Hazardous Materials Safety by The International Trade Association of Greater Chicago

Hazardous Materials Safety

Nathan J. Renie, Customs and Border Protection - Chicago, IL

HazMat SafetyThere are over 17 Million different chemicals in use

around the world each day.

HazMat Safety HazMat Compliance

HazMat Security

HazMat ComplianceThe transporting of Hazardous Materials

internationally requires the cooperation of hundreds of individuals and various government agencies. In the United States three government agencies have regulations which apply to HazMat: DOT, EPA, and OSHA.

HazMat ComplianceThe DOT Hazardous Materials Regulations specify

requirements for the safe transportation of hazardous materials in commerce by rail, air, sea, and motor vehicles.

HazMat ComplianceThe DOT HazMat regulations cover transportation

related activities by shippers, brokers, freight forwarders, warehouses, carriers, packaging manufacturers, and many others. These regulations apply to all aspects of the transportation of an item from packaging to its final point of delivery.

HazMat ComplianceDOT HazMat regulations are enforced by… DOT FAA Federal Highway Administration Federal Railroad Administration The Coast Guard CBP

HazMat ComplianceFederal Law provides for civil penalties up to

$25,000 for each HazMat violation. For willful violation of the laws there are stiffer penalties including imprisonment of willful violators.

HazMat ComplianceDOT HazMat regulations include

requirements for… Training Classification and

Identification Protective Packaging Hazard Communication Incident Reporting

HazMat Training

HazMat TrainingEmployee awareness will be the most important

part of your HazMat program. The more exposure your workforce has to information pertaining to HazMat the better equipped they will be to handle an issue or serious incident.

HazMat TrainingBefore any employee performs a function subject

to the DOT HazMat Regulations, that person must be provided initial training in the performance of that function.

HazMat TrainingIf a new regulation is adopted, or an existing

regulation has changed, that employee must be instructed in those new or revised requirements prior to the performance of the new function.

HazMat TrainingIf an employee has not been trained in a specific

task relating to new or revised HazMat regulations they may perform the task under the direct supervision of a properly trained individual for a period of 90 days.

HazMat TrainingEvery employee working with HazMat must receive

initial training and periodically be retrained at least every three years.

HazMat TrainingThe training should cover three specific categories: General Awareness Function Specific Training Safety Training

HazMat Training General Awareness

Should provide employees a familiarity with the HazMat Regulations. Employees should be able to recognize and assess a HazMat situation.

HazMat Training Function Specific Training

Should be applicable to the trainee’s daily work. This training could be quite brief and may be easily incorporated into OJT.

HazMat Training Safety Training

Should include emergency response procedures, protective measures, and methods of avoiding accidents.

HazMat TrainingEmployers are responsible for the proper training,

testing, and record keeping




HazMat Classification and Identification


The DOT HazMat Regulations set forth the criteria for determining the hazard class and the proper shipping name for hazardous materials.


Proper labeling or placarding is vital to public safety. The more information available to emergency responders and during an incident the better.


Hazardous Materials are broken down into nine numbered classes.


Each hazard class is generally made up of materials with similar properties and shipping requirements. This allows for identification of the basic dangers involved with the material.


1) Explosives

2) Gases

3) Flammable and Combustible Liquids


4) Flammable solids, combustible materials, and dangerous when wet materials

5) Oxidizers and organic peroxides

6) Toxic materials and infectious substances


7. Radioactive Materials

8. Corrosive Materials

9. Miscellaneous dangerous goods


More specific information about materials is provided by the placard (which may break the hazard class down further into divisions) and the display of the UN number, a four digit code which allows emergency responders to identify the chemical being shipped.


The HazMat table in 49CFR172.101 provides extensive information about the requirements for specific materials. This is the same table used by regulatory agencies when they determine compliance with the regulations.


Proper compliance with the classification and identification portion of the HazMat regulations will eliminate most violations.




HazMat Protective Packaging


The packaging required for HazMat is the first line of defense in preventing a release during transportation.


DOT HazMat regulations specify various performance levels for packaging HazMat.


The type of protective packaging used is dependent on the nature of the material to be packaged. All packaging must be designed to prevent a release during normal transportation or storage of the material.


Normal transportation of these materials can often involve significant changes in temperature and ambient pressure. The protective packaging must take this into account.


Shipments of liquids must be sealed correctly and have proper labels to indicate the correct orientation of the container.


All inner packages must be adequately secured and cushioned in order to prevent spillage or breakage during normal transport.


Substances that may react with each other may not be placed within the same packaging.


Inadequately packaged HazMat should not be transported, accepted for transportation, or offered for transportation.




HazMat Hazard Communication

The elements of hazard warning information are to be communicated through shipping documents, packaging markings and labels, placards, and written emergency response information.


Shipping Documents


Shipping documents can be in the form of a bill of lading, freight bill, hazardous waste manifest, or another shipping document.


At a MINIMUM, a properly prepared shipping paper clearly identifies HazMat by its proper shipping name, hazard class and division, UN identification number, packing group (if applicable), and total quantity.


Additional hazard warning and handling information, such as “POISON” and “CARGO AIRCRAFT ONLY” must also be entered on the shipping documents.


Package Markings


Package markings and labels convey information such as, the shipping name, UN identification number, and hazard class of HazMat.


Information on the outside of a package will allow carriers and warehouse staff to comply with proper loading and stowage protocol. This information could prevent potentially dangerous situations, such as inadvertently contaminated foodstuffs.


HazMat markings must be durable, visible, in English, and comply with proper size and color specifications.


Placards


HazMat warning placards must properly be displayed on the outside of motor vehicles, freight containers, and other bulk shipments of Hazardous Materials.


The HazMat placard gives a clear description of the contents of a large shipment of Hazardous Materials to the general public, emergency responders and others.


Emergency Response Information


Emergency response information and an emergency response telephone number must be provided by the offerer and maintained by the carrier for use in the mitigation of an accident involving HazMat.


The offerer must also provide information concerning immediate health hazards, fire or explosion risks, immediate precautions that must be undertaken in the even of a spill, first aid information, and and emergency response telephone number of an individual who is knowledgeable of incident response information for that particular material.


Material Safety Data Sheet – A list, provided by the manufacturer, which contains detailed information, including comprehensive safety information, about a single product. The information provided can vary from manufacturer to manufacturer, and from the various forms of the same chemical.


Emergency response numbers = CHEMTREC, CHEM-TEL, INFOTRAC, 3E Company, etc.

Many manufacturers will include contact information for individuals within their company in their MSDS.


The information included on the shipment and in the shipping documents is intending to inform those people working with or around the HazMat shipment of the nature of the product.


The information you provide will ensure the HazMat is safely handled, never stored with incompatible goods, and will likely be used by emergency personnel in the event of a serious incident.




HazMat Incident ReportingThe DOT & FAA HazMat Regulations require

carrier to report all incidents involving HazMat. These incident reports are maintained in a database that will allow them to identify and correct problems which occur during transportation and storage.

HazMat Incident ReportingThe proper reporting will allow the detection of

serious problems and the regulations may be amended.

HazMat Incident ReportingHazardous Materials Information Center

1-800-467-4922Mon-Fri 9AM-5PM Eastern

http://hazmat.dot.gov




HazMat ComplianceYour community depends on you to take the extra

step to protect them from danger. An estimated 85% of all HazMat incidents are the result of preventable human errors. One incident can have tremendous consequences.

HazMat Security

HazMat SecurityDOT has additional regulations which require the

development and implementation of a security plan if you offer or transport the following…

HazMat SecurityHazMat that must be placarded under federal

regulationsHazMat in a bulk package having a capacity of

greater than or equal to 3,500 gallons for liquids or gases or more than 468 cubic feet for solids

A select agent or toxin regulated by the CDC under 42 CFR Part 73

HazMat SecurityAt a minimum your security plan must address:

Personnel Security Unauthorized Access

En route Security

HazMat SecurityEmployers are responsible for training their

employees and implementing their security plan. Compliance is currently being enforced!

HazMat SecuritySuggestions for HazMat security…

HazMat Security PlanRisk Management Self-Evaluation Framework

(RMSEF)

http://hazmat.dot.gov/rmsef.htm

Based on the result of the RSEF develop your security plan to improve weak areas.

http://hazmat.dot.gov/rmsef.htm

HazMat Security PlanThe RMSEF utilizes the following steps

Scoping Knowledge of Operations

Assessment Strategy Action

Verification Evaluation

HazMat Security PlanScoping – Determining the scope of operations

that should be subject to security risk management. Identify the types of HazMat you handle and the modes of transport which are used.

HazMat Security PlanKnowledge of Operations – Review your current

security procedures and related safety programs.

HazMat Security PlanAssessment – Analyze potential security threats

and identify security control points where improvements can be made.

HazMat Security PlanStrategy – Prioritize and group security risk and

decide on preventative procedures. Create a written security plan summarizing those procedures.

HazMat Security PlanAction – Implement the plan!

Verification – Implementation of the security plan must be monitored.

Evaluation – Determine if your goals are being met and if your strategy is getting results in the field.

HazMat Security PlanOther suggestions…

HazMat Security PlanEncourage your employees to report any and all

suspicious activity.

Implement routine inspections.

Conduct regular meetings on security topics.

HazMat Security PlanEstablish a partnership with local emergency

responders.

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HazMat Security PlanUtilize technology to track shipments

GPS tracking

Cell phones

HazMat Security PlanEscorts for sensitive shipments.

Limiting the amount of stops en route.

Limiting the number of entrances at a facility.

Asking counterparts in industry.

HazMat Security PlanDOT regulations require all employees to be

trained in the company’s security plan.

HazMat Security PlanThe training should cover the following: Company Security Objectives Specific Company Security Procedures Employee responsibilities Action to take in the even of a security breach Organizational security structure

HazMat Security TrainingDOT regulations also require all employees

working with HazMat to have general security training. This may be incorporated into their initial HazMat awareness training or the company’s security plan training. Your local DOT HazMat office has free training materials available.

HazMat SecurityHazardous Materials Information Center



HazMat Security How do we inform the public and involved

personnel without giving too much information to criminals and/or terrorists?

HazMat Security Placarded shipments of HazMat do not

necessarily make a effective target for terrorists.

HazMat SecurityAs the technology develops alternatives to the

placarding regulations are on the horizon. RFID (radio frequency identification tags) GPS vehicle tracking systems Centralized Information System

HazMat SecurityAll signs point to placards as an irreplaceable

source of readily available hazard information.

HazMat SecurityDiscuss security issues with your fellow

employees.Many of the best ideas come from problems solved in the field.

YOUR security solution could be the best!

HazMat SafetyIn summary…

HazMat SafetyDOT HazMat regulations are enforced by several

agencies and cover everyone involved with the handling of the shipment.

HazMat SafetyDOT HazMat regulations include



HazMat SafetyAs well as the following

security requirements for HazMat offerors…

Security Plan Security Plan Training General Security Training

HazMat SafetyA workforce well-trained in DOT HazMat

regulations and HazMat security is your best defense against serious incidents. An investment in prevention will eliminate many potential problems and minimize the severity of accidents.

HazMat SafetyTHE END

HazMat SafetyHazardous Materials Information Center



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Hazardous Materials Safety by The International Trade Association of Greater Chicago