HAZMAT TRANSPORT PRO

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2 HAZMAT TRANSPORT PRO Copyright 2017 J. J. Keller & Associates, Inc Breezewood Lane P.O. Box 368 Neenah, Wisconsin Phone: (800) Fax: (800) JJKeller.com Library of Congress Catalog Card Number: ISBN: Canadian Goods and Services Tax (GST) Number: R All rights reserved. Neither the publication nor any part thereof may be reproduced in any manner without written permission of the Publisher. United States laws and Federal regulations published as promulgated are in public domain. However, their compilation and arrangement along with other materials in this publication are subject to the copyright notice. Printed in the U.S.A. ii 6/17

3 HAZMAT TRANSPORT PRO Introduction It makes little difference whether you are employed by a shipper of hazardous materials or by a carrier that transports hazardous materials, you have a responsibility to yourself, to others, and to the environment in which we all exist, for eliminating problems and potential dangers while in the business of shipping and transportating hazardous materials. The Hazmat Transport Pro helps all parties involved in the transportation of hazardous materials address the associated problems of hazardous materials transportation and provides solutions to those problems. This manual helps Operations Managers, Hazmat Transport Managers, Shippers and Trainers achieve safety and compliance standards necessary in this industry every day. In addition, this management tool provides the information needed to remain in compliance with the many and complex regulations associated with hazmat transport. Finally, this manual provides best practices and requirements for packaging, labeling, employee training, audits, and risk management that promote proper and safe transportation of hazardous materials for both the shipper and carrier alike. Revision bars, like the one at the left of this paragraph, are used in this publication to show where significant changes were made on update pages. The revision bar next to text on a page indicates that the text was revised. The date at the bottom of the page tells you when the revised page was issued. Due to the constantly changing nature of government regulations, it is impossible to guarantee absolute accuracy of the material contained herein. The Publisher and Editors, therefore, cannot assume any responsibility for omissions, errors, misprinting, or ambiguity contained within this publication and shall not be held liable in any degree for any loss or injury caused by such omission, error, misprinting or ambiguity presented in this publication. This publication is designed to provide reasonably accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the Publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional person should be sought. The Editors & Publisher J. J. Keller & Associates, Inc. iii 6/17

4 HAZMAT TRANSPORT PRO Published & Printed by J. J. Keller & Associates, Inc Breezewood Lane, P.O. Box 368 Neenah, Wisconsin Phone: (800) Fax: (800) JJKeller.com EDITORIAL director of editorial resources PAUL V. ARNOLD project editor ROBERT J. ROSE contributing editor THOMAS E. BRAY contributing editor THOMAS J. ZIEBELL sr. editorial manager transportation BETTY J. B. WEILAND sr. editor transportation safety DAREN B. HANSEN sr. editor transportation management MARK G. SCHEDLER editor hazardous materials transportation MICHAEL L. ATKINSON editor transportation safety KATHY L. CLOSE editor transportation management RICHARD J. MALCHOW editor transportation operations HEATHER L. NESS editor transportation safety JILL M. SCHULTZ sr. metator/xml analyst MARY K. FLANAGAN PUBLISHING GROUP chairman ROBERT L. KELLER vice chairman & treasurer JAMES J. KELLER president & ceo MARNE L. KELLER-KRIKAVA evp & chief operating officer RUSTIN R. KELLER chief financial officer DANA S. GILMAN sr. director of product development CAROL A. O HERN sr. product development manager JENNIFER M. JUNG sr. product development specialist SUZANNE IHRIG director of manufacturing TODD J. LUEKE sr. electronic publishing & prepress manager GERALD L. SABATKE The Editorial Staff is available to provide information generally associated with this publication to a normal and reasonable extent, and at the option of, and as a courtesy of, the Publisher. iv 6/17

5 HAZMAT TRANSPORT PRO Table of Contents Hazmat Transport Responsibilities Overview Shipper-Carrier Relationship What Is a Hazardous Material? Who Regulates Hazmat? How Is Hazmat Regulated? Hazmat Responsibilities Q & As Hazmat Compliance Management Shippers Carriers Hazmat Compliance Q & As Hazmat Enforcement Roadside Inspections and Violations On-Site Audits Self Audits Hazmat Enforcement Q & As Risk Management & Loss Prevention Goals and Requirements Operational Practices Driver Practices Incident Mitigation Risk & Loss Q & As Managing Hazmat Training Regulatory Requirements Developing a Training Program Hazmat Training Q & As Reference Hazmat Table Violations and Penalties v 12/09

6 HAZMAT TRANSPORT PRO Sample Policies Sample Documents Agency Contacts Subject Index vi 12/09

7 Hazmat Transport Pro Risk Management & Loss Prevention Operational Practices Developing operational procedures to reduce risk When we use the term operational in this discussion, we are referring to dispatch or customer service; the back office operations at a company. We will specifically be discussing functions and policies that can be implemented in the office to reduce the risks associated with transporting hazardous materials. One key procedure is to develop function-specific training for dispatch and customer service personnel. This is not only required in the regulations, but it is critical if you want to be safe and successful at transporting hazardous materials. Dispatch personnel need to be trained to spot the presence of a hazardous material and have enough knowledge to counter customer arguments. Next, consider having a procedure to ask every customer, no matter what, if the shipment they are offering contains hazardous materials. If the answer is yes, the next step would be to ask for the exact material description (proper shipping name, hazard class, ID number, and packing group). At this point, the dispatcher or customer service representative should have enough information (provided by the customer) and knowledge (provided by the training) to decide if the company can ship the material. If there are questions as to what the material is, the dispatcher or customer service representative must have the authority to Operational Practices 1 12/13

8 Hazmat Transport Pro ask the customer to fax a copy of either the shipment paperwork or an SDS for the material to the company for review. Once the decision is made to accept the shipment, all paperwork or computerized entry concerning the shipment should be flagged, indicating that it is a shipment of hazardous materials. Real World If operations personnel are not comfortable with the shipment, they must have the right to refuse. Many times carriers end up in bad situations involving hazardous materials because no one thought they could say no. You want to be sure that your operational people have the ability to say no and know that it is expected that they will say no if anything is not right involving a shipment of hazardous materials. The next operational procedure is to provide full disclosure to the driver, as well as an instructional briefing. Full disclosure involves telling the driver exactly what the materials is and how much the driver can expect to be picking up. The briefing (which can be done by a safety or compliance person) is a review of the loading, paperwork, driving, emergency, and unloading procedures that must be followed based on the anticipated material. Part of the brief should include verifying that the driver and vehicle have the credentials and equipment necessary for the shipment. The company needs to have a right to refuse policy in place for drivers that matches the operational policy. The driver refusal policy should involve the driver being able to stop the loading process at any point and having concerns addressed by the shipper or the company. The driver refusal policy should include drivers knowing and understanding that they have the right to stop loading until concerns are addressed. Here again, many carriers end up in bad situations involving hazardous materials because no one thought they could say no. Once the driver is loaded, the driver should check in and let the operations group know that everything went according to plan, that the material matches the order, and the procedures for loading were followed. At this point, the company should enter the contact in a log or register. Drivers that transport hazardous materials requiring a Hazardous Materials Safety Permit (HMSP) must communicate with the company when loading, at the beginning and end of each duty cycle, and when unloaded. The log starts this contact cycle with these drivers. Other drivers may not be subject to the communications requirements, but it is still a good idea to include the other drivers and shipments on the log or register. Here is an example of some of the basic information a carrier should consider on the log or register: Driver name. Operational Practices 2 12/13

9 Risk Management & Loss Prevention Truck and trailer numbers. Was the driver briefed? Shipper and origin, consignee and destination, and check in times at shipper and consignee. Expected route. Proper shipping name, hazard class, ID number, and packing group of the material being carried. Placard(s) displayed. Emergency information (contact number and type of emergency information, i.e. SDS, ERG, or shipper s form, that is with driver). Communications required? If yes, is communications log started? An additional requirement in use at some carriers is requiring the shipper or the driver to fax a copy of the shipping papers to the carrier. This allows the carrier to verify that the shipment papers are completed correctly and do not contain any surprises. The shipping papers are then kept with the log the entire time the shipment is under carrier control. The log is placed in a location where it is secure, but can still be accessed quickly by on duty or on call personnel. The reason for quick access is not only is the log or register used to aid in compliance, it is also an important source of information for emergency responders. Emergency responders are taught to contact the motor carrier if they cannot get information from the normal source (the driver and shipping papers are their usual information sources). Many times when these calls come in from responders, they have very little information (all they may know is it is one of your trucks ). This log is not required by the regulations. As with many issues discussed when it comes to risk management, this is a best practice. The log simply allows a carrier to be constantly conscious of the materials actively moving in its system, who is moving it, where it can be expected, and if an emergency should arise, it makes sure that the company and the driver are prepared for it. Operational Practices 3 12/13

10 Hazmat Transport Pro Designation of a go-to person in the event that an error is found at any time in the process (from a customer service representative having problems with a customer to a billing clerk discovering a shipment was unreported hazmat) is another practice that many successful carriers have. This person should resolve and record any problems that develop involving a shipment of hazmat. Best Practices Best Practices The go-to person should be knowledgeable of hazmat regulations and the company hazmat policies, procedures, and practices. This person should also have instant access to the regulations and emergency response information. If this is not possible (due to the size of the company or the level of expertise of the employees), then the go-to person should have access to resources that can provide regulatory and response information. Having a go-to person or hazmat contact at the company will also allow for central storage location of information on problems that have occurred. This information can then be used to refine policies, procedures, and practices in the future. Operational Practices 4 12/13

11 Risk Management & Loss Prevention Customer screening and tracking Screening customers that will be involved in hazmat is actually a fairly simple process. When considering accepting shipments from a new customer (whether a shipper or receiver), officially ask, Will any of your shipments involve hazmat? If the answer is yes, make sure at least the following questions are answered (and that the answers match your processes to reduce risk): What hazmat (ID number, name, and class) will we be carrying for you? What type of packaging is used for these shipments (pails, boxes, drums, portable tanks)? Will you provide us with the hazmat information when a shipment is offered to us? Can our drivers be present on the dock to supervise loading and unloading? Do you have the ability (via or fax) to send us a copy of the shipping paperwork in advance of loading? Do you provide a 24-hour emergency contact, or are you contracted to a service (such as ChemTrec) that provides this? Will we be picking up or delivering to a variety of your customers, or will this be a one shipper/one receiver arrangement? The hazmat go-to person and others at the company should be tracking its customers. If a customer is not reporting the presence of hazmat on shipments, is not fully disclosing what hazmat will be on shipments, or is constantly having a problem with drivers requests, it needs to be brought to the attention of the company. If tracking is not being performed, all these problems could be going on unnoticed. Customer tracking simply involves creating a metric (even something as simple as a questionnaire) of what is expected of a shipper and receiver (customer). Each violation of the metric is then scored. As shipments are progressing (or after each shipment), the customer is scored using the questionnaire. Here is a sample of a simple questionnaire: Did the initial communications with the customer include a notification that the shipment included a hazardous material? Did the shipper allow the driver to supervise the loading? Did the material loaded match the information provided by the customer? Was the material properly named, classified, marked, labeled, and packaged? Did the shipper provide the driver with proper shipping papers? Was the shipper willing to fax or a copy of the shipping papers to the company for verification (if requested)? Was the shipper willing to assist in securement issues (if any arose)? Operational Practices 5

12 Hazmat Transport Pro Was the driver provided with emergency information by the shipper? Were there any problems with the loading process? Was there any shifting of the product during transport? Did the receiver allow the driver to supervise the unloading? Were there any problems during the unloading process? Was the shipment received with no exceptions? Were there any excessive delays created by the customer (improper shipper or receiver appointments or loading delays, etc.)? Did the customer (either shipper or receiver) place the company in a situation that required the violation of the safety regulations to make delivery on time? Was there a release of the hazardous material at any time? If a customer consistently ends up with a score in the tracking, there may be a need to discuss the situations involved with the customer. If the customer refuses to address recurring problems, a sound risk management decision will need to be made. If the customer is exposing the company to unnecessary risk through the practices in question, it may be beneficial for the long-term health of the company to look for a different customer (remember the possible penalties?). Internal tracking to determine operational compliance with procedures Finally, one operational procedure that should be considered is internal auditing of the procedures that are in place. These can be random audits designed to check that the existing procedures are followed, or they can be formal audits. This is different than auditing for compliance. When auditing for compliance, you are comparing the company s performance against the regulations. When auditing processes, you are auditing your performance against your process. Operational Practices 6

13 Risk Management & Loss Prevention Pulling shipping papers that have hazardous materials indicated and verifying that all company processes were followed is a common example of this practice. The process involves checking items such as the material was marked as hazmat on the initial order form, the order was flagged in the dispatch system as hazmat, and there is proof of the driver was briefed. Auditing Loading and Unloading Procedures The physical act of transporting hazardous materials accounts for a significant portion of hazmat incidents and will always be considered as a risk factor. Drivers who exceed speed limits on curved or banked roads, equipment with an unfamiliar center of gravity for an inexperienced driver, and adverse weather conditions for all drivers are issues that management can address with ongoing awareness and training of driving skills. What may come as a surprise to many is that the loading and unloading of hazardous materials is a bigger cause of hazmat incidents than is the transporting of hazmat. In fact, more incidents of hazmat damage and spills are caused by the unloading of hazardous materials than the loading and transporting combined. Both shippers and carriers can benefit from a periodic internal audit of their operational procedures to reduce the possibility and the risk of hazmat incidents due to faulty loading and unloading practices. The following is a list of items and steps to take to confirm that proper loading and unloading procedures are in place: Operational Practices 7 12/11

14 Hazmat Transport Pro Material Handling and Safety Equipment Inspect material handling equipment regularly and in addition to scheduled maintenance schedules. Make sure that the proper forklift accessory is used for the freight to be handled, e.g., drum grips or clamps for drums loaded on the floor of the trailer, barrel clamp on hand trucks, etc. Make sure flammable material and explosives are kept away from any source of heat. Is safety equipment on vehicles inspected regularly, including fire extinguishers? Is personal protection equipment required for loading/unloading purposes and is it being inspected on a regular basis? Are compressed gas cylinder safety devices inspected for safe use? Inspect emergency shutoff valves at the start of each shift or as a part of pre-trip inspection. Shipping Papers and Placards Before loading or unloading, make sure that the information on the shipping papers matches the shipment being transported. Check shipping papers for accuracy: 1. Hazardous Materials properly and clearly identified on shipping papers, 2. Emergency Response number on shipping papers, 3. Material Safety Data sheet available. Make sure shipping papers match with markings and labels on shipment. Make sure proper placards are affixed to vehicle when loading begins and that all placards are removed when hazardous materials are unloaded from the vehicle. Loading/Unloading Are supervisors or experienced staff required to be present during loading/unloading? Are DOT regulations checked regarding the compatibility of hazardous materials per the Segregation Table of Hazardous Materials for mixed loads? Has the trailer been thoroughly checked for holes in the floor, walls, and ceiling, and have all nails or sharp objects been removed before loading? Is the load properly distributed throughout the vehicle and braced or secured to prevent shifting while in transit? Tank trucks handling bulk loads must be inspected for any loose objects inside the tank. Operational Practices 8 12/11

15 Risk Management & Loss Prevention Inspect valves, connections, emergency shutoff valves, and pipes. Make certain all electrical components in the vehicle are off before loading or unloading. Tank trucks must be grounded before loading/unloading. Ensure that all containers are cleaned and purged once unloaded and before scheduling for re-loading purposes. Operational Practices 9 12/11

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