|May 2009 Newsletter
Have you checked your training records lately?
Click on TRAINING on our opening page in order to reserve your place now. Remember, if you ship, handle, or transport dangerous goods, U.S. Transportation Law as well as International Laws you must receive initial training and then recurrent training every two or three years thereafter, depending on the mode of transportation.
Warehouse and Driver Hazmat Training
The weakest link in hazmat compliance is the untrained warehouse employee and the untrained truck driver. Compliance in transportation actually starts with the driver that picks up the freight from the shipper. If he does not recognize errors in packing, marking, labeling or paperwork the entire system goes downhill from that point. If the driver gets stopped in a routine DOT Highway inspection and a shipment is not in compliance it triggers a number of possibilities. Delays, obviously. But the truck could also be taken out of service by police or DOT inspectors. If the truck should have been placarded but wasn’t – a fine. If the truck is placarded but the driver has no hazmat endorsement on his driver’s license – a fine and the truck is taken out of service.
But even if the first part of your cargo’s journey goes smoothly, the next few steps can be quite costly. Mishandling at the trucker’s or forwarder’s warehouse can cause damage to the cargo. If the damage is serious it can cause an “incident”, i.e., release of a hazardous chemical that can cause serious injury or property damage. If untrained personnel are handling the cargo such things as mislabeling or improper storage or misrouting the cargo surely will frustrate the shipper due to delays or repacking charges.
Aside from U.S. D.O.T. compliance issues, experience indicates that well trained employees not only handle the hazmat shipments safely but all types of claims are reduced – a significant financial savings for the trucker or warehouse operator. The better service also translates into loyal customers.
The U.S. D.O.T. (PHMSA) does not allow Lithium Metal Batteries (UN 3090) to be shipped via passenger-carrying aircraft. Refer to the revised USG-02 in the IATA Regulations and the ICAO Technical Instructions. This applies to the batteries only. The packages must be marked: “LITHIUM METAL BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT” and the package must bear the Cargo Aircraft Only Label.
However, DOT does permit Lithium Metal Batteries contained in equipment or Lithium Metal Batteries packed with equipment (UN 3091) to be shipped on passenger aircraft provided:
We remind everyone that Part 1 of those IATA packing instructions deals with “non-regulated” lithium metal batteries. Contrary to popular belief “non-regulated” does not mean non-hazardous or that no danger exists. If not packaged according to the regulations the shipper is in non-compliance and subject to severe penalties.
In P/I 969 and 970, at the end of Part 1, IATA advises that persons preparing or offering cells and batteries must receive adequate instruction on those requirements.
Part 2 of P/I 969 deals with fully regulated lithium metal batteries and cells packed with equipment and Part 2 of P/I 970 deals with fully regulated lithium metal batteries and cells contained in equipment. While the IATA Regulations permit carriage on passenger-carrying aircraft the U.S. Regulations do not. The packages must be labelled with the Class 9 label and the Cargo Aircraft Only Label.
If not packaged and labelled according to the regulations the shipper is in non-compliance and subject to severe penalties.
Our Soap Box
More Feedback from airlines
In the good old days before “fees” – the 1970’s – no one purposely cheated and it was a friendlier atmosphere between the carrier and the shipper. Everyone tried to help each other.
So? What about other types of batteries? With all the emphasis on Green Environmental Issues, how do we recycle batteries? Glad you asked. Click on this link: http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/2009_Battery_Safety_Compliance_Advisory.pdf
You must feel like you have batteries coming out of your ears.
Are you well known?
Apparently a single employee of a world recognized company with more than 50,000 employees who packs dangerous goods must be pretty well known. He shipped a dangerous goods shipment from Asia to the U.S. by air, and when typing his name and title on the dangerous goods declaration he listed his title as “person in charge”. The airline rejected the shipment for only one reason – “person in charge” was not an acceptable job title as far as the airline cargo agent was concerned. Was he in charge of the whole company? A division of the company? The facility that did the shipping? The shipping department? Or just the guy that was given the responsibility for that one package? We never did find out what he was “in charge” of.
Dangerous Goods Advisory Council
For over thirty years the DGAC has been a leader in promoting safety in transportation. The council has been an advocate for the chemical industry and transporters of dangerous goods/hazardous materials. Your company should seriously consider becoming a member of this outstanding organization.
Mark your calendar: