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August 2010 Newsletter

Upcoming Dangerous Goods Training Dates at JFK and on the web

  • Dangerous Goods by Air - Recurrent. August 10, THIS CLASS IS FULL The next class is November 30, 2010
  • Dangerous Goods by Air – Initial. August 24-25-26, THIS CLASS IS FULL The next class is December 14-15-16, 2010
  • Warehouse & Driver Hazmat training - Initia,l September 21
  • Domestic Cosmetics and Perfume Shippers On-Line Program available 24/7

In-House Training subject to schedule availability.

Our complete 2010 training schedule is posted on this website.

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.

Training – it’s the law!

Why driver and warehouse personnel need training -

June 5, Tulsa World – (Oklahoma) Chemical accident sickens workers. Corrosive chemicals affected more than a dozen people at a Tulsa, Oklahoma trucking company Friday morning when an industrial solvent spilled during transport. Authorities cordoned off part of the Old Dominion Freight Line facility at 2921 Dawson Road after a 55-gallon drum of chloromethyl naphtalene spewed dangerous vapors, a fire department spokesman said. Emergency crews responded shortly before 10 a.m. and decontaminated 15 workers. Medics took nine of them to hospitals. The spokesman noted that even slight chemical contact is potentially dangerous. The workers stripped off their clothes in a blue decontamination tent and firefighters doused them with soapy water to remove any chemical residue. Meanwhile, other area businesses were warned about the spill, and employees were told to stay indoors. The barrel apparently sprang a leak when it rubbed against a piece of sharp metal while being moved. It was inside a trailer, which kept the gas from dispersing over a wide area, a fire captain said. The situation was brought under control about two hours later, and a restoration company arrived to finish the cleanup. Source: http://www.tulsaworld.com/news/....l972408

June 7, Truckinginfo.com – (National) FMCSA to propose easing of supporting documents for EOBR* users. Under a pending Federal Motor Carrier Safety Administration proposal, carriers that use electronic recorders will get a break on the list of documents required to prove they are in compliance with the hours of service rules. The agency is asking for comments on a plan to drop a half-dozen documents from its required list altogether, and many more for carriers that are using qualified electronic recorders to track driver hours. The policy change is the first step toward an anticipated revision of the new electronic recorder requirement. That rule, which takes effect June 2012, says carriers that violate hours of service rules 10 percent of the time, based on single compliance review, must use electronic onboard recorders to track driver hours. Later this year the agency is planning to propose a rule that will require many more carriers to use EOBRs. This policy change is in anticipation of that move. One part of the policy change affects all carriers. The agency said it will no longer consider these items to be supporting documents: driver call-in records; international registration plan receipts; international fuel tax agreement receipts; trip permits; cash advance receipts; and driver fax reports. These documents are simply not used regularly by enforcement officials, the agency explained. Specifically, the carrier will not have to keep: gate record receipts; weigh/scale tickets; port of entry receipts; delivery receipts; toll receipts; agricultural inspection reports; over/short and damage reports; driver and vehicle examination reports; traffic citations; overweight/oversize reports and citations; carrier pros; credit card receipts; border crossing reports; customs declarations; and telephone billing statements. Carriers that take advantage of this policy would not be able to challenge the accuracy of their electronic tracking records. Source: http://www.truckinginfo.com/news/news-detail.asp?news_id=70630
*Electronic Onboard Recorders

Do you need to be trained?
If you have had any doubts about whether you need training or just who within your organization needs training you should check the U.S. DOT/PHMSA-DGAC pamphlet dealing with these issues.
You can download the pamphlet by clicking on this link http://www.phmsa.dot.gov/staticfiles..._Guide.pdf

In the current economic environment we are all trying our best to operate our businesses as economically as possible. However, where employee or public safety is involved, hazmat/dangerous goods training programs are not areas where you can afford to be frugal. Potential law suits due to accidents, employee safety and lost time from injuries or worse, fines from government agencies, or loss of your good reputation with business peers, all should dictate that you must have a safe, reliable, and well-trained staff.

Many years ago we received a letter from an up and coming freight forwarder that is now a giant in the industry. The writer complimented us concerning a warehouse-driver type of course that we conducted. The author stated that he no longer had damaged hazardous materials shipments but also damages and claims for general cargo had been almost totally eliminated because the employees treated all forms of cargo with care. And that is how it should be. Those of us involved with distribution and transportation should be providing excellent service to all of our clients. The end result is loyal clients, steady business, and a safe environment.

Safety is the law, but it is also good business.

So?  Who needs to be trained?
From the pamphlet listed above, a hazmat employee may be a person (including a self-employed person or an owner-operator of a motor vehicle) who:

  • Determines the hazard class of a hazardous material
  • Selects a hazardous materials packaging
  • Places warning signs, blocks wheels, and sets brakes on tank cars placed for loading or unloading with closures open
  • Fills or loads a hazardous materials packaging
  • Secures a closure on a filled hazardous materials package or container
  • Marks a package to indicate that it contains a hazardous material
  • Labels a package to indicate that it contains a hazardous material
  • Prepares a hazardous materials shipping paper
  • Provides and maintains hazardous materials emergency response information
  • Reviews a hazardous materials shipping paper to verify compliance with the HMR or international equivalents
  • For persons importing a hazardous material in to the United States, provides the shipper

with information as to the requirements of the HMR* that apply to the shipment of the
material while in the United States

  • Certifies that a hazardous material is in proper condition for transportation in conformance with the requirements of the HMR*
  • Blocks and braces a hazardous materials package in a freight container or transport vehicle
  • Segregates a hazardous materials package in a freight container or transport vehicle from incompatible cargo
  • Selects, provides, or affixes placards for a freight container or transport vehicle to indicate that it is carrying hazardous materials
  • Loads or unloads hazardous materials for the purpose of transportation
  • Tests, reconditions, or repairs hazmat packaging
  • Operates a vehicle used to transport hazmats

*HMR – Hazardous Materials Regulations

If you perform any of the above functions you must be trained.

Lithium Batteries

We’re beginning to believe that no newsletter is complete without some new information on lithium batteries. So now we find out that “smokeless cigarettes” may be even more dangerous than tobacco cigarettes. Perhaps we’ll see the Surgeon General’s warning on e-cigarettes in the near future?

Our close friend and colleague Howard Skolnik of Skolnick Industries had the following item in his July Newsletter.

“D & M Custom Injection Molding Corp. of Burlington, Ill gave a five-piece shipment of approximately 2,000 smokeless cigarettes to Federal Express, for transportation by air, from Indianapolis to Minneapolis-St. Paul, Aug. 14, 2009. Each smokeless cigarette contained alcohol — a flammable liquid, and a lithium battery — a hazardous material. The Federal Aviation Administration is proposing a $168,000 civil penalty against the company for alleged violations of DOT Hazardous Materials regulations. Each box contained 400 E-Mysticks, including 7.6 kilograms of lithium batteries, exceeding the five-kilogram limit for shipment aboard passenger aircraft. Because the shipment was not packaged in accordance with regulations, it is forbidden on all aircraft, including all-cargo flights. As the flight approached Minneapolis-St. Paul International Airport, the FedEx flight crew received a fire warning on the instrument panel. The crew discharged the fire suppression system during the landing and taxied to the gate. The airport fire department responded and extinguished a fire in an LD3 cargo container. The fire was started by the lithium batteries in the shipment. DOT continues to monitor lithium battery shipments as a high priority dangerous goods concern. In this case, FAA is also indicating their concern with this substantial fine. Shippers — be aware that lithium battery shipments are regulated and must comply with the dangerous goods requirements. “
— Howard Skolnik

Skolnik manufactures U.N. Specification steel and stainless steel drums. Howard’s newsletters always provide some interesting tidbits. You can check his newsletters and review his products at news@skolnik.com.

You can see the entire FAA lithium battery listing of incidents at:

Just about every MSDS for lithium batteries makes some reference to the U.N. Manual of Tests. These are the tests for the lithium batteries.

UN Tests for lithium batteries:

  1. Test 1: Altitude Simulation
  2. Test 2: Thermal Test
  3. Test 3: Vibration
  4. Test 4: Shock
  5. Test 5: External Short Circuit
  6. Test 6: Impact
  7. Test 7: Overcharge
  8. Test 8: Forced Discharge

These tests are vital to the everyday safety of lithium batteries in transportation and in personal use. We would not handle those batteries if the MSDS did not state specifically that the batteries were “UN Tested”. For “guardhouse lawyers”, no, this does not mean the batteries were actually tested by the U.N. but that the batteries successfully passed all the tests conducted by a responsible test laboratory with the proper technical equipment to perform the tests according to the U.N. Manual of Tests – the orange book.

If the tests were not performed the batteries are identified as “prototype lithium batteries” and may not be shipped without an approval from the country of origin’s national authority.  .

The return of our soap box:

We rant and rave and preach about safety in transportation most of the time.

Follow-up to our July Newsletter about fireworks -

In Islip Terrace, LI, NY, a man had his arm blown off at the shoulder when he lit an illegal mortar fireworks display by his home on July 3rd. Surgeons were unable to reattach the arm due to the extensive damage to the arm and shoulder. 

The Material Safety Data Sheet.

We continuously tell our shipper and forwarder clients that the MSDS that they submit to us for guidance is either not current or simply does not comply with Global Harmonization System (GHS) standards.

Our 24 Hour Emergency Response partner, CHEMTEL, addresses these issues on their website at http://www.chemtelinc.com/index.php/msds-authoring.html

We’ll repeat part of it here.

IF your current MSDS…

  • Is in the old 8, 9, or 10-part format, your firm is not in compliance with the GHS! (GHS requires a 16 part format)
    Does not have Harmonized Hazard Statements, your firm is not in compliance with the GHS! (GHS requires a harmonized hazard statement).
  • Consists of many different Safety Data Sheets for each hazardous chemical you export. Your firm needs to update now to the universal GHS format!
  • Does not list “Hazard Information” as the second category. You’re non-compliant with the GHS. 
    Does not display pictograms, safety phrases, and risk phrases. Your firm is non-compliant with both current  E.U. (European Union) and GHS requirements.
  • Does not list “Permissible Exposure Limits” in the exposure controls section. Your firm is non-compliant with the GHS.
    Is more than 3 years old, it is probably out of date.

We would add that if you ship lithium batteries you should be updating your MSDS just about every year due to all of the regulatory changes.

CHEMTEL offers MSDS authoring services.

If your company is a carrier or forwarder feel free to pass this information on to your clients.  

What happens when you fail to pay attention to State Variations?

In this case, ICAO/IATA USG-10(a) -

FAA fines two India companies for uranium cargo. The Federal Aviation Administration (FAA) has fined two Indian companies $422,500 for sending a radioactive shipment of depleted uranium as cargo on a passenger-carrying British Airways flight from Mumbai to Logan International Airport in Boston in 2008. The FAA alleges that IIS & Allied Services and its freight forwarder, Gallant Freight & Travels, failed to declare the hazardous nature of the shipment, which wasn’t properly packaged or labeled. Radioactive materials are not allowed to be shipped as cargo aboard passenger aircraft, with some exceptions.

100% air freight screening requirements for passenger aircraft effective on August 1, 2010.

Dangerous Goods Advisory Council

32nd Annual Conference & Hazardous Materials Transportation Exposition
Hyatt Regency Bellevue
Bellevue, WA
October 18-20, 2010
Phone: 425/462-1234

DGAC Room Rate: $195 single or double
Reservation Cut-off date: September 24, 2010
For information click on this link: http://www.dgac.org/conferences/

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