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May 2005 Newsletter
News Archive
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Upcoming Dangerous Goods Training Dates at JFK

U.S. and International Transportation Laws require that any employee who prepares hazardous materials (dangerous goods) for transportation must be trained.

New Refrigerated Packing by R-A Specialists

We have been providing refrigerated packaging to the pharmaceutical, medical, food, aeronautics, chemical and electronics industries for 15 years. For the past year we have successfully developed and tested a larger palletized cooler that should solve a number of distribution problems in air freight.

Refrigerated (not frozen) testing consistently indicates a temperature range of 1.3°C to 15.0°C (34°F to 59°F) in summer weather over an eight day span. At six days the temperature is 7.8°C (46°F). Gel packs are used as the refrigerant.

Frozen goods can maintain temperatures of -38°C to -1.6°C for over six days under the same conditions. A single block of dry ice, weighing 25 kgs. maintains the sub-zero environment.

The inside dimensions are 114.3x68.6x73.7 cm. (45x27x29 inches, 20.4 C/F).

Smaller, equally effective coolers are also available.

There are no batteries to worry about; no rental fees; no deposits - you own it; no need to return the unit; it is re-usable for 2 or 3 roundtrips if handled with reasonable care. No reservations are necessary.

It is especially useful as an overpack for frozen or refrigerated diagnostic specimens and films and adhesives.

If you have a need for refrigerated packing contact us at info@r-a-specialists.com

LIMITED QUANTITY by Ocean

We get most of our ideas for these newsletters from phone calls that we receive.

As we were trying to get a head start on this month's newsletter we were interrupted by a young lady who worked for an NVOC. We had inspected a large shipment of aerosols for her company and after determining that the shipper had packaged the aerosols correctly we attached the markings required for UN 1950, Aerosols, Class 2, Limited Quantity. When the client's driver picked up the shipment and brought it over to their warehouse the YL (young lady to those that do not have a CB radio) called us to remind us that we did not put the non-flammable gas labels on the boxes. We referred her to the IMDG Code, 3.4.5 and 3.4.6 covering Limited Quantities. She did not have a copy of the Code. She also had never been trained. And she did not know that the ocean container had to be marked. And she was absolutely sure we were in error.

For any readers who are in the same boat (no, eh, yes, a pun is intended), this is the required mark for the boxes - yes, it looks like a label but it is officially a "mark." No other marks (or labels) are required other than the shipper and consignee's names and addresses.

The mark (above) is in compliance with the IMDG, U.S. D.O.T. and ADR/RID.

(Since Limited Quantities shipped by air require a hazard label the package must be marked to indicate "Limited Quantity" or "LTD. QTY.")

Security

This is the 21st Newsletter that we have featured security as a prominent topic since 11 September 2001. We also mentioned it at least one other time prior to 9-11 But it was not in the context of hijacking or using aircraft as weapons.

Since 9-11 we probably receive at least one e-mail or U.S. Federal Notice every business day. Most are "heads up" from Al Roberts, president of DGAC, but the Department of Homeland Security and the Transportation Security Administration and other government agencies have sent their fair share of notices as well. About 90% of our business revolves around Kennedy Airport (JFK) which is within the New York City limits so we are aware of frequent alerts issued by NYPD and the Port Authority of New York & New Jersey.

In the March/April 2005 issue of HAZMAT Packager & Shipper, our good friend and colleague Vincent Vitollo included two fascinating interviews with John O'Connell, Chief of Enforcement, Office of Hazardous Materials Safety, U.S. DOT, and Bill Quade, Hazardous Materials Division Chief, Federal Motor Carrier Safety Administration, U.S. DOT. The interviews were conducted separately.

There was a common thread in both interviews - Security.

Both gentlemen indicated that one of the most common violations of transportation law was "failure to have or adhere to a security plan."

Mr. O'Connell stated that of the 1200 inspections his inspectors have accomplished since July 2004 58% of those companies required formal security programs. Of that 58%, only 56.5% actually had complied with the security requirements.

We would remind all U.S. Hazmat employers that a Hazardous Materials Transportation General Awareness Security Training Program is mandatory for everyone who handles hazmats in transportation or causes hazmats to be transported. A formal program involving a written risk assessment, personnel security, unauthorized access and enroute security is mandatory for all individuals and corporations who are required to be registered under the U.S. D.O.T. Hazardous Materials Registration program.

For more information about HAZMAT Packager & Shipper go to http://www.hazmatship.com/


Our roots are in aviation so we remind our airline friends that:

Aircraft Pilot Notification
For the past two months our newsletters reminded air carriers that the dangerous goods/hazardous materials pilot notification form must now include a 24 hour emergency phone contact for any dangerous goods loaded on board the aircraft. We would remind shippers and carriers that international access and area codes should be included with the phone number. U.S. "800" numbers can not be dialed from points outside of North America.

Air Carriers must maintain a copy of the pilot notification at their principal place of business or at the airport of departure for at least 90 days.

If the airport of departure is not the carrier's "principal place of business" (home base) the carrier must keep a copy of the pilot notification readily accessible until the flight arrives at the destination airport.

Speaking of 24 hour emergency phone contacts - we are climbing back up on our soapbox once again.

Solar Case Revisited

Back in June 2004 we noted that the U.S. Federal Railroad Administration had referred criminal charges against Solar International Shipping Agency, a rail freight consolidator, for supplying false information on shipping papers for a rail consolidation. The false information allegedly was the 24 hour emergency phone contact provided by the actual shipper. Solar supposedly used the Chemtrec 800 telephone number but the agency was not a Chemtrec member, while the actual shipper presumably was a member. Since June '04 some of the charges were dropped but the U.S. Department of Justice filed another criminal indictment against Solar last month.

Transposing the 24 hour emergency phone contact from the actual document used by the shipper identifying his hazardous shipment to truckers pros, bills of lading, ocean and air declarations used by countless carriers, forwarders and consolidators happens thousands of times a day.

This makes us wonder how and when the phone contact is actually used. Do emergency responders really use the phone contact? Or do they rely more on placarding and labeling and shipping papers to determine the correct response? We would welcome comments from emergency responders about this issue.

Emergency responders can reach us at info@r-a-specialists.com

Some of the issues that we worry about are identification of the actual product that is being shipped. What is the appropriate first response to a transportation spill, fire or explosion?

Using UN 1133, Adhesives, Class 3, PG II, as an example, one of our customers produces close to 100 different adhesives for perhaps 20 or 30 different uses. Each adhesive requires a unique response to a variety of different scenarios. Since the shipping document has limited space available, the shipper is likely to indicate the basic description, types of packaging, and quantity of the material, plus a 24 hour phone contact. How would the shipper of 100 different adhesives, with differing emergency responses, quickly identify the specific product involved in an accident? Better yet, how would Chemtrec or Chemtel or Infotrac know which MSDS to bring up on their computers in order to assist the emergency responder?

If the shipper provides additional information such as manufacturer's name and product number, along with the 24 hour phone contact, does that provide the necessary information for a speedy initial response? Would computerized bills of ladings and declarations be able to handle the additional information? Probably not.

What if the shipper is not the manufacturer? Suppose he ships a variety of dangerous goods from a variety of manufacturers? The regulations are clear that when that occurs and different emergency response phone numbers are used the phone number should be listed in conjunction with the basic description. But how does that shipper avoid the same fate as Solar International? Is he providing "false information?"

Shippers, forwarders, consolidators and carriers are increasingly relying on a Material Safety Data Sheet (MSDS) as the principal safety document for transportation. The MSDS is generated by the manufacturer, not necessarily the same organization as the shipper. In view of the Solar case how does all of this sit with the enforcement personnel?

Adding to those problems are increasing numbers of carriers and states (national governments) that also require "emergency response information, including a 24 hour emergency phone contact with international access codes."

What we find is that the MSDS can be a valuable tool but unfortunately a majority of transportation people and lesser-trained emergency responders from poorer communities do not know how to read and interpret the valuable technical information. Are the MSDS's up-to-date?

Ever hear of John C. Morton? Our paths crossed a few times during the '80's and '90's. In 1998 he was the recipient of the prestigious George L. Wilson Award for outstanding contributions in the area of hazardous materials safety. The award has been presented annually by the Dangerous Goods Advisory Council since 1982.

John's passion was safety for the community and the emergency responders. His mission: provide emergency response guidebooks to third world emergency response personnel (firefighters, police, and medical responders). When he received his award he made an impassioned speech about how that immediate first response could save lives and property. He was in the process of trying to provide those guidebooks in local languages throughout the world. I don't recall John Morton requesting a phone number with international access codes or a MSDS.

Since 1998 have we become too high tech?

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