Since 9/11 people have been paying more attention to dangerous goods. And in case it slips their mind, they are re-minded every time they travel by air. A person walking down a street might even consider an abandoned backpack a dangerous good. That said, people are not always aware that something THEY introduce into the flow of everyday life might be a dangerous good. Even companies that should know better—don't.
USA Today reported recently that a shipment of lithium-ion batteries caught fire as it was being loaded onto a FedEx jet at the company's Memphis hub in August 2004. According to the National Transportation Safety Board, the probable cause was unapproved packaging used by the shipper, AC Propulsion. The packaging "was inadequate" to protect the lithium, the NTSB said.
I talked to one of DHL Express's Hazmat experts about why hazardous material handling is such a difficult skill to master. Jerry Freeman, dangerous goods manager for DHL, told me there wouldn't be such confusion if dangerous goods regulations were consistent year after year. But the hazmat regs change quite often.
“What customers knew yesterday might change today and will change tomorrow,” he said. “When calls come into our hotline it's through that channel I learn that customers need to be educated.”
Sometimes the hazmat supply chain is like a game of telephone. That's where a message changes with each transfer along the line of communicators. By the time that message gets to the last person in the chain, it's a completely different message. In the same way, a shipper may receive a dangerous good from a supplier for shipment to another company which will ship it to a consumer. By the time that product gets down to the shipper that's shipping it for the final time, it's either not in its original packaging or it has otherwise lost its visibility as a dangerous good. That's the kind of thing that keeps Freeman busy.
“It's our hope that the training we provide gets to those kinds of shippers,” he said.
DHL will be rolling out training in 2011 to update shippers on international dangerous goods. The biggest new regulation takes hold in January 2011. The U.S. Department of Transportation issued a notice of proposed rulemaking earlier this year announcing changes related to the offering and handling of lithium batteries, both rechargeable ion and metal batteries. If the notice becomes final, he says, there will be significant changes impacting not just your typical dangerous goods shipper who ships chemicals and substances, but shippers of electronic equipment, as well.
This rule would change how and where lithium batteries are loaded into aircraft. The shipper will be responsible for executing the appropriate paperwork, getting the training, and implementing a security plan.
When in doubt about the nature of something you're handling, always refer to the Material Safety Data Sheet (MSDS). Freeman says most MSDSs include transportation regulatory information to help the shipper and the carrier determine if something is a dangerous good.
The customer should be looking at those documents to determine what they have in inventory that's regulated as dangerous goods.
And remember, what's reflected under U.S. law is not necessarily what you have to do under international law. It's your responsibility to understand what those variations are. Where lithium batteries are concerned, the International Civil Aviation Organization (ICAO) is a little ahead of the game in that the U.S. DOT's 49CFR doesn't fully regulate lithium batteries yet. Unfortunately what DOT is proposing with regard to those batteries will supersede ICAO's requirements, according to Freeman.
“A lot of what the U.S. laws state regarding dangerous goods over time have been based on incidents and by lobbyists,” he told me.
Guess that's good news for anyone offering hazmat training. That said, I'll play devil's advocate for them. Are you sure you don't have any hazardous goods in your warehouse or distribution center?