Safety Training *Print or save this presentation if you want, by clicking here to load a.pdf of this handout. The DOT Ground, IATA Air, and IMDG Ocean Regulations all require safety training. We will use the US DOT requirements as the starting point, and then show where international alternatives differ. 4-2-17
DOT Safety Training using 2016-2020 ERG *Print or save this presentation if you want by clicking here to load a.pdf of this handout. Using the North American Emergency Response Guide Understanding DOT Emergency Response Information Requirements Why are you taking this DOT program?
DOT Safety Training This program is designed to teach the student how to use the current D.O.T. North American Emergency Response Guidebook (published every 4 years). This program will also cover D.O.T. Emergency Response communications requirements such as a 24 hour phone number and written emergency information that must accompany or be available with each shipment (for example, an MSDS or similar document). DOT Safety Awareness 3
You need a copy of the ERG Ideally, you should have a copy of the actual ERG in front of you. The 2016 edition is current until mid 2020. It's published every 4 years. If you don't have a copy you will be able to load a pdf copy on the following pages. Remember, once loaded, you can save the pdf by using the Control + S feature, or choosing the disk icon on your screen if that s available. DOT Safety Awareness 4
Overview of this DOT Safety Training Program Emergency response information. This is not intended to be a comprehensive emergency response training session. This section is to emphasize the usefulness of the emergency response guidebook for first responder information on dealing with a dangerous goods incident. The learning objectives for this section include: how to look up the hazardous material in the North American emergency response guide. the general philosophy of handling a hazardous materials emergency, and, understanding emergency response communication requirements. This does NOT replace your U.S. OSHA training requirements from the Department of Labor... this course is focused specifically on how to use the ERG and understanding phone number and written emergency info requirements. DOT Safety Awareness 5 image
Reference Copy of 49 CFR Part 172, Subpart G Emergency Response Information Do you want to load a pdf copy from 49 CFR of Subpart G of Part 172? This 4 page pdf covers the DOT s emergency response information requirements. If you are not familiar with their rules it might be a good idea to print it out. Or at least load the pdf and save it to your desktop or elsewhere on your hard drive. Click here to load Subpart G. DOT Safety Awareness 6
DOT Emergency Response Information and Communication 1) Telephone Number The Shipper's Declaration must include a 24-hour emergency response telephone number (with area code and international access codes) for use in the event of an incident involving dangerous goods. This number must be monitored at all times by a person who: is knowledgeable of the hazards and characteristics of the substance being transported. has comprehensive emergency response and accident mitigation information. or has immediate access to a person who possesses such knowledge and information. This number must be listed on the Shipper's Declaration immediately following the description of the dangerous goods and identified as the "Emergency Contact." There are exceptions to the emergency phone number requirement that will be shown at the end of this section. You can use the number of an outside agency (i.e. Chemtrec) if you have a contract with them. If you use their number without a contract you could be fined several thousand dollars per incident. If you use Chemtrec or another third party "ERI" (Emergency Response Information) Provider you must show the contract number or the name of the company with the contract with the ERI to provide that service if that s not readily apparent from the shipping papers. DOT Safety Awareness 7
DOT Phone Number Not Needed Note, that a D.O.T. 24 Hour Phone number is not required for certain shipments: Under 49 CFR 172.604(c) and IATA/ICAO variation USG-12, the emergency phone number requirement does not apply to shipments made under the limited quantity provisions of the regulations, nor does it apply to the items listed below. Consumer Commodities Battery powered equipment Battery Powered Vehicle Castor beans, flakes, meal or pomace Dry Ice, Carbon dioxide solid Engines, internal combustion (flammable gas powered or flammable liquid powered) Refrigerating machines, and Vehicle (flammable gas powered or flammable liquid powered). Keep in mind that while D.O.T. may not need a phone number for these items, it's possible other countries or even the airlines themselves may require it for ALL dangerous goods. DOT Safety Awareness 8
Written Emergency Response Information Please remember that there is also a requirement for Written Emergency Response Information. In addition to a phone number, written emergency response information must be immediately available at all times the dangerous goods is present. This information must include as a minimum: the description of the dangerous goods. immediate hazards to health. risks of fire or explosion. immediate precautions to be taken in the event of an accident or incident. immediate methods for handling fires. initial methods for handling spills or leaks in the absence of a fire. preliminary first aid measures. This written information must be in English, available away from the package. Let me repeat that: the information must not be attached to the package, during an emergency with a leaking package the last thing you want to do is force someone to approach the package to pull off an MSDS or other written emergency response information. DOT Safety Awareness 9
Methods of Providing Written Emergency Response Info Methods of Providing Written Emergency Response Information. There are several methods of providing the written emergency response information. These methods are listed in USG-12 in the IATA regulations and in Subpart G of 49 CFR part 172. This information can be relayed in the following manner, but not limited to: including the information on the Shipper's Declaration for Dangerous Goods. locating the information in a separate document such as a material safety data sheet. using the information on the shippers dangerous goods declaration in conjunction with a separate document such as the North American Emergency Response Guide. Note: Few people make use of the first option (which is writing the information on the shipper s declaration) because there simply is not enough space on a typical DGD. Most people use an SDS but even this has it s limitations. As the shipper, you have to make certain that the Safety Data Sheet is current, and contains the required information. This is not always the case especially if you are relying on someone else, such as your vendor, to provide the MSDS to you. It may come as a surprise, but if they make a mistake on the MSDS that affects this D.O.T. requirement for written response info, it is you or your company that could be liable. DOT Safety Awareness 10
Summary of Rule for Written ERI DOT Safety Awareness 11
Load a Copy of the 2016 DOT North American Emergency Response Guidebook If you didn t do this already (two pages ago), click on the image of the guidebook at right and it will load a.pdf file that you can save to your computer (on your desktop or elsewhere on your hard drive). You ll need it for your exam. Remember, once loaded, you can save the pdf by using the Control + S feature, or choosing the disk icon on your screen if that s available. DOT Safety Awareness 13 image
First Response in a HazMat (DG) Emergency Your First Actions Emergency response information, general: know your capabilities. If an accident occurs and you do not have comprehensive emergency response training, then your best course of action is to clear the area immediately to prevent yourself and others from being exposed or injured and call for help. Notify the appropriate emergency response personnel. You should follow your companies established emergency procedures if you have them, but when in doubt, or absent any specific instructions, 911. Inform them that you have a hazardous materials emergency; (persons outside the U.S. may be more familiar with the term Dangerous Goods). Either way, be prepared to tell them as much information as you can safely provide. If possible get a copy of the shipping papers if it is safe to do so. They will want to know what substances are being shipped and providing them with the U.N. numbers and proper shipping names as well as the quantities involved will be very helpful. DOT Safety Awareness 14 cleartheareablack.png
Open to the ERG Inside Cover How to read shipping papers. This is a quick reference guide on how to find hazardous materials information on shipping papers or on placards. In general the easiest step to take is to look for a 4 digit UN/NA or ID number on the shipping papers. Since 2013, by all modes, this is required to be listed first. 15
ERG Page 1 Instructions Follow the flowchart from the upper left: Is it an explosive? If not, can you see a UN number? If you can, look in the yellow pages Your goal is to Determine the Guide Number which is in the orange pages. Run through a couple scenarios on this chart, and we ll move into some specific examples. DOT Safety Awareness 16
Step 1: Locate the UN Number or Proper Shipping Name Let s say, for example, that the substance IS an explosive, division 1.4S. With that information you can turn to the orange pages immediately and review Guide 114. Maybe it s not an explosive, let s say you are looking at the shipping papers and you see a UN number of UN1090. This means you can look it up in the yellow pages in the ERG. Based on this info you d turn to ERG guide number 127 in the orange pages. Let s look at that on the next screen. 17
NAERG Guide 127 This guide is for Water- Miscible flammable liquids (meaning that they can be diluted by water). It s divided into these main sections: Potential Hazards Public Safety Emergency Response Review this guide in your ERG or click on the image to enlarge it and you will see the sub-topics within those main three headings. You can see important information in the subtopics. For example, this guide is for certain flammable liquids, but under Fire it cautions you that if it involves UN1170, for example, to use alcoholresistant foam. 18
ERG Page 1 Instructions (The Blue Pages) Let s say you don t know the UN number of the material, but you know it s name, let s say it s Battery fluid, acid. Follow the flow chart down do you know the UN number? No. Do you know the name? Yes The blue square says to search for the material in the blue pages. 19
NAERG Guide 157 This guide is for certain toxic and/or corrosive substances. It s divided into the same main sections: Potential Hazards Public Safety Emergency Response Review this guide in your ERG or click on the image to enlarge it and you will see the sub-topics within those main three headings. You can see important information in the subtopics. For example, this guide warns you that with fires, some foams will react with the material and release corrosive or toxic gases. That s a good reason why just having the ERG isn t always enough. Having a safety data sheet or some product specific information may be helpful. 20
ERG Page 1 Instructions (The Placard Chart) Let s say you don t know the UN number or the name of the material, but you can see a label or placard. Follow the flow chart down do you know the UN number? No. Do you know the name? No. So you see a placard? Yes. Start by reviewing the instructions on page 7 of the ERG (or you can click the image at right). 21
Table of Placards Guide Pg 8-9 FIND THE PLACARD THAT MOST CLOSELY MATCHES YOUR SUBSTANCE AND TURN TO THAT 3 DIGIT GUIDE UNTIL MORE SPECIFIC INFORMATION BECOMES AVAILABLE 22
ERG Page 1 Instructions (An Unknown Substance) Let s say you don t know the UN number or the proper shipping name and you cannot see a hazard label but you believe dangerous goods are involved. Follow the flow chart down to the second row of boxes and across to the right to the orange square that says Use Guide 111 That is the guide you would use until more specific information becomes available. Let s take a look at it on the next screen. 23
Guide 111 Unknown Substances 24 DOT Safety Awareness
ERG Page 1 Instructions (The Green Pages) If the entry is highlighted in green you need to drop down to some specific questions. Click on the image below to get an idea of how emergency responders would use this information for evacuation and isolation guidance. 25
Green Highlighted Entries (Evacuation Criteria) If an entry in either the blue pages or the yellow pages is highlighted, you will need to turn to the greenbordered pages in the back of the book. The green pages are used when some sort of evacuation criteria exists. Take a moment to review some of the highlighted entries. For example, in the example to the right, UN 1005 (in the yellow pages) is a highlighted entry. On the next page in this training program are instructions on how to utilize the Table of Initial Isolation Distances (the green bordered pages) DOT Safety Awareness 26
Green Pages: Using Table 1 Initial Isolation Distances This isn t something in which a shipper or forwarder is likely to be involved. They key lessons in this involve the actions in this page, including: 1. Figure out what the material is and the three-digit ERG guide that goes with it and note the direction of the wind. 2. Look in the green pages for your substance. 3. Determine if it s a small or a large spill, during the day or at night. 4. Start with the initial isolation distance to clear an area in all directions. 5. Determine the protective action distance downwind. On the right hand page you can see Step 6 and a diagram for protecting an area downwind from the spill. The last thing it reminds you to do is call the emergency response number on the shipping paper or the appropriate agency ASAP. DOT Safety Awareness 27
International Alternatives DOT Safety Awareness 29
International Alternatives to the DOT NAERG: IATA IATA requires safety training but does not specify any emergency response guide or procedures other than the use of the ICAO Red Book for in flight emergencies. Column N (which is explained in IATA 4.1.6.14 4.1.6.14 Column N ERG Code Emergency Response Drill Code as found in the International Civil Aviation Organization (ICAO) document The Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods (ICAO Doc. 9481-AN/928). The code consists of a combination of letters and numbers, which represents suggested responses to incidents involving the specific dangerous good entry to which the drill code is assigned. The ERG Code is provided for the benefit of operators so that the ERG Code may be added to the Special Load Notification to Captain (NOTOC). DOT Safety Awareness 30
ICAO Red Book ERG This manual provides the flight crew with immediate emergency response information that is applicable to inflight DG incidents as there are not the types of resources available as would be on the ground. Will Carry Air Carrier Training 31
Aircraft Emergency Response Drills from the ICAO Red Book Table 4-1, Aircraft Emergency Response Drills: Will Carry Air Carrier Training 32
IMDG Ocean and European Land Emergency Guides The IMDG Ocean rules and others use a system of placards on a container or vehicle. You can find information on this in the DOT NAERG and elsewhere. Click image for details. DOT Safety Awareness 33
European Road ADR Driver Safety Info The IMDG Ocean rules and others use a system of placards on a container or vehicle. You can find information on this in the DOT NAERG and elsewhere. Click image for details. The ADR (the Road regulations that are part of the UN) require instructions for drivers of hazardous materials (dangerous goods) vehicles. If this is important to you in your job, you can link to the UN website by clicking here. You may also see a pdf example of a Driver Instruction by clicking on the image below. DOT Safety Awareness 34
Congratulations The End! Remember, this training may not cover ALL of your company s safety training requirements. While there is substantial training on selecting an emergency response guide, you will probably need more training to meet workplace safety rules. Some elements that may require additional training are listed here. It does not cover these key OSHA (and other) workplace safety training requirements. How to read and understand Material Safety Data Sheets Workplace Safety Safety Requirements of your company Safety Resources of your company (i.e. eye-wash stations, first aid procedures, etc). European and other national training rules on these safety topics. You may now exit this module and take the final exam when you're ready. You will need a copy of the current ERG (or the.pdf file) to complete the exam. You can click here to load the file before starting the exam (just save it on your hard drive). Remember, the 2016 guide is okay till 2020. DOT Safety Awareness 35