your training records:
In the January/February 2004 issue of HAZMAT Packager & Shipper,
this informative magazine conducted an interview with John O'Connell,
Chief of Enforcement, Office of Hazardous Materials Enforcement,
Almost every newsletter we put on our website mentions "check
your training records." The article in Hazmat Packager and Shipper provides some enlightening
comments concerning enforcement of the dangerous goods regulations
in the United States. One of the more interesting comments by Mr.
O'Connell indicated that his inspectors check the written training
record for compliance, the subject matter, the materials used in
the training, observe the hazmat activities of the employees, and
interview the employees to verify their level of competence. He
also said that inspectors may ask for the written test "to
determine if the number and range of questions covers the company's
scope of operations."
Since April of 1993 all training records issued by R-A Specialists
have had the written test attached to the record. The record itself
lists the employee's test score, the subject matter covered in
the training program the materials used in the program, and the
location of those materials. The document is clearly marked Training
Record, not to be confused with a Training Certificate, which is
a document suitable for framing, that the employee may display
in his or her office or worksite. But, the RECORD, with the test
attached, is the document that is to be presented to the inspector.
In our certification that the employee received a certain number
of hours of training, we also note that the original training
record is the only document that should be presented to enforcement personnel.
Photo copies should not be used.
In the certification that we sign to verify that the employee
was properly trained, we note that the original training record,
not a photo copy, should be presented to enforcement personnel
for inspection. Sadly, it has been reported back to us that unscrupulous
individuals have photocopied the records and changed names in order
to falsely indicate that a large number of employees have been
When the training records are presented to the hazmat employer,
he or she is instructed to countersign the record to verify that
the employee attended the training.
If the employee fails the test, we bring them to our office for
additional tutoring and when they are comfortable enough to take
another test, we give them a different test. If the employee fails
the second test, we give them one more try. Second and third tests
are not easier than the first test since the employee has received
anywhere from 4 to 8 hours of additional training.
Many thanks to HAZMAT Packager and Shipper for an excellent article
and splendid publication. For quite some time they have been featured
in our "Links" (at the top of our welcome page). Their
website is www.hazmatship.com
Feel free to visit their website and request a complimentary,
no-obligation review copy of the publication.
Security, security, security,
We can't remember when we last put out a newsletter since 9-11
that didn't mention security. Just about every U.S. Department
and/or Administration has issued a requirement for a security
program by shippers, carriers and warehouse agencies.
Pay close attention to all U.S. Government agencies that you may
deal with. While it won't work for larger companies, smaller companies
may want to explore the possibility that one security program might
fit every Federal (and sometimes state and local) requirement.
Our training programs cover Hazmat Transportation General Awareness
training and the CD that we issue may also be helpful for other
government agencies. You have a requirement to set up a formal
training program if you ship or carry certain dangerous goods.
Make sure that you are in compliance.
Highway - new hours of service rules are in effect
Highway - CDL's with Hazmat endorsements require
a security background check conducted by the state that issues
the license. Drivers should file as soon as possible after receiving
their renewal application.
Air - the air eligibility mark is not required - ICAO and IATA have issued addendums
to the rule.
The following excerpt is from Transport Canada’s Fall/2003 Newsletter.
For visitors who have not used our link to Transport Canada, we think it’s
worth reproducing here.
Civil Aviation Dangerous Goods Public Awareness Stakeholder Committee
By Roger Lessard
Each day, products defined as dangerous goods are transported
within Canada. It is essential for the public, government and industry
to continually work towards minimizing the risks involved in the
transportation of these goods through the application of safe practices.
Many common items used everyday in the bathroom, kitchen, and
garage, for hobbies or for work may seem harmless, however, due
to their physical and chemical properties they can be very dangerous
when transported by air. As a general rule passengers are not permitted
to transport dangerous goods on board an aircraft in their carry-on
or checked baggage. However, incidents and accidents caused by
dangerous goods in carry-on or checked baggage or being shipped
undeclared do happen:
A soap-dispensing bottle containing acid (drain purging liquid) leaked its
contents when an overhead bin was opened after arrival at the airport. Two
passengers were transported to the hospital and treated for third degree burns.
Three flight crew, the airport Customer Service Manager and one paramedic were
overtaken by fumes and also hospitalized. Before it could be cleaned the fluid
had damaged the overhead bins, the seats, the floor and the baggage hold below.
An undeclared flammable liquid in a passenger's luggage inadvertently
ignited in the cargo locker of a DHC-6 Twin Otter 300 causing an
in-flight fire. Two crew members and all 13 passengers were killed.
A nine-volt battery shorted out against a piece of metal causing
a pilot's flight case to overheat and explode in the baggage compartment
of a Cessna 182.
A miss-declared fibreboard drum containing five gallons of 50 % hydrogen peroxide
and 25 lbs. of a corrosive agent leaked during a flight on a DC-9 causing an
in-flight fire in the cargo compartment. Just before landing smoke began to
fill the passenger cabin.