Some critical dates that you can not ignore -
September 25, 2003 -
If you are required to be registered with the U.S.D.O.T./RSPA as
a Offeror or Carrier of Hazmats (Dangerous Goods) you must have
a formal security program prepared and in place by September 25th.
The highlights are as follows:
(We have edited U.S. 49CFR 172.800 through 172.802 for brevity)
By September 25, 2003, each person who offers for transportation
in commerce or transports in commerce one or more of the following
hazardous materials must develop and adhere to a security plan for
hazardous materials that conforms to the requirements of this subpart:
(1) A highway route-controlled quantity of a Class 7 (radioactive)
material, as defined in § 173.403 of this subchapter, in a
motor vehicle, rail car, or freight container;
(2) More than 25 kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive)
material in a motor vehicle, rail car, or freight container;
(3) More than one L (1.06 qt) per package of a material poisonous
by inhalation, as defined in § 171.8 of this subchapter, that
meets the criteria for Hazard Zone A, as specified in § 173.116(a)or
173.133(a) of this subchapter;
(4) A shipment of a quantity of hazardous materials in a bulk packaging
having a capacity equal to or greater than 13,248 L (3,500 gallons)
for liquids or gases or more than 13.24 cubic meters (468 cubic
feet) for solids;
(5) A shipment in other than a bulk packaging of 2,268 kg (5,000
pounds) gross weight or more of one class of hazardous materials
for which placarding of a vehicle, rail car, or freight container
is required for that class under the provisions of subpart F of
(6) A select agent or toxin regulated by the Centers for Disease
Control and Prevention under 42 CFR part 73; or
(7) A quantity of hazardous material that requires placarding under
the provisions of subpart F of this part.
At a minimum, a security plan must include the following elements:
(1) Personnel security. Measures to confirm information provided
by job applicants hired for positions that involve access to and
handling of the hazardous materials covered by the security plan.
(2) Unauthorized access. Measures to address the assessed risk
that unauthorized persons may gain access to the hazardous materials
covered by the security plan or transport conveyances being prepared
for transportation of the hazardous materials covered by the security
(3) En route security. Measures to address the assessed security
risks of shipments of hazardous materials covered by the security
plan en route from origin to destination, including shipments stored
incidental to movement.
(b) The security plan must be in writing and must be retained for
as long as it remains in effect. Copies of the security plan, or
portions thereof, must be available to the employees who are responsible
for implementing it, consistent with personnel security clearance
or background investigation restrictions and a demonstrated need
to know. The security plan must be revised and updated as necessary
to reflect changing circumstances. When the security plan is updated
or revised, all copies of the plan must be maintained as of the
date of the most recent revision.
January 1, 2004 -
The Air Eligibility Mark
This mark will be required on all packages of dangerous goods
that are offered for shipment by air with the exception of "Dangerous
Goods in Excepted Quantities" (see IATA 2.7 for Excepted Quantities
and 49CFR 173.4 for small quantity exceptions).
Be careful. Don't be cavalier about that mark. The mark means that
the person who places the mark on a package is certifying that all
the extra packaging requirements for air have been complied with.
This includes such items as a leak proof liners for hazardous liquids
in combination packaging; compatibility of the packaging with the
dangerous goods that are being shipped; requirements for absorbent
material; positive means of holding closures, stoppers, corks, and
friction-type lids in place; the quantity limitations for inner
and outer packagings; the ability for inner packagings of dangerous
liquids to withstand inner vapor pressure requirements; the ability
to withstand vibration, pressurization and temperature changes.
The mark also means that the packages were specifically tested for
shipment by air.
U.S. Domestic shippers that ship "Consumer Commodity - ORM-D"
and air shippers of "Consumer Commodity, ID 8000" should
pay particular attention to this mark. For more information about
the Air Eligibility symbol refer to our April 2002 newsletter. Click
Dangerous Goods Advisory Council -
If you have been reading our newsletters, every newsletter since
November 2001, with the lone exception of our April 2002 Newsletter,
has dealt with security issues in one form or another. In one newsletter
we quoted a line from a long ago radio-movie-TV comic by the name
of Jimmy Durante. Most of our younger website visitors never heard
of him. The quote was "Everybody is trying to get into
the act." It is still appropriate almost a year later.
Much of the dangerous goods shippers and carriers bewilderment is
due to the fact that almost every single U.S. Government Agency
and local governments have enacted a security program. Most of those
programs are at odds with each other. Some appear to be impossible
to live with and to carry on any semblance of routine business.
And it is indeed difficult to understand them all. The Dangerous
Goods Advisory Council will help us understand the most difficult
of these security initiatives - U.S. D.O.T./RSPA HM-232.
The conference will be held in Arlington, Virginia on November
13 & 14, 2003. DGAC Members and interested and frustrated non-members
are welcome. We recommend that all of our website visitors attend
this important conference. We hope to see you there.
For more information about the conference, click on the following
the Maze of Dangerous Goods Regulations"
2003 DGAC Annual Conference and Hazardous Materials Transportation
Exposition, November 13 & 14, 2003, Arlington VA
The events of September 11, 2001, had a dramatic impact on the regulations
that govern the transportation of hazardous materials. The publication
of the US Department of Transportation's Security Requirements for
Offerors and Transporters of Hazardous Materials has given the hazmat
transportation industry cause for concern regarding their implementation.
Regulators and industry representatives from all modes will be on
hand to discuss the impact on new security/safety issues. The conference
will be held at the Hyatt Regency Crystal City, 2799 Jefferson Davis
Highway, Arlington VA 22202, 702/418-1234.
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