USDOT/FMCSA HM UPDATE. National Propane Gas Association April 2014

Transcription

1 USDOT/FMCSA HM UPDATE National Propane Gas Association April 2014

2 CSA Got Data? Regardless of your feelings towards CSA, it has: Motor carriers monitoring their data more closely Enforcement verifying their violations are accurate

3 CSA Impacts on Safety Most dramatic decrease in violations in a decade Violations per roadside inspection are down 14% Driver violations per roadside inspection are down 17% The SMS has enough performance data to evaluate nearly 40% of active carriers (these carriers are involved in more than 92% of reported crashes) The SMS Website hosted 68 million user sessions in 2013

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 CSA Changes: November 5, 2013 SMS Preview: Federal Register Notice FMCSA Focused on information display Makes no changes to the SMS methodology Enhancements: Based on feedback from enforcement, industry, and other safety stakeholders. Information will be: more understandable actionable for motor carriers seeking to improve their safety performance.

6 Unified Registration System (URS) Federal Register issued: August 23, 2013 (78 FR 52607) Registration now includes: motor carriers, brokers, freight forwarders, intermodal equipment providers (IEPs), hazardous materials safety permit (HMSP) applicants/holders, and cargo tank manufacturing and repair facilities.

7 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.

8 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.

9 RR Crossing Safety

10 How good is your CT Inspection Program?

11 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?

12 Does he/she have the right equipment?

13 Does he/she know the regulations?

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15 Anyone looked at your spec plates?

16 When does a bobtail need overturn protection?

17 What qualifies as overturn protection?

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20 When is a DCE required? R Stamp?

21 Rear End Protection Device Must be DCE certified to withstand 2Gs of force INCLUDES Remounted CTMVs!

22 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

23 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

24 If your RI thinks it needs fixing, it probably does..

25 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 SNT-TC-1A Written Procedures Calibrated Equipment

26 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.

27 Always check your cargo tanks after they are inspected, something might have been overlooked.

28 This is what can happen when you utilize the wrong cargo tank facility!

29 This is what can happen when you utilize the wrong cargo tank facility! Since January 2013, there have been 6 fatalities and 12 injuries in cargo tank facility incidents, including a father/son team. At least 1 facility was burned to the ground.

30 CT Carrier Compliance Issues CT Files Do you know where your manufacturer certificates are? U-1A forms? R-1 forms? Definition of HM Employee Are you sure they re ALL trained? Training How long is that CDL good for? More than 3 years? Where s your training documentation?

31 Shipping Paper change Effective 1/1/13 UN# Proper Shipping Name Hazard Class (Packing Group) ER TX# ER Info

32 Shipping Paper Retention Motor Carrier 1 year HM Shipper 2 years HM Shipper and Motor Carrier 2 years Includes private motor carriers

33 Placarding

34 5% or Less Rule (j)(1) Permanent installation on consumer premises, one-way 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

35 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

36 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.

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39 Emergency Discharge Control (n) Which cargo tanks need what type of device (l) -- Operating Procedures (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?

40 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!

41 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

42 Test Markings V External Visual K Leakage P Pressure I Internal L Lining T- Thickness 42

43 Test Markings

44 Propane with H2S

45 Propane and NH3

46 Be careful out there! David W. Ford HM Program Manager Southern Service Center USDOT/FMCSA