|February - March 2008 Newsletter
Upcoming Dangerous Goods Training Dates at JFK and on the web
February 26-27-28, 2008 (Tuesday-Wednesday-Thursday) - OCEAN INITIAL
March 4, 2008 (Tuesday) - AIR RECURRENT
April 15-16-17, 2008 (Tuesday-Wednesday-Thursday) - AIR INITIAL
May 6, 2008 (Tuesday) - AIR RECURRENT
May 13 (Tuesday) - WAREHOUSE EMPLOYEES
May 20 (Tuesday) - HAZMAT IMPORTS
Our On Line Training Program for the Cosmetics Industry - available 24/7.
We have added a new training program for importers and customs brokers as a result of a number of requests that we received after a dangerous goods presentation that we participated in for the Long Island Import Export Association www.liiea.org
Our complete 2008 training schedule is available on the website - click on "Training" on the opening page.
Check your current training records - if you are close to the expiration date make your reservations now for any of our classes throughout the year. We always remind attendees a few days prior to the class.
Material Safety Data Sheets (MSDS) - New Service
Back in August of 2007 we noted that a single or two page MSDS just does not hack it anymore. Many of those documents that are presented to us for review are more than 10 years old and do not reflect transportation information or current environmental considerations.
Despite our mild complaints shippers and forwarders continue to tie up our e-mail addresses and fax machines with requests to decipher material safety data sheets. While we have offered MSDS interpretation as a free service to clients and non-clients for the past 31 years, we have reached the saturation point and we will be forced to charge a fee for the service effective 1 March 2008.
As is the case with your company, our time is precious to us as we try to serve our regular clients with training, consulting, documentation and packing services.
In order to continue the MSDS review service we will be charging an annual fee of $250.00. No limits will be placed on those companies that sign up for the service. All other requests will be denied with a statement that we regret that we can no longer provide the free service. Your company is encouraged to sign up and pay the fee via our website. Look for the link on our opening page.
As the saying goes - "garbage in - garbage out." In the past we have been unable to help clients when the MSDS lacks enough information to provide a responsible report or assessment. LET THE BUYER BEWARE.
We remind our training clients that your employees who have received dangerous goods training from us receive MSDS training as part of our regular curriculum and you may already have qualified employees on your staff who are ready, willing and able to read and interpret the MSDS.
Every employee of R-A Specialists has successfully passed TSA's Security Threat Assessment and Training Program.
Chemical manufacturers and storage facilities should note a revised regulation dealing with Chemicals of Interest. The U.S. Department of Homeland Security issued revised regulations as published in the Federal Register on November 20, 2007. While major chemical manufactures received notices directly from DHS or other sources such as the Dangerous Goods Advisory Council and Hazmat Packager there may be distributors or contract warehouse organizations that missed this important revision.
Mark Your Calendar
30th Annual Conference and Hazardous Materials Transportation Exposition
Check the DGAC website for additional information – www.dgac.org
If you are not a DGAC Member, you should consider joining this great organization.
“I’ve been shipping it that way for 30 years”
Most of us who have worked for carriers have heard that same old refrain countless times. We’re sure enforcement personnel have heard it too.
The only problem with that comment is that regulations have been changed, updated, and changed again numerous times over the past 30 years.
30 years ago. That would be the year 1978.
In 1976, U.S. D.O.T. consolidated all the hazardous materials regulations into 49CFR after U.S. Congress passed the Hazmat Transportation Act of 1975.
In 1978, IATA continued to update its regulations annually, and still does to this day. The International Maritime Organization, an agency of the United Nations continued to update its regulations as chemical technology continued to forge ahead.
By the mid ‘80’s ICAO – the International Civil Aviation Organization, another agency of the United Nations, set international standards for dangerous goods by air with its Technical Instructions.
From 1976 to the mid ‘90’s the U.S. D.O.T. was revising Title 49 at a dizzying pace and DOT finally adopted the international standards making marking, labeling, packing and testing standards the same world-wide.
If you are one of those shippers who have been shipping hazardous materials the same way for the past 30 years, go to http://www.phmsa.dot.gov Click on “Regulations” and look up “Final Rules”. You’ll see that 60 “Final Rules” have been issued by D.O.T. alone since 1998.
Since 1978, IATA has issued updated regulations 30 times.
The IMDG Code has been amended approximately 15 times and in 2002 went from 5 volumes to 2 volumes (plus the supplement).
We would really doubt that packaging and packing methods, quantity limits, marking and labeling and certainly documentation requirements have not changed for your product during the last 30 years (or less).
That is why the regulatory agencies have initial and recurrent training requirements.