Motor Carrier/Shipper Audit

Transcription

1 Avoid Pitfalls During a DOT Avoid Pitfalls During a DOT Motor Carrier/Shipper Audit

2 Identification Crashes Regardless of fault SMS Basics in Alert Status HM Incidents Road Side Inspections Just Because They Can

3 The View From Feet Part million in insurance (MCS-90) Part 391 Driver Qualification File Part 392 Driving Speed Limits 392.9b 9b Must have Active DOT Number

4 The View From Feet Part 393 Parts and Accessories Part 395 Hours of Service Part 396 Inspection, Repair & Maintenance Record Keeping IT IS ALL ABOUT THE PAPER

5 The View From Feet Part 397 Driving and Parking Fueling In attendance at the point where the fuel enters the tank Tires Inspect every time the vehicle is parked

6 Shipping Papers The person offering the HM for transportation must describe the material on a shipping paper Not the motor carrier.

7 Shipping Papers M t C i l b hi Motor Carrier may also be a shipper. Propane marketer loading a bobtail and delivering propane to the customer. Makes the propane marketer a shipper

8 Shipping Papers Description of HM Identification Number UN1075 Proper Shipping i Name Liquefied Petroleum Gas Hazard Class 2.1 Packing Group Not required for compressed gases Quantity 1 cargo tank

9 Shipping Papers (b) Basic description MUST be shown in sequence with no additional information interspersed. Definition from Webster: To scatter here and there or place at intervals among other things

10 Shipping Papers Additional Descriptions: Following the basic description?? (h)(2)(i) NONCORROSIVE or NONCOR indicating suitability for transportation in QT tanks (h)(2)(ii) NOT FOR Q AND T TANKS Classification is a Shipper Classification is a Shipper Responsibility

11 Shipping Papers (p) - The word "non-odorized" or "not-odorized" must be included in association with the proper shipping description on a shipping paper when non-odorized liquefied petroleum gas is offered for transportation.

12 Shipping Papers UN1075, Liquefied Petroleum Gas, 2.1, Non-Odorized, NONCORROSIVE 1 Cargo Tank For Hazardous Materials [or Dangerous Goods] Incident Spill, Leak, Fire, Exposure, or Accident Call CHEMTREC Day or Night Within USA and Canada: CCN703222

13 Shipping Paper Accessibility (e)Clearly visible and within arms reach in the cab while retained by the lap belt On the drivers seat or in the pouch in the drivers door. Pouch needs to be a clear pouch so it is visible. Not a pocket.

14 Shipping Paper Retention (f) 2 years for shippers and 1 year for motor carriers

15 Permanent Shipping Paper (f) For multiple shipments without a change in the shipping i description your delivery ticket t must have the following additional information:

16 Permanent Shipping Paper Shipping Name Liquefied Petroleum Gas Identification Number UN1075 Quantity Transported Number of gallons Date of Shipment

17 Permanent Shipping Paper Recommendation Make sure your delivery ticket and/or your shipping paper has language on it that verifies that odorant was added, a sniff test was performed and odorant was detected.

18 Cargo Tank File Identify the file with the following info: Unit Number Year Make Serial Number Tire Size

19 Cargo Tank File Permanent Documents Certificate of Compliance U-1A Certification of Emergency Discharge Control All records of repair, modification, stretching or rebarrelling.

20 Cargo Tank File Recommendations Picture of specification plate Pictures of all 4 sides of the CTMV Other documents from the CTMVM Operating instructions Equipment specifications Build list

21 Cargo Tank File Most Recent Tests and Inspections (Part 180) External Visual (V) Leakage (K) Internal (I) () Pressure (P) Wet Fluorescent Magnetic Particle Examination Motor carrier supplemental report for MC331 Periodic Inspection

22 Cargo Tank File Preventive Maintenance Schedule Repair and Maintenance Records p Maintain for 12 months

23 Word to the Wise Do not maintain documents any longer than required by Statute.

24 Word to the Wise Originals of all documents relating to repairs, modifications, inspections, tests and repairs performed on cargo tanks between January 1, 2000 to the present.

25 Word to the Wise All customer files and invoices during the same time period. Records reflecting SS# s of all employees during the same time period. All records of training during the same time period.

26 Word to the Wise If you anticipate needing access to these records, it is your responsibility to make copies. you ll be the one who ends up in the doghouse if you don t have what you need.

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28 Presenter Name: Daniel G. Shelton Organization: HazMat Resources, Inc.

29 Avoiding Pitfalls Paul Horgan Retired California Highway Patrol Engineer and HM Specialist DOT Registered DCE and RI HM Consultant

30 Avoid odthe e6ococ O'clock News Defensive Driver Training Comply with the regulations Keep track of your CSA scores Know what the enforcement personnel are looking at.

31 CSA Red Flags

32 Fine Structure 49 CFR Part 107 Training CTF facilities Birth Certificates U-1A, R-1, etc. Security Plan HOS Pre-employment etc. Handout Audit checklist Pt. 386 Appendix B to Part 386 Penalty Schedule; Violations and Monetary Penalties Appendix A to Subpart D of Part 107 Guidelines for Civil Penalties

33 FMCSA List of Cases $4,351 $4,932 $4,381 $4,770 $4,988 Range from $2,000 to over $43,000 this last year plus under microscope

34 Penalties $250 to $250,000 possibly higher. Carriers I have worked with $35,000 to $45,000 fines last year

35 PHMSA HM shipper and carrier registration. Copy in each placarded vehicle or Registration number on shipping papers

36 HazMat Safety Permit If you are also transporting Security Sensitive e loads Bulk shipments of Natural Gas - LNG & CNG PIH You will need a HMSP See 49 CFR

37 Applying for HMSP Will trigger FMCSA Compliance Re ie ithin a fe months Will trigger FMCSA Compliance Review within a few months (not more than 6 months)

38 BIG Ticket Item Security Plan Hazardous Materials and training of ALL employees Drivers Dispatchers Anyone having after hours access Enroute In-Depth

39 Security Plan Must Cover all facilities Reviewed Annually and signed off. One size does not fit all. Updated as rules change or facility changes.

40 Security Plan Changes Gates/fencing/access Employee changes Adding video cameras, alarms, patrols Hours of operation Emergency phone numbers change PD, Sheriff, State Police, FBI, DHS or TSA

41 Daily Vehicle Inspection Reports Pre- and Post-trip trip inspections Check lists not just lined thru Signatures of drivers and reviewed by supervisors Do they match enforcement documents Repairs that were completed are noted on DVIR

42 Do Internal Audits Videos of drivers starting or ending their day. Web cams are CHEAP insurance!!!! Also check to make sure included on Log Books if used, and are included in the On-Duty, not driving time.

43 Hours of Service Local Driver 12 consecutive hours Report to duty End of duty 10 consecutive hours off duty Late night service calls Log Book drivers 14 consecutive hours Report to Duty to End of Duty 10 consecutive hours off duty

44 Cargo Tank Driver Training This includes General HM Loading and unloading training General operation Off-truck remotes, etc Emergency Procedures CT rollover Check ride on that unit. Pre- and Post-trip inspections

45 Cell Phone Use Policy Not required, q, but recommended

46 Accident Register List all accidents in past 3 years 49 CFR

47 Filling of DOT cylinders a(c) Verification of content t in cylinder. Must be by weight. The weight of liquefied gas filled into the cylinder also must be checked, after disconnecting the cylinder from the filling line, by the use of an accurate scale. Checking dates and condition before filling.

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50 Cylinder Requalification (RIN) Records: Current requalification identification number (RIN) issuance letter from PHMSA Current copies of DOT regulations. Copies of the Compressed Gas Association (CGA) or American Society for Testing and Materials (ASTM) standards for cylinder retesting. CGA C-6, C-6.3 possibly others. Cylinder retest logs.

51 Training MODULE 5 Requalify DOT Cylinders by Visual Inspection

52 RIN Training Records ALL employees who requalify cylinders

53 ASME vs. DOT cylinders ASME only transported for permanent installation DOT transported full of empty to any location

54 Questions Contact: Paul Horgan Phone: