HazMat Transportation Compliance. September 2017
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1 HazMat Transportation Compliance September 2017
2 My HazMat Journey Biology Environmental Studies Freshwater Sciences
3 Labelmaster One Stop DG Shop 30,000+ products with core capabilities in dangerous goods labels, placards, and packaging Tens of thousands of customers across a wide variety of industries Twenty years experience building technology solutions to simplify the process of shipping dangerous goods Flagship product is the Dangerous Goods Information System (DGIS) Team of regulatory and operating experts with deep experience across industries Consulting services include: -Compliance audits -Classification -Regulatory interpretations -Training strategies and development
4 DOT Enforcement HazMat Shipping Process Product Classification Outbound Shipping Carrier Acceptance & Transport Arrival at Destination HazMat Transport Training
5 HazMat Shipping Process Product Classification Outbound Shipping Carrier Acceptance & Transport Arrival at Destination
6 The Nine (9) Hazard Classes Hazardous Materials: Articles or substances that pose a risk to health, safety, and property when transported Explosives Gases Flammable Liquids Flammable Solids Oxidizers & OP Poison & IS Radioactive Corrosives Miscellaneous
7 Hazard Classification Transport Safety Relies on Correct Classification How do I classify materials for transportation? Section CFR Part 173
8 Hazard Classification Build Product HazMat Data Set: UN Number & Proper Shipping Name Hazard Class Packing Group Weight/Volume of SKU Flash point (Class 3) Battery attributes (lithium batteries)
9 Classification Challenges Articles not subject to SDS requirements Bad Information Gathering classification info on large inventories Product Classification Data MANUFACTURER Products 3PL Discrepancies
10 HazMat Shipping Process Product Classification Outbound Shipping Carrier Acceptance & Transport Arrival at Destination
11 Fully Regulated v. Exceptions Fully Regulated Everything is required unless it s not UN Performance Package Hazard Marks Hazard Labels Placards Shipping Papers Emergency Response Common Exceptions Limited Quantity/ORM-D Excepted Quantity Materials of Trade Small Lithium Batteries Full Training
12 Outbound Shipping UN1090 Acetone UN Performance Packaging Hazard Marks Hazard Class Labels Placards Shipping Papers UN1090 Acetone 1,800 lbs. gross
13 Outbound Shipping UN1090 Acetone UN Performance Packaging Hazard Marks Hazard Class Labels Placards Shipping Papers X UN1090 Acetone UN1090 Acetone 400 lbs. gross
14 Outbound Shipping UN Performance Packaging Hazard Marks Hazard Class Labels Placards Shipping Papers X X X X X UN1090 Acetone 6 fl oz. GROUND
15 Outbound Shipping UN Performance Packaging Hazard Marks Hazard Class Labels Placards Shipping Papers X X UN1090 Acetone 6 fl oz. + HazMat Surcharge AIR
16 Business Turn to Automation NONE SOME COMPLETE
17 DOT Enforcement NONE SOME COMPLETE How accurate & complete is the dataset? Who is writing the automation rules? Are the rules updated as regulations change? How often is the process audited?
18 Undeclared Shipment Four (4) spare lithium ion batteries Top Enforcement Priority for Parcel Shipping: Difficult to discover Mandatory reporting on discovery FAA On-Site Inspections Strict financial penalties
19 Parts of a Compliant Training Program HazMat Transport Training General Awareness Employees that ship hazmat must be trained In-Depth Security Security Awareness Function Specific Safety Training DOT training regulations are non-prescriptive No minimum time No instructor qualifications Insufficient or lack of training is the most frequent violation cited by DOT inspectors
20 HazMat Training Who needs training? C-level staff? Pick/pack personnel? Outbound shipping area? DC managers? What level of training do they need? Week-long multimodal training? Short elearning modules? On-the-job instruction?
21 Streamline Training Hazardous Materials 3,700+ UN#s Quantity Small Parcel Mode Air Non-Bulk (e.g. drum) Ocean Vessel IBC/Tote Rail Cargo Tank Highway
22 Streamline Training Hazardous Materials 3,700+ UN#s Quantity Small Parcel Mode Air Non-Bulk (e.g. drum) Ocean Vessel IBC/Tote Rail Cargo Tank Highway
23 HazMat Shipping Process Product Classification Outbound Shipping Carrier Acceptance & Transport Arrival at Destination
24 Air Operator Challenges Acceptance Check and FAA Oversight DG shipments subject to 50+ item acceptance checklist FAA agents often peeking over their shoulder
25 Air Mode Enforcement Customers
26 Highway Carrier Inspection Placarding?? Determination Placards Trigger: HazMat Endorsement on CDL PHMSA Registration More Enforcement
27 INSPECT ME Highway Enforcement
28 Carrier Challenges Quick & correct determination on placarding Reliant on the shipper to get things right Communicating company policy v. regulation
29 HazMat Shipping Process Product Classification Outbound Shipping Carrier Acceptance & Transport Arrival at Destination Customer Returns/Reverse Logistics
30 On The Horizon HazMat Regulations are always changing Most changes are minor, lithium batteries in flux: SAE G-27 Lithium Battery Packaging Committee On-going Rulemakings (Int l & Domestic) UN Working Group on Lithium Battery Classification Lithium battery producers & shippers: Now is the time to get involved!
31 Final Thought Complexity Breeds Opportunity Gaining an Advantage: Shipper: Adding regulated items to inventory Shipper: Quicker fulfillment times through air transport 3PL/FF: Broaden customer base to include hazmat Carrier: Expanding hazmat willing to transport
32 Questions Mike Pagel Senior Consultant Labelmaster Services
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