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June 2004 Newsletter
News Archive
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New Look -
We hope you like our website's new look. We hope that it will be easier to navigate.

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 general public.

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 security.

Check our “Links” at the top right hand side of our Links Page -
We have some valuable information for aircraft mechanics and stock room clerks.

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 -
RSPA-02-12064 (HM-232) <http://hazmat.dot.gov/68fr-14509.pdf>

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.


Proposed 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.

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