USDOT/FMCSA HM UPDATE. David W. Ford USDOT/FMCSA
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1 USDOT/FMCSA HM UPDATE David W. Ford USDOT/FMCSA
2 Unified Registration System (URS) On November 1, 2013: Motor Carriers, HMSP Holders, IEPs new enforcement provisions for failing to file biennial updates according to the schedule in 49 CFR (b)(2), and a prohibition on operating with an inactive USDOT Number in 49 CFR 392.9b(a). On October 23, 2015: All Other FMCSA-Regulated Entities the Agency will require all entities registering or providing information to the Agency to do so through the URS electronic online registration process.
3 CSA Got Data? Regardless of your feelings towards CSA, it has: Motor carriers monitoring their data more closely Enforcement verifying their violations are accurate
4 HM BASIC What motor carriers receive a percentile in the HM Compliance BASIC? A motor carrier is assessed when they have 5 or more relevant inspections (Levels 1, 2, 5, or 6) where placardable quantities of HM were being transported. What is the intervention threshold for the HM Compliance BASIC? 80% for all carriers. Carriers will be prioritized for an HM Compliance BASIC investigation if this threshold is exceeded or if a serious violation is discovered in the BASIC. BASIC Passenger Carriers HM Carriers All Other Unsafe Driving, HOS Compliance, Crash Indicator Driver Fitness, Controlled Substances/Alcohol, Vehicle Maintenance HM Compliance
5 Driver Behavior Texting/cell phone Railroad Crossing Safety General Traffic Laws Weather-Related Loading/Unloading Delivery Hose securement
6 HM Training, / Every THREE years: General Awareness Function-Specific Safety Security Awareness In Depth Security (Your Security Plan) Cargo Tank Driver Employer must certify they trained and tested their employees
7 Cargo Tank Rollover Prevention FMCSA Web Site includes links to: Cargo Tank Rollover Prevention Video ATRI Rollover Hotspot Map Tank Truck Safety News Cargo Tank Rollover Stability Study Cargo Tank Rollover Training (b) Must meet requirements of documentation and be done once every 3 years.
8 Security Plans, Must include all DOT components Site-Specific Risk Assessment, Enroute Security, Personnel Security, Unauthorized Access, Training Plan, Senior Management Official Annual Review
9 Do you have your: CT Carrier Compliance Issues manufacturer certificates? ASME U-1A forms? Repair records (R-1 forms)? Emergency Discharge Control certification? Test/Inspection Reports?
10 Shipping Papers Correct sequence? Valid ER TX#? ER Information?
11 Shipping Paper Retention Motor Carrier 1 year HM Shipper 2 years HM Shipper and Motor Carrier 2 years Includes private motor carriers
12 Marking and Placarding On the Cargo Tank, all four sides: UN # Propane Correct Placard Non-Odorized, two opposite sides
13 Marking and Placarding QT/NQT Marking, near spec plate Emergency Shut Off Marking Liquid/Vapor lines Marking
14
15 (n) Which cargo tanks need what type of device (l) -- Operating Procedures Emergency Discharge Control (s) --When the driver must have the off truck remote on his person. Does your remote system work? Fresh batteries? Antenna in a location that works from all directions?
16 Emergency Discharge Control Hoses permanently marked Post-delivery hose inspection Monthly hose and piping inspection and report Monthly EDC actuation and report Monthly internal valve check and report (meter creep test) Annual hose leakage test report New/repaired hose pressure test Smart Hoses MUST be on unit, even if using facility hoses!
17 Emergency Discharge Control Not all CT Facilities are performing the annual leakage test on the hose during the leakage test on the cargo tank! All records (monthly hose inspection, annual leakage test, etc.), must include the information required by Section
18 5% or Less Rule (j)(1) Permanent installation on consumer premises, oneway only by private carrier ASME Code Tank, and so marked Safety devices meeting NFPA 58 Tanks must be secured against movement Valves and fittings must be protected
19 Yes, you actually have to secure it A fireman from the Quincy Volunteer Fire Department cautiously approaches a downed propane tank after it fell off the back of a truck on Highway 70 in East Quincy, CA
20 Over 5% Rule (j)(2) No more than 500 gallon capacity Permanent installation on consumer premises, one-way only by private carrier ASME Code Tank, and so marked Inspection prior to loading trained/qualified person, inspection report (date, signature, phone #, tank serial#, water capacity, origin/destination, estimate of propane), retain for 2 years, signature = certification of no defects
21 Over 5% Rule (j)(2) One storage tank per vehicle Lifted by slings, lifting lugs prohibited Tank must be completely within trailer/truck No weight on supporting legs (e.g., cradle) Tank must be secured against movement Trailers must have rear end protection (j)(3) storage containers less than 125 gallons capacity may be transported with LPG in compliance with DOT filling density.
22
23
24 How good is your CT Inspection Program?
25 What we have here is a failure to communicate. Does your RI meet the qualifications in 171.8? Is your RI in compliance with the training requirements? Do they properly perform the bench test on PRDs during the pressure test? Or did they really replace it? Do they remove the upper coupler on transports during the pressure test? How much pressure are they putting to YOUR cargo tank?
26 Does he/she have the right equipment?
27 Does he/she know the regulations? Even if an RI inspects and tests your CT, you are still responsible for violations!
28 When does a bobtail need overturn protection?
29 What qualifies as overturn protection?
30 When is a DCE required? R Stamp?
31 Rear End Protection Device Must be DCE certified to withstand 2Gs of force INCLUDES Remounted CTMVs!
32 CT Facility Compliance Issues Training, Training, Training I ain t never had no schoolin on tanks But I ve been doing this for 30 years.. RI Qualifications No Diploma/GED Lack of 3 years of experience
33 CT Facility Compliance Issues Improper Test Procedures PRD Bench Testing Blocking off PRDs during the pressure test Don t know the procedure, open/reset thresholds Don t have the equipment Over-pressurizing the CT -- no more than 1 ½ times the MAWP Using nitrogen over propane during the pressure test Conducting several pressure tests in a single day
34 Wet Florescent Magnetic Particle Exam Applies to all QT CTs (usually transports); and NH3 NQT CTs without post weld heat treatment Must be Registered as a CT Facility Must meet ASME Code requirements Written Qualifications, such as eye exams Documented Training Written Procedures Calibrated Equipment
35 CT Facility Compliance You need to be familiar with the test/inspection procedures that are used on your cargo tanks. It s YOUR tank! Remember, the HM Regulations place the responsibility of compliance with the specification and testing requirements on the cargo tank owner, not the CT facility.
36 Always check your cargo tanks after they are inspected, something might have been overlooked.
37 Since January 2013, there have been 8 fatalities and 38 injuries in cargo tank facility incidents, including a father/son team. At least 1 facility was burned to the ground. This is what can happen when you utilize the wrong cargo tank facility!
38 Test Markings V External Visual K Leakage P Pressure I Internal L Lining T- Thickness 38
39 Test Markings
40 Propane with H2S
41 Propane and NH3
42 Be careful out there! David W. Ford HM Program Manager Southern Service Center USDOT/FMCSA
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