4. Questions
• If you have questions
during the presentation,
please submit them using
the “Questions” feature
• Questions will be
answered at the end of the
webinar
5. 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
7. DOT HazMat Training
“...ensuring a fast, safe,
efficient, accessible 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
8. DOT HazMat Training
“...ensuring a fast, safe,
efficient, accessible 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
10. 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.
11. 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.”
12. 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.
13. Recent Regulatory Activity
DOT Standard Penalty Description of issue
49 CFR 172.702 $860,000 Toyota – 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 Honda – 1 fuel pump with residual fuel
49 CFR 172.702 $72,000 Chrysler – 12 containers of Tire and Wheel Cleaner
49 CFR 172.702 $59,500 Acura – 1 Lead Acid Battery
15. 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
16.
17. The Audit
• Function specific training completed
• List 24 hour shipping hotline
• Recertified every 3 years
• Certified within 90 days of hire
18.
19. 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.
20. 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
21. 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
22. 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
23. 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
24. Regulatory Update
Third Party 24 Hour Emergency Number
• Must link back to original Shipper
• Facility Name on Shipping Papers
• Account Number on Shipping Papers
25. DOT Hazmat Program
Use KPA binder to 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
26.
27. The Hazardous Materials Regulations
The process of complying with the HMR centers
around the Hazardous Materials Table (HMT):
28. Filling out the Shipping Paper
Basic Description
1. Proper Shipping Name.... Acetone
2. Hazard Class/Division..... 3
3. Identification Number..... UN 1090
4. Packing Group................ PG II
These four elements MUST appear in this order!
33. Shipping Papers
Hazmat entries must include:
•Basic Description
•Total quantity shipped
•Any additional data
•ER information
•Certification
34. 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
35. 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
36.
37. Shipments by Air
• IATA Dangerous Goods Regulations
• FedEx and UPS Requirements
• International Shipments
• Increased scrutiny
38. Parts Trucks and Mobile Service
• Materials of Trade (MOT) exemption
• Shipping Papers and Emergency Response
• Exempted materials
• Interstate Commerce
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.
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.
