John Dho, regulatory coordinator for the National Parts Division of American Honda Motor Co. Inc. (Torrence, Calif.), faces challenges shared by auto manufacturers, and others, in shipping parts that are classified as dangerous goods.
Dho’s challenges, however, are multiplied by the fact that American Honda not only ships auto parts, it also stocks and ships motorcycle, power equipment, marine and smallengine service parts. Dho oversees the regulatory aspects of shipping dangerous goods for Honda’s 12 U.S. parts distribution centers. The parts it stocks, like batteries, air bags, pretensioned seat belts, compressed gas articles, paints and service chemicals, are shipped worldwide to approximately 5,000 auto, motorcycle and power equipment distributors and dealers.
There are variables in shipping these dangerous goods domestically and internationally that are unique to vehicle and engine service parts. Because of this, the shipping process can’t always be fully automated. Sometimes, the variables depend on which airline is used for shipping.
Hazardous goods are packaged in non-bulk packaging, primarily fiberboard boxes. They may or may not be UN certified, depending on the content and quantity.
There are also international classification variations. For instance, seat belts and air bags are usually Class 9 hazards in the U.S.; however, they’re often 1.4 hazards in Europe. Shop chemicals are shipped as ORM-D (Consumer Commodity) hazards domestically but must be reclassified for international transport, often to Limited Quantity Compressed Gas or Flammable Liquid hazards.
It is mandatory that those doing the shipping understand these variables and are able to comply with stringent regulatory requirements.
Where to store hazardous material is always a challenge in distribution centers. American Honda manages hazmat inventory within specific zones. Parts centers are zoned for large and small hazardous materials. Hazard goods picking is done by people specially trained to handle hazardous material within specific zones dedicated for hazmat storage.
Several auto manufacturers have formed an ad hoc group to address some of these tough regulatory issues. Dho is one of the founding members of the North American Automotive Hazmat Action Committee (NAAHAC), a group of compliance specialists from the major automotive manufacturers of North America. The organization was founded in 1998 by several auto manufacturers to share information on issues they all have in common with respect to shipping parts classified as dangerous goods. NAAHAC has since grown to a membership of 28 regulatory compliance specialists representing automotive manufacturers and major suppliers. The organization works with regulatory agencies, like the U.S. Department of Transportation (DOT), to share information and formulate standards that increase public safety.
“Regulators cannot be expected to be experts in automotive parts,” says Dho. “Our organization, comprised of auto manufacturers and suppliers, can provide needed information on our products that affect both regulatory compliance and public safety. This exchange of information between regulatory agencies and manufacturers,” Dho continues, “results in better, more effective and more efficient regulations to ensure public safety.”
The shipping of hazardous goods is highly controlled and regulated, and the regulations governing these shipments are very detailed and complex. One of Dho’s primary responsibilities is managing American Honda’s dangerous-goods compliance program, including product identification, classification, training and certification of distribution center personnel directly responsible for shipping. This training is required for all personnel involved in shipping hazardous goods and must be completed when new employees are hired or job functions of existing employees change. Certification must be renewed every two years.
One of the tools that Dho uses, both for training and also as a resource for following the detailed regulations required for shipping dangerous goods by air, is a manual entitled A.I.R. Shipper Air International Regulations for Shippers of Dangerous Goods. A.I.R. Shipper is recognized by the International Civil Aviation Organization (ICAO) and has been developed in compliance with ICAO standards. (See box for more information on this important document.)
| Strict regulations control where and which labels will be placed on the carton by a certified operator. |
The manual was compiled and formatted to increase shippers’ efficiency and accuracy and reduce the time and cost involved in preparing dangerous goods for air transport.
Because there is so much regulatory information to be absorbed and strictly adhered to in the book, the format and presentation are important in both increasing readability and ease of use. The clean, uncluttered design and the larger type size are easier on the eyes. White pages with colored borders make the pages more legible when faxed yet provide a distinction between chapters.
Dho states, “The white pages are easier to read in a warehouse environment where high-intensity lighting tends to be used.” Margin notes provide helpful references to the regulations.
Dho says the wealth of material in the book is what makes it useful. “It’s the incremental improvements,” says Dho, “all small things in and of themselves, that make a big difference when you’re shipping thousands of parts on a regular basis. You need to look for ways to make the tasks simpler and increase efficiency wherever you can.”