In our daily jobs, particularly within distribution centers and creating transport packaging, encountering hazardous material happens more often than we're aware. Certainly more education on the subject is required. At the very least we need to know enough to want to learn more. There's a temptation to think handling dangerous material doesn't apply to what we do. Think again.
Experts engaged in handling hazardous material say, when it comes to packaging and shipping hazardous material, the number one rule is to follow the rules. The number two rule, in case there is any confusion, is to re-read rule number one.
Here are a couple recent examples of folks who did not follow the rules. I picked these up from the newswires.
A New Jersey company was fined $500,000 and its vice president sentenced to a month in prison for criminal violations of the Hazardous Material Transportation Law. It seems that in May 2004, the company, and said officer, admitted it had transported more than 10,000 shipments of flammable butane canisters and gas-charged lighters in unmarked packages via ground delivery services in violation of Department of Transportation (DOT) regulations.
Then there's the case of the former Emery Worldwide Airlines. In December 2003 it pleaded guilty to 12 counts of violating federal hazardous material laws by failing to identify shipments properly. The carrier was eventually fined $6 million.
What's the common denominator here? A cynical person might say stupidity. More than likely it's a combination of greed and the fact that someone didn't read the rulebook.
Carriers and shippers handling hazardous material are required to transport the material in accordance with the Hazardous Material Regulations, 49 CFR Parts 171-179. Under these regulations, shippers have the option of complying with either part 171-179 or the regulatory requirements found in the International Civil Aviation Organization's (ICAO is the United Nations agency concerned with civil aviation) Technical Instructions for the Safe Transport of Dangerous Goods.
To ensure compliance, special agents periodically inspect and conduct investigations of violations. The regulations are inter-modal, applying to ground, sea, rail and air.
Granted, reading the rulebook on proper handling of hazardous material can be a challenge. Defining hazardous material seems to be a moving target. What's hazardous today was not so bad yesterday. And there are plenty of different rulebooks to read. Ignorance, however, is no excuse; it's curable. Stupidity is not.
In our brave new world, new federal regulations are affecting domestic and international shippers of hazardous material now and will do so for years to come. DOT Docket #HM215-E for example, which became effective last fall, makes all shippers of hazardous material responsible for strictly following the manufacturer's closure instructions that accompany all DOT and UN marked packages. Significantly, it's shippers who are required to assure that proper closure procedures have been followed. DOT goes even further in suggesting shipper verification of container closure prior to shipment.
"Container closure instructions are not generic," says Chris Hilty, vice president for ENPAC (Eastlake, Ohio). ENPAC's products provide visual verification of container closure on screw-top salvage drums, among other things.
The intent of the regulation is that shippers should be extra vigilant to use the correct packaging for spilled or leaking hazardous material. And it seems carriers are paying attention. Material handlers in the country's small-parcel sortation hubs are getting better at spotting, or sniffing, hazardous material. In February 2003, the Federal Aviation Administration went after Tristar (San Antonio, Texas), alleging it improperly offered a fiberboard box containing four spray bottles and four aerosol cans of perfumery products, all flammable liquids, to United Parcel Service for transportation by air. Ground handling employees at the UPS sort facility in Louisville, Ky., discovered the shipment. Tristar offered the hazardous material for transportation when it was not packaged, marked, classed, described, documented or in condition for shipment as required by regulations.
In a similar case, also in February 2003, the FAA alleges that Coty improperly offered a fiberboard box containing 27 two-ounce glass bottles of perfume, a flammable liquid, to FedEx for transportation by air. Ground employees at the FedEx sort facility in Atlanta discovered the shipment leaking.
Handling hazardous material transcends issues of greed and making the bottom line look good. It's really about creating and preserving a safer world. When it comes to handling hazardous material, there are no excuses for not doing the right thing. Information and rulebooks are not hard to find in this age of instant communication. Get smart. Check out all the free stuff you can get at www.faa.gov and www.dot.gov.