Upcoming Training Dates at JFK
Note – because of the U.S. DOT/PHMSA Hazmat Security requirements and the huge volume of questions concerning U.S. Regulations for primary lithium batteries the recurrent air training classes have been running over the normal 8-hour session. Please be prepared for a nine-hour or longer day.
U.S. Hazmat Security
This is the 22nd Newsletter that we have featured security as a prominent topic since 11 September 2001. All Hazmat Employees must receive general awareness security training as part of their initial and recurrent training requirements. In addition to the general awareness training, a risk assessment and more formal security program and training may also be required. The additional program is mandatory if your company must participate the U.S. D.O.T. Hazmat Registration Program. Go to the DOT-PHYMSA Office of Hazardous Materials Safety site at http://hazmat.dot.gov/regs/register/register.htm
Hazmat Transportation Security General Awareness is included in all of our training programs.
Confusion continues to rule concerning “non-restricted” lithium cells and batteries as evidenced by the number of calls we receive each day. Usually the issue is the shipper or forwarder who is unable to understand the ICAO/IATA Special Provision A-45 and the overwhelming desire to use that provision because it will reduce the shipper’s costs. However strong that desire may be, it is no excuse to reduce safety in air transportation.
U.S. DOT/RSPA (RSPA is now known as PHMSA) introduced HM-224E on December 15, 2004 with an effective date of December 29, 2004, an incredibly short “advance” notice for implementation of a final rule. The rule prohibited shipping primary (non-rechargeable) lithium cells and batteries via passenger aircraft into/out of/within the U.S.
Responsible manufacturers and distributors immediately complied with the new emergency regulation. Unfortunately, some entrepreneurs or occasional shippers of lithium batteries were not privy to the U.S. Regulation while still others simply were not aware of the dangers related to lithium batteries and simply shipped them without ever mentioning that the batteries were part of a shipment.
If you ship or transport lithium batteries it would be in your best interest to invest a little over an hour of your time to read all of the comments submitted to the Office of Hazardous Materials Safety concerning HM224E. The DOT/PHMSA website can be reached by clicking on http://dms.dot.gov/search/searchFormSimple.cfm
When prompted refer to Docket 19886.
24-Hour Emergency Response Phone Number
Last month we threw out some questions about the real practicality of the 24-hour telephone number with international access codes. Although we invited emergency responders to give us an idea as to how often the number is used we also invited others to respond as well. We get between 700 and 800 visitors to our website every day. No firefighters responded.
We did get nine comments that brought our attention to potential advantages for that number when exposures to leaking chemicals occur. Of those nine, six raised the issue of the security implications from an intentional release by a terrorist.
When we raised those same questions at a recent training class one entrepreneur admitted that he used call waiting and call forwarding features on his cell phone and keeps it operating day and night. He also admitted that he had no idea how to lessen the severity of an accident involving his flammable liquids and, until he attended the class, he had no idea how to read a material safety data sheet.
Please send your comments to firstname.lastname@example.org
DGAC 27th Annual Conference
The Dangerous Goods Advisory Council will be holding its 27th Annual Conference in New Orleans on November 10-11, 2005. The conference promises to be exceptionally interesting and informative and in a great city with fantastic restaurants and a wonderful atmosphere. Watch for the official announcement and registration form towards the end of June on DGAC’s website at www.dgac.org
If your company is not a member you really should consider joining this outstanding organization. Membership applications are available on the website.