DOT HazMat Shipping Compliance


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DOT HazMat Shipping Compliance

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  • The DOT oversees all transportation related agencies in the us, including the FAA, The Federal Motor Carrier Safety Administration and the Federal Railroad Administration. All these agencies are involved with enforcing Hazardous Materials Transportation rules.After 9/11, the Department of Homeland Security took over cargo security in US and one of its agencies, the TSA, often works closely with the FAA in referring hazmat violations, though enforcement is still left to the FAA. So the DOT focuses on HazMat transportation, with each of its agencies enforcing different types of shipments, FAA by Air, the Federal Motor Carrier Safety Adminstration for ground shipments and the Federal Railroad Adminstration for rail. The FAA is also assisted by the department of homeland security through the TSA who checks passenger bags and cargo shipments for hazmat at the airport.DOT’s mission is:
  • This may not apply to our clients as we’ve been trying to drill this into your heads for many years now, but you may be thinking:
  • That’s the same assumptions ValueJet tried to make...That’s why the FAA now takes these so seriously. Since this disaster in 1996, the regulations have been getting increasingly stringent. Let’s look at some recent examples.
  • Still under review a year later.
  • Basically anyone who employs someone who touches hazmat while it is being prepared or is actually in transport.
  • Google Search 49 CFR 172.101
  • Temperature extremes from -40 to 130 degrees F and large changes in air pressure require that even more attention is paid to proper packaging and shipping procedures.  These extremes and the increased likelihood of a disaster if something does go wrong, also greatly increases your odds of a regulatory audit whenever hazmat is shipped by air.
  • Some interesting situations arose when the HMR went into effect. All of a sudden, salesmen could no longer transport samples and truck drivers couldn’t have a can of bug repellent on board without having the proper paperwork and hazmat compliance. Thus an exception for “materials of trade” was created. MOT is defined as hazardous material that is carried on board a motor vehicle: PG I: Not to exceed one lb. (0.5 kg) or one pint (0.5 L). PG II, III or ORM-D: Not to exceed 66 lbs. (30 kg) or eight gallons Division 2.1 (flammable gas) or 2.2 (non-flammable gas) in a cylinder: The gross weight of the gas and cylinder must not exceed 220 lbs. (100 kg).Total weight. The total allowable weight of a MOT is 440 lbs. per vehicle.Mobile Service Exempt:Motor oil; Brake fluid; Automatic transmission fluid; Grease; Antifreeze
  • Typical parts department wouldn’t have to placard unless you’re transporting over 1000 Lbs of material.
  • DOT HazMat Shipping Compliance

    1. 1. Webinar Overview • Why training? • Recent regulatory activity • The audit process and regulator procedures • DOT Shipping Requirements • Preparing for Shipment • Shipping by Air • Parts and Mobile Services • Training Options
    2. 2. DOT, FAA, TSA oh my!
    3. 3. DOT Mission “...ensuring a fast, safe, efficient, accessi ble and convenient transportation system that meets our vital national interests and enhances the quality of life of the American people, today and into the future...” DOT’s mission is
    4. 4. DOT Mission “...ensuring a fast, safe, efficient, acces sible and convenient transportation system that meets our vital national interests and enhances the quality of life of the American people, today and into the future...” DOT’s mission is
    5. 5. DOT HazMat Training Fast? Efficient? Accessible? Convenient? “So why are they always busting my chops about shipping a little package?”
    6. 6. DOT HazMat Training In 1996 a subcontractor failed to properly mark, label and package a shipment of oxygen generators in the plane’s cargo hold. This hazardous materials shipment caused a fire that quickly brought down the plane into the Florida Everglades, killing all of the passengers and crew aboard.
    7. 7. DOT HazMat Training “Let me stop you right there – our facility almost never ships HazMat items” “We now have a policy that we do not ship hazardous materials at all, so we don’t need the training.”
    8. 8. DOT HazMat Training • ValuJet tried to avoid dealing with HazMat regs by issuing a policy that they wouldn't transport HazMat. – Thus ValuJet personnel weren't trained to watch for HazMat. • A vendor presented the O2 generators as non-haz. – If ValuJet staff had been properly trained, they would have connected "oxygen generator" with the definition of "Oxidizer" Hazard Class, and refused the shipment. • If they had known to refuse the shipment it would have saved 110 people's lives.
    9. 9. Recent Regulatory Activity DOT Standard Penalty Description of issue 49 CFR 172.702 $860,000 OEM - 6 boxes containing shock absorber or paint 49 CFR 172.702 $192,500 Valvoline – 1 box containing 4 gallons of tire dressing 49 CFR 172.702 $150,000 OEM – 1 fuel pump with residual fuel 49 CFR 172.702 $72,000 OEM – 12 containers of Tire and Wheel Cleaner 49 CFR 172.702 $59,500 OEM – 1 Lead Acid Battery
    10. 10. Dealer shuts down FedEx Facility
    11. 11. Regulatory Procedures 1. Go to Airports 2. Pull HazMat Shipping Papers 3. Visit facility and audit signer of air bill 4. Call 24 hour emergency # while on site 5. Audit facility programs and procedures
    12. 12. The Audit • Function specific training completed • List 24 hour shipping hotline • Recertified every 3 years • Certified within 90 days of hire
    13. 13. Hazardous Material Definitions Hazardous material (Hazmat), means a substance or material, which has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated. The term includes hazardous substances, hazardous wastes, marine pollutants, and elevated temperature substances.
    14. 14. Hazardous Material Definitions Hazmat Employer means a person who uses one or more employees in connection with: – Transporting hazmat in commerce; or – Causing hazmat to be transported or shipped in commerce; or – Representing, marking, certifying, selling, offering, reconditioning, testing, repairing or modifying packaging as qualified for use in the transportation of hazmat
    15. 15. Hazardous Material Definitions Hazmat Employee means a person who is employed by a Hazmat employer and directly affects hazmat transportation safety including: – An owner-operator of a motor vehicle which transports hazmat – A person (including a self-employed person) who: – Loads or handles hazmat; – Tests, reconditions, repairs, modifies, marks, or otherwise represents packaging as qualified for use in the transportation of hazmat; – Prepares hazmat for transportation; – Is responsible for safety of transporting hazmat; or – Operates a vehicle used to transport hazardous materials
    16. 16. Training Requirements DOT Hazmat employees must receive training: • Within 90 days of new hire • Every 3 years • When proficiency or understanding is not demonstrated DOT Hazmat employees must receive the following training: • General Awareness Training • Function Specific Training • Security Awareness Training
    17. 17. 24 Hour Emergency Contact Information • Monitored at all times the hazardous material is in transportation, including storage • The person monitoring the number has knowledge of the material and emergency response information • Placed on hazardous material shipping papers
    18. 18. Regulatory Update Third Party 24 Hour Emergency Number • Must link back to original Shipper • Facility Name on Shipping Papers • Account Number on Shipping Papers
    19. 19. Recordkeeping Maintain your DOT Hazmat Training information and certificates – Certificates must be kept for 3 years for current employees and 90 days for employees that have recently resigned Add Training to Parts employee new hire packet and those signing hazardous materials shipments
    20. 20. The Hazardous Materials Regulations The process of complying with the HMR centers around the Hazardous Materials Table (HMT):
    21. 21. Filling out the Shipping Paper Basic Description 1. Identification Number..... UN 1090 2. Proper Shipping Name.... Acetone 3. Hazard Class/Division..... 3 4. Packing Group................ PG II
    22. 22. Shipping Papers Hazmat entries must include: •Basic Description •Total quantity shipped •Any additional data •ER information •Certification
    23. 23. Airbags - Regulatory Update Notice of Proposed Rulemaking (not law yet) • Bulk Airbag Shipping – Special Permit Procedures • Removal of EX numbers for Airbag Shipments • Special Exemption not required
    24. 24. Consumer Commodities – Regulatory Update DOT aligning with International Standards • ORM-D being phased out 1/19/2011 – 12/31/2012 – ORM-D-Air eliminated – 12/31/2013 – All ORM-D shipments eliminated • Re-classified as limited quantity or Class 9 Ground ltd qty marking Air ltd qty marking
    25. 25. FedEx & UPS Update Carriers standardizing shipping papers • HazMat paperwork must be submitted electronically. – Use either carrier software or approved custom software Shipping by air or international? • HazMat paperwork must be prepared using software with compliance checks.
    26. 26. Specification Packaging To Be Designated as a “DOT Approved Container” HM Containers Must Meet Performance Tests United Nations symbol UN1A2/Y/S/100 Type of container Packing group Container is for solids Packaging will have a Certification # •DROP TEST •LEAKPROOFNESS TEST •HYDROSTATIC PRESSURE TEST •STACKING TEST
    27. 27. Labeling • Identify & communicate the hazards within the package • Correspond to the hazard class/division of the material in the package • 24 different DOT labels • Column 6 of the HMT (172.101) determines the label(s) required for a material
    28. 28. Shipments by Air • IATA Dangerous Goods Regulations • FedEx and UPS Requirements • International Shipments • Increased scrutiny
    29. 29. Parts Trucks and Mobile Service • Materials of Trade (MOT) exemption • Shipping Papers and Emergency Response • Exempted materials • Interstate Commerce
    30. 30. Training Options • Online • Offsite • Onsite
    31. 31. New KPA Course • Completely redesigned • More engaging interactions • Recertification Test-Out – Faster job function changes • Reduced Course Time • More Resources