have we been?
We’ve been working
our tails off! While the economy may be down our business continues
to grow. Due to increased scrutiny by the FAA and USCG there has
been increased demand for compliance packing and documentation for
dangerous goods. As enforcement officers inspect more shippers,
forwarders, and warehouse operators, Hazmat training demands have
also increased, particularly in-house training programs.
Because of the increased demand for hazmat training we are adding
a three day initial training class for Dangerous Goods by
Air to our June schedule - June 23-24-25 (Monday-Tuesday-Wednesday).
Check your training records -
Our next recurrent training classes for air are June 2 and August
12. Mandatory new security awareness training has been added to
Check our “Links” at the top
right hand side of our Welcome Page -
Go to our FAA link and review the fines issued by the FAA. Most
of the fines refer to the fact that the shipper did train his employees.
We’ve had a lot of homework to take
care of -
Here are the security initiatives that U.S. businesses have to cope
with in the immediate future:
(Copied from the U.S. D.O.T./RSPA website)
- Risk Management Self-Evaluation Framework
including security template.
- RSPA-03-14982 (HM-232C); Hazardous Materials: Enhancing
Hazardous Materials Transportation Security; Interim
Final rule and request for comments; Published 05/05/2003; 68
- FMCSA-2001-11117; Limitations on the Issuance of Commercial
Driver's Licenses with a Hazardous Materials Endorsement;
Interim final rule and request for comments; Published 05/05/2003;
68 FR 23843.
- TSA-2003-14610; Amendment No. 1572-1; Security Threat
Assessment for Individuals Applying for a Hazardous Materials
Endorsement for a Commercial Drivers License; Published
05/05/2003; 68 FR 23851.
- RSPA-02-12064 (HM-232); Hazardous Materials:
Security Requirements for Offerors and Transporters of Hazardous
Materials; Final Rule; Published 3/25/03; 68 FR 14509. (see more
- FMCSA-02-11650 (HM-232A); Security Requirements
for Motor Carriers Transporting Hazardous Materials; Notice; Published
3/19/03; 68 FR 13250.
- FMCSA-02-13376; RSPA-02-12773 (HM-232B); Revision
to Periodic Tire Check Requirement for Motor Carriers Transporting
Hazardous Materials; Final rule; Published 10/4/2002; Effective
Date: November 4, 2002; 67 FR 62191.
- FMCSA-02-11650 (HM-232A) TITLE: Security Requirements
for Motor Carriers Transporting Hazardous Materials; Supplemental
advance notice of proposed rulemaking; extension of comment period;
Published 10/8/2002, 67 FR 62681.
- FMCSA-02-11650 (HM-232A) TITLE: Security Requirements
for Motor Carriers Transporting Hazardous Materials; Advance notice
of proposed rulemaking (ANPRM); Published 7/16/2002, 67 FR 46622.
U.S. Hazmat Cargo Security Regulations – effective
After many months of waiting, HM-232 RSPA-02-12064 (final
rule) was published on March 25, 2003 with the effective
date also being March 25. Within 90 days of the effective date,
shippers, forwarders, carriers, and warehouse operators who offer
or accept hazardous materials/dangerous goods must provide a Hazmat
Transportation Security Awareness program to all hazmat employees.
Companies who are required to be registered in the DOT/RSPA HAZMAT
Registration Program must also institute a more extensive Hazmat
Security formal (written) training program dealing with risk assessment,
methods of mitigating theft or sabotage, building and vehicle security,
employee background checks, and other issues. You can view the final
rule directly from here – RSPA-02-12064
DOT/RSPA permits copying of its Security Awareness CD Program.
We use that CD in our initial and recurrent training programs and
we furnish copies to each company that sends employees to us for
air, highway, and ocean dangerous goods training. A test is not
required for this phase of the training. However, our clients are
reminded that they should have other employees view and work with
this interactive CD. Make sure you add this feature to your training
record files for each employee. Although HM-232 applies to Hazmat
Employees we suggest that the general awareness program should be
voluntarily applied to all employees.
New Proposed Hazmat Training Requirements for U.S. Air
Carriers (Part 121 and 135) and their subcontractors, and Part 145
Docket Number FAA-2003-15085.
The FAA is proposing detailed training requirements, expanding
the curricula, adding categories of employees that will need training,
extending training to FAA-approved repair stations, and communicating
to employees, subcontractors, and repair stations whether the carrier
will or will not carry hazardous materials (dangerous goods).
Air carriers will be divided into two groups – those who
will carry dangerous goods, and, those who will not
carry dangerous goods. Both types of carriers will be required to
do more extensive training in identifying undeclared dangerous goods.
Subcontractors providing freight and/or baggage handling services
will be required to train all of their employees who perform any
those functions. Supervisory employees of both the carrier and the
freight and baggage subcontractors will have to receive more extensive
As in the past, the training programs must be approved by the FAA,
and the present mandatory one year recurrent training requirement
will continue to apply to the U.S. Flag Carriers and the subcontractors.
Dangerous Goods –
Whether you are a shipper or a carrier or anything related to them
your employees must be able to recognize dangerous goods. Many years
ago, long before we ever dreamt of using computers, when we thought
a website was the place where spiders hung out, we used to send
a monthly note along with our invoices alerting transportation related
people about hazardous materials that the average person frequently
overlooks in terms of regulations. While we may bore some of you,
others may well stop and say “I never thought of that.”
Going back all the way to 1976, when we opened out business, we’ll
start off with this list. If you would care to make additional suggestions
you can e-mail us at email@example.com.
power chain saws
spot and stain removers
swimming pool chemicals
automobile & aircraft engines
power lawn mowers
electric wheel chairs
perfumes & colognes
cough medicine with alcohol
alcoholic beverages, 141
proof or higher.
Beer, wine, and carbonated
beverages are not regulated.
Hazard Class 4 -
A Number of months ago a frequent visitor to our website pointed
out that we never addressed class 4 in our monthly attempts to help
people who handle dangerous goods to better understand the classification
system and the potential dangers concerning these hazard classes.
- Flammable Solids are solid materials that ignite by friction
or are easily ignited, such as:
MATCHES – IGNITE BY FRICTION, and,
STERNO – EASILY IGNITED
Flammable Solids also consist of substances that
“Wetted” Explosives…also known
as “Desensitized” Explosives.
These chemicals are explosives in the dry state and capable of exploding
when subjected to sudden shock or impact. They are downgraded to
division 4.1 when they are submerged in water or a phlegmatiser
is added to insure stability and reduce the sensitivity to impact.
They become less sensitive to shock because of their mud-like state.
Urea nitrate is an example of this type of chemical.
As a dry solid it is a 1.1D explosive, meaning it is capable of
an instantaneous explosion. Adding 10% or more water and/or phlegmatiser
reduces the explosion risk, allowing the product to be downgraded
to a flammable solid, division 4.1
What is a “phlegmatiser”? We thought you might ask.
It is a solid or liquid that is added to explosives and organic
peroxides to reduce sensitivity to impact.
Flammable Solids also include,
“Self-Reactive” Substances –
materials that are prone to exothermic reactions, a self-accelerating,
very rapid fire as opposed to an explosion. Self-Reactive Substances
are sensitive to sunlight and heat and are considered to be extremely
You won’t find these chemicals listed by their names in any
of the dangerous goods tables. You will find them listed according
to chemical name, concentration (%), control and emergency temperatures,
and U.N. identification numbers. The % and the temperatures are
critical to safety in transportation and storage. The listings can
be found in 49CFR 173.224; IMDG, Volume 1, 184.108.40.206.2.3; IATA Appendix
C-1; ICAO 2-4-4, Table 2.6; and ADR, Volume 1, Part 2, Chapter 2.2,
If the chemical name and/or formulation are not listed in those
tables the National Competent Authority must be consulted for shipping
advice, in writing.
Caution: since temperature is a significant factor in transporting
these items safely they are frequently shipped in refrigerated containers
or vehicles. Additional cautions must be indicated on the packages.
Handling and location in storage are extremely important. Warehouse
employees must be constantly alert to the presence of these materials.
Note: All Proper Shipping Names begin with the phrase “Self-Reactive
Liquid” or “Self-reactive Solid” but you must
start from the appropriate table for proper identification.
Substances that are liable to spontaneous
Solid materials that retain heat from the manufacturing process
or from the transportation environment and may self-ignite, such
as coal, charcoal or carbon, and, pyrophoric liquids or solids that
ignite when exposed to air. They do not need a source of ignition.
Oily fabrics and fibres and human or animal hair are good examples
of spontaneously combustible substances. As the fibre breaks down
due to decay it builds up heat and then ignites. Note that “fibres”
are further identified as animal, vegetable, or synthetic, with
As with the self-reactive substances, package integrity is vitally
important to safety. Frequently these spontaneously combustible
substances must be packaged under a blanket of nitrogen gas, which
is used to displace air (oxygen) from the packaging.
Substances which, when in contact with water,
emit flammable gases (Dangerous When Wet)
Calcium and Sodium are two classic examples of dangerous when wet
Calcium, when exposed to moisture, releases hydrogen gas (a flammable
gas). Pretty dangerous.
Sodium, when exposed to moisture, ignites and is a severe fire
risk. Very dangerous.