|March 2010 Newsletter
Upcoming Dangerous Goods Training Dates at JFK and on the web (All Feature Lithium Batteries)
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 by e-mail or telephone a few days prior to the class.
24 Hour Emergency Phone Contact
While the U.S. has relaxed the requirement for the 24 hour emergency phone contact a little, we note that a number of air and ocean carriers have instituted their own rules that are even more restrictive than the DOT’s rule. Carriers always require the international telephone access codes. U.S. Shippers should note that you cannot dial a U.S. 800 telephone number from overseas. You must use the access code 001 followed by the state are code and the local exchange number.
We would also remind shippers that they cannot use Chemtrec or Chemtel or other agency phone numbers unless the shipper is a member of one of those agencies.
Freight Forwarders should note that under 49CFR 172.604(b)(3) they are responsible for confirming that the shipper is registered with any third party provider of the 24 hour phone contact.
While the U.S. D.O.T. continues to use the term “shipping papers” the rest of us use terminology such as air waybills, bills of lading, manifests, dangerous goods declarations, etc. we remind you that the documents must be in order and drivers are just as responsible as the shipper, forwarder or air and ocean carrier for the proper completion of that paperwork. You are also reminded that hazardous materials paperwork must be on a clipboard on the driver’s seat or in a pouch on the driver’s door while you are out of the vehicle making a pick up or taking your meal break. If you have placards on the truck you must have a CDL with a hazmat endorsement. And, if you are required to have placards, your company must be registered as a Hazmat transporter with the U.S.D.O.T.
And make sure you did a safety inspection before leaving your terminal including checking that the cargo has been properly blocked and braced. Have a safe trip.
Warehouse Operators and Ramp Service Companies
If your company accepts dangerous goods, transports dangerous goods, stores or loads dangerous goods your employees must receive hazmat training. “It’s the Law!” according to the U.S. Department of Transportation and the United Nations. You can look it up.
Over many years we have mentioned feedback that we have received from warehouse managers or supervisors that when their employees have received training their claims for damaged general cargo as well as dangerous goods were drastically reduced. Not training your employees can be costly due to fines imposed by enforcement officers.
Last year’s PHMSA report on penalties cited 130 penalty actions with fines totaling $1,135,256. Of that total 36 cases involving fines of approximately $367,000 involved failure to train employees. That averaged out to $10, 196 per violation.
D.O.T. Hazmat Website
From time to time we check out the DOT/PHMSA website at http://www.phmsa.dot.gov/hazmat
U.S. Shipper and Carrier personnel should check the website frequently. First we examined the Enforcement link and much to our surprise there were a large number shippers listed for violations due to failure to register with the DOT as hazmat shippers in the most recent report (2008). Security plans also received a lot of attention.
If you are not registered with DOT/PHMSA you should check the following link - http://www.phmsa.dot.gov/hazmat/registration
Lithium Batteries (What? Again?)
What we look for in an MSDS for Lithium Metal Batteries:
Organizations governing the transport of lithium batteries
Their regulations are based on the UN Recommendations. Each special provision provides specifications on exceptions and packaging for lithium batteries shipping. The product can be transported as “Non Dangerous Goods” when they meet the requirements of packing instruction 968 section II or 969 section II or 970 section II of IATA-DGR (51st edition) or SP188 of IMO-IMDG Code.
Happy St. Patrick’s Day – we’ll see you at the NYC Parade.