounds so they can be handled with a regular forklift or pallet jack equipment.

Is the cargo adequately packed or will other protective wrap be necessary?

Yes in packaging from the manufacturer.

What questions to ask about the commodity if it contains hazardous materials?

What information is provided by the manufacturer of the batteries for transportation? You may need to check with the Department of Transportation, Pipeline and Hazardous Materials Safety Administration.

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Step 1: What if The Example Were Different?

If the Cargo Were… Then…

Aerosol cans? Each will be classified accordingly. The TO must research the requirements associated with each anticipated mode to determine the limitations and requirements involved. Medical vaccines?

Radiological imaging equipment with radioactive material?

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Step 2: Determine Shipment Origin and Destination


What is the origin address? The origin is a Boston, MA distribution facility on the Port of Boston property.

What is the destination address? The destination is a warehouse in Austin, TX.

What are the material handling capabilities at the sites?

Both sites have standard loading and receiving dock configurations and forklifts.

What are the access requirements at the sites? The Port of Boston requires an appointment prior to arrival.

What hazardous materials requirements do the origin and destination have?

Inquiries should be made at both the origin and destination point facility managers for protocol on shipping out and receiving in hazardous materials.

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Step 2: What if the example were different?

If the Origin/Destination Were…

Then…

An office building? The building may not have a commercial loading dock or equipment to handle pallets. This may require loading the pallets to a different-size truck for better access, and extra time for material transfer.

A secure facility? The driver may be required to provide proof of citizenship, or some other identification, or be pre-cleared.

Only open part-time? The delivery needs to be scheduled to arrive when the facility is open.

Basic

http://transbasic.knowledgeportal.us/session6/p16b/

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Step 3: Identify Delivery Date


Is there a no-later-than delivery date? The shipment has no firm delivery date required, just sometime next week.

What is the risk and impact of a late delivery? The cargo is replenishment for warehouse stock, as opposed to delivery to a customer for immediate use.

Is transportation cost a primary or secondary consideration?

Transportation costs should be kept at a minimum. If additional costs are required as a direct result of transporting hazardous materials, it is recommended to identify these costs for informed decision making.

Basic

http://transbasic.knowledgeportal.us/session6/p16a/

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Step 3: What if the example were different?

If… Then…

The cargo had a definite delivery date?

Potential modes of transport may be limited to only those that can arrive by the delivery date.

Making delivery was more important than the cost incurred?

The best mode will be the mode that guarantees on-time delivery.

Transportation cost was a concern?

Determine if the identified delivery date must be met, and provide alternate options for delivery that save money.

Required delivery date was over a week away?

An intermodal transportation mode may be a solution. While intermodal moves tend to be less expensive, this mode may take a longer delivery time.

Basic

http://transbasic.knowledgeportal.us/session6/copy_of_p12/

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Step 4: Evaluate and Select Mode(s)


What modes can meet the delivery date? Air, truckload and less-than-truckload (LTL) can likely make the delivery date. Air may be expensive and delivery is not urgent.

Do any modes prohibit the transport of the cargo in question?

Determine if and how HAZMAT affects the mode decision. All modes can handle HAZMAT.

Does the weight or dimensions of the cargo make any modes uneconomical?

The pallets and weights are standard and easily handled by an LTL carrier.

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Step 4: What If The Example Were Different?

If… Then…

The commodity was not authorized for air movement

The TO would be required to consider a surface mode and type of service for shipment of the material.

The commodity was authorized, but the quantity was too large for a single shipment

The TO would have to consider repackaging the material into split shipments in order to comply with shipping requirements. This could add cost and delivery time.

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Step 5: Evaluate Carriers and Award Shipment


What mode(s) have we narrowed the options to? The shipment is best fit with LTL, however you must ensure your potential carrier(s) have all the necessary authorities and permits to move your HAZMAT. In the example, it is lithium batteries.

Do established agency rates or tenders exist? The origin and destination combination has been used before and multiple tenders are on file.

If multiple modes, do you want someone else to manage the multiple bills of lading?

Select the best value LTL transportation service provider (TSP) that meets the delivery and HAZMAT requirements.

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Step 5: What If The Example Were Different?

If… Then…

There are limited options for selection of carriers; i.e., for movement of arms, ammunition, andexplosives

The TO choices will be limited to the available market, and the shipper may have to pay significantly higher rates during periods of increased competition for services.

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How Do You Verify a TSP’s Ability to Move HAZMAT?

When you are making arrangements with the Transportation Service Provider (TSP) to transport hazardous materials, make sure that the TSP is certified by the DOT to transport that particular hazardous material by checking the DOT permit search register.

Basic


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What About Packaging and Marking of HAZMAT?

Each of the regulating bodies, domestic and international, publishes specific guidance for how each HAZMAT commodity must be prepared for shipment to ensure public safety.

Package—and conveyance—marking is necessary to alert handlers and public safety officials of the contents if an incident occurs. This information, along with bill of lading (BOL) or manifest documentation allows research into the properties, risks, and safeguards needed for the material. This information is also documented on Material Safety Data Sheets (MSDS), produced by the manufacturer of the item or material. For some shipments, an MSDS for each HAZMAT commodity must accompany the shipment.

Basic


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Where is this guidance found?

Packages/containers and the transportation mode that contain hazardous or dangerous goods must be marked with the correct technical name and distinctive labels or stencils. Guidance is found in 49 CFR Part 172:

Subpart D–Marking

Subpart E–Labeling

Subpart F–Placarding

Federal regulations incorporate UN Performance Oriented Packaging global standards for all continental United States (CONUS) and outside CONUS (OCONUS) HAZMAT shipments.

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What documentation is required?

Freight shipments contents must be described on bills of lading in a uniform and consistent manner that is recognizable and acceptable to all TSPs.

The proper description of shipments is essential for determining applicable freight rates, proper handling while in transit, safety procedures, and processing freight claims for loss or damage.

You may also be required to file an EPA Hazardous Waste Manifest to track hazardous waste from a generator's site to the site of its disposal.

Your shipment may require a special permit or approval prior to transporting the hazardous materials. You should verify PHMSA requirements prior to shipping. Check state laws to ensure proper documentation is met. In addition, check with your agency for any specific policy or regulations for hazardous materials transportation.

Basic


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What Is Required in the Event of an Incident or Accident?

49 CFR provides requirements for notifying authorities of emergency situations at the time of the incident and documentation of the incident after the fact.

49 CFR 171.15 specifies the incident notification process:

"As soon as practical but no later than 12 hours after the occurrence of any incident described in paragraph (b) of this section, each person in physical possession of the hazardous material must provide notice by telephone to the National Response Center (NRC) on 800–424–8802 (toll free) or 202–267–2675 (toll call) or online at http://www.nrc.uscg.mil."

49 CFR 171.16 outlines the required written reporting procedures.

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Where can I go for guidance in a hazardous materials emergency/incident?

PHMSA website provides incident reportinginformation. Guidance ranges from how to initially report HAZMAT incidents or accidents to the directions for completing the required DOT Incident Report Form 5800.1.

Basic


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Glossary of Terms

Shipper's certification: Each person who offers a hazardous material for transportation shall certify that the material is offered for transportation in accordance with applicable regulations of the Department of Transportation.

Material Safety Data Sheet (MSDS): A formal document prepared by manufacturers and importers of HAZMAT containing important information about the characteristics and actual or potential hazards of a substance. It identifies the manufacturer of the material (with name, address, phone, and fax number) and usually includes (1) chemical identity; (2) hazardous ingredients; (3) physical and chemical properties; (4) fire and explosion data; (5) reactivity data; (6) health hazards data; (7) exposure limits data; (8) precautions for safe storage and handling; (9) need for protective gear; and (10) spill control, cleanup, and disposal procedures. Mandated by the U.S. Occupational Safety and Health Administration (OSHA), it is used also in many other countries in one form or the other. It is called a chemical safety data sheet (CSDS) in Europe.

Hazardous Waste Manifest: A specific shipping document required by the U.S. DOT and the EPA for hazardous waste shipments. Also referred to as the Uniform Hazardous Waste Manifest (UHWM). If all DOT requirements (i.e., the basic description to include proper shipping name, hazard class/division, ID No., and packing group) are entered on the UHWM, the manifest may be used as a shipping paper (49 CFR § 172.205).

Basic


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Knowledge Review

Which three of the following are examples of hazard classes?

GasesWaterRadioactive materialRailPipelineCorrosives

Answer: Gases, Radioactive material, and Corrosives

Yes, that's correct. The other 6 classes are explosives, flammable liquids, flammable solids, toxic and infectious substances, oxidizing substances and organic peroxides, and miscellaneous dangerous goods.

Incorrect: Sorry, that's not correct. The other 6 classes are explosives, flammable liquids, flammable solids, toxic and infectious substances, oxidizing substances and organic peroxides, and miscellaneous dangerous goods.

Basic

http://transbasic.knowledgeportal.us/session6/KCans

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Where to Go for More Information

In addition to the sites identified in this session, you can find more information from the following:

U.S. Department ofTransportation, Pipeline andHazardous Materials SafetyAdministration

U.S. Department of Transportation, Federal Aviation Administration Officeof Security and Hazardous Materials

U.S. Department of Transportation, Federal Motor Carrier SafetyAdministration Hazardous Materials

U.S. Environmental Protection Agency, Office of Resource Conservation andRecovery

Basic


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Documents

Federal Transportation Officer Training Program: Basic ... · Federal Transportation Officer Training Program: Basic (Level 1) Freight, Cargo, ... Knowledge Review ... Transportation