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Security and Hazmat Handling -
With all of the attention given to security since September, 2001,
HAZMAT training goals seemed to be pushed aside by small and
medium-sized companies. They are caught up almost daily by new
security initiatives by just about every government agency in
the United States and around the world. The scary part of this
situation is that nowadays major hazardous materials incidents
are almost always thought of as potential "terrorist" incidents
initially, causing suspicions by emergency responders and the
That can tie up valuable resources.
For example, on February 21, 2003, a gasoline tank farm on Staten
Island, NY, experienced an explosion and fire while a barge containing
100,000 barrels of unleaded gasoline was being unloaded.
"We thought we got hit by terrorists" was the immediate
thought of most of the residents of Staten Island and nearby areas
of New York City and New Jersey.
The NYC PD thought the same thing and immediately closed off all
the bridges to and from Staten Island and the famous Staten Island
Ferry - the valuable resources.
Later, CNN quoted Staten Island Borough President James Molinaro
as saying "It was an accident; no sabotage, no terrorism."
New York City Mayor Michael Bloomberg and the NYC Police described
the explosion as a "refueling accident" at the loading
dock. The smoke plume stretched for 94 miles.
Where have we been?
We’ve been working our tails off! While the economy may be
creeping along at a snail's pace towards improvement, our end of
the business remains brisk, thanks to our loyal customers. Due
to increased security scrutiny by the TSA, FMCSA, 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.
Check your training records -
Our next dangerous goods training class is recurrent training for
ocean shippers and forwarders on June 29. This class is limited
in size because the attendees need additional table space since
they will be working with a set of three IMDG books.
Our vacation period will be in July this year. Our next Dangerous
Goods by Air classes will be on 10 August for recurrent training
and August 17-18-19 for initial training.
All of our classes include the U.S. D.O.T. mandatory Hazardous
Materials Transportation Security General Awareness Training. Copies
of the D.O.T. program are also distributed to all attendees in
order to bring other employees up-to-date concerning hazmat cargo
Check our “Links” at the top right hand side of
our Links Page -
We have some valuable information for aircraft mechanics and stock
U.S. Hazmat Cargo Security Regulations - effective now!
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 that 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 -
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.
Hazmat Training Requirements for U.S. Air Carriers (Part 121
and 135) and their subcontractors, and Part 145 Repair Stations.
Docket Number FAA-2003-15085.
The FAA has proposed expanding the curricula, adding categories
of employees who 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 hazmat training.
As in the past, the FAA must approve the training programs, and
the present mandatory one year recurrent training requirement will
continue to apply to the U.S. Flag Carriers and their subcontractors.
There have been numerous comments about this proposed rule, including
some from non-industry sources such as concerned citizens.
The rulemaking procedure is moving along slowly. If you care to
review the comments they can be viewed at
24-Hour Emergency Telephone Contact -
A number of years ago, we recall FAA Security/Hazmat inspectors warning shippers,
forwarders, and air carriers that they should pay close attention to the
legitimacy of the 24-hour emergency phone contact listed on the shipping
documents. Shippers who did not belong to agencies like Chemtrec and Chemtel
were using the agencies' phone numbers to satisfy the requirement. Sometimes
they were encouraged to use the number by uninformed transportation personnel.
A number of fines were issued and it seemed to reduce the unauthorized use
of those numbers.
Now we have a new wrinkle in this procedure. Recently, a railroad
forwarding agent used the shipper's Chemtrec number on the bill
of lading as instructed by the shipper. A Federal Railroad Administration
enforcement officer found that the forwarding agent was not a member
of Chemtrec resulting in criminal charges being brought against
the forwarder. The basis of the criminal charges
was that the forwarder knowingly provided false information
on the bill of lading, i.e., the 24-hour phone contact.
At first glance it would appear that the forwarder was following
a routine that has been practiced by transportation companies in
all modes of transportation. Distributors and customers of chemical
companies routinely use the 24-hour contact listed on a material
safety data sheet as the appropriate contact in the event of an
emergency when they ship the hazardous chemicals to their own clients.
If FRA prevails in this case the ramifications in all modes of
transportation will be awesome.