Hazmat Transportation Compliance: A Crash Course

hazmat transportation compliance

 

Hazmat compliance must be a top priority in a hazmat shipper’s world. Historically, many organizations have viewed compliance as a cost of doing business and important primarily for safety and to avoid the delays and civil penalties of non-compliance.

If you are new to the world of hazardous materials shipping, you may be wondering: what does it take to comply and why dedicate so much time, efforts and resources into it? As you will soon find out, compliance it is more than just a buzzword. Here is a crash course on the concept of hazmat compliance.

The Nature of the Industry

To understand the value of hazmat compliance, one must first fully understand the first word in that term. Hazardous materials have that name for a reason. Hazardous materials are articles or substances which are capable of posing a hazard to health, safety, property or the environment.

And yet,  facilitate thousands of shipments of hazardous materials every single day. They have proven essential for energy, manufacturing, and other essential parts of society as we know it. In order for these shipments to happen, certain people must handle these materials on a regular basis. No one would do this without some assurances of their safety and compliance requirements.

Federal and international organizations provide these assurances by creating, updating, and enforcing hazmat regulations. Hazmat employees must do their part by complying with the regulations.

Steps to Compliance

Of course, this may be easier said than done. Hazmat regulations cover the required aspects of the transport process, from inspection to packaging to shipping and more. To that end, they are stuffed with painstakingly detailed instructions, enormous tables, and a plethora of minutia. Becoming familiar with all of these rules may take a long time – and can be quite tedious.

Despite this, hazmat employees must follow regulations to the letter. These rules are not arbitrary. Federal and international organizations create and update them for the sake of maintaining safety – not just for hazmat employees, but also, for the general public and the environment. If they seem overly strict and specific, that is because researchers and experts have deemed such strictness and specificity necessary for maintaining safety. Compliance ensures that this safety is achieved.

Before offering a dangerous good to a carrier for shipment, the Hazardous Materials Regulations require the hazmat employer and hazmat employees, to properly classify, package, mark and label the package to identify the hazard.

When shipping dangerous goods (e.g., lithium batteries or battery powered devices, aerosols, oxygen cylinders, or perfumery products) please follow these steps to ensure your package is correctly packed and marked:

Step 1: The Safety Data Sheet (SDS) is a good starting point for determining if an item you are shipping might be a dangerous good. Typically, you can obtain an SDS from the manufacturer of the products that you plan to ship, and check the transportation information section. Pay particular attention to the specific information that pertains to shipments by air

As stated above a hazardous material or dangerous good is defined as a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under section 5103 of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous Materials Table (see 49 Code of Federal Regualtions (CFR) § 172.101), and materials that meet the defining criteria for hazard classes and divisions in Part 173 of [the Hazardous Materials Regulations].

Step 2: If you determine that an item is a dangerous good, we recommends that you perform a needs assessment analysis to determine which employees at your company will be performing a hazmat function and identify the level of training that is needed by the regulations.

Step 3: For most employees, training will include general and security awareness, safety, and function-specific training. Under the 49 CFR, a hazmat employee is required receive recurrent training every three years.

The lCAO Technical Instructions provide that the recurrent hazardous materials training requirements prescribed in Part L, Chapter 4, Section 4.2.3, “must take place within 24 months of previous training to ensure knowledge is current.”

Hazmat employee is a person employed by a hazmat employer, or person who is self-employed, and who directly affects hazmat transportation safety including a person who: loads, unloads, or handles hazardous materials or dangerous goods; designs, manufactures, fabricates, inspects, tests, reconditions, repairs, modifies, marks, or otherwise represents packagings as qualified for use in the transportation of hazardous materials or dangerous goods; prepares hazardous materials or dangerous goods for transportation; is responsible for safety of transporting hazardous materials or dangerous goods; or operates a vehicle used to transport hazardous materials or dangerous goods.

Step 4: Have a trained employee look up the material in the Hazardous Materials Table to determine the authorized quantities permitted to be shipped, labels required, and the allowable packaging as per the 49 CFR Part 173 and the packing group.

Step 5: Determine the quantities and corresponding packaging requirements for your shipments. Depending on the packing group assigned to the hazardous material, UN-Specification packaging may be required.

The Packing Group is a grouping according to the degree of danger presented by hazardous materials or dangerous goods. The performance level identifies the performance standard to successful testing of the packaging:

X – For packaging meeting Packing Group I, II and III test. (Packing Group I Great Danger)

Y – For packaging meeting Packing Group II and III test. (Packing Group II  Medium Danger)

Z – For packaging meeting Packing Group III test. (Packing Group III  Minor Danger)

Step 6: If UN-Specification packaging (PDF) is required, read the package closure instructions carefully and obtain all the materials listed in instructions, such as tape, zip ties, poly bags, etc. Be sure to follow the information closely. Packages meeting UN specifications are tested with the materials listed in the closure instructions. Any variation from the manufacturer’s instructions is a violation and could compromise the integrity of the package.

Step 7: Once you have the proper packaging, obtain the appropriate hazard communication, i.e., markings, labels, and shipping paper/shippers declaration. Generally, the Proper Shipping Name, the UN Number, and the shipper or consignees name and address are required to be marked on the package on the same surface as the label.

Step 8: Mark and label the package.

Step 9: If you are using a combination package, place the material in its inner packaging in accordance with the closure instructions. Then place the inner packaging in its authorized outer packaging and seal the package in accordance with the package closure instructions.

Step 10: Fill out the shipping paper and offer to carrier when offering the packages. For example, shipper’s declaration for infectious substances (PDF).

Step 11: Your package is ready to be shipped.

Step 12: Keep the Shipper’s Declaration on file for a period of two years.

The Need for Enforcing Hazmat Compliance

Along with having to follow these steps there is also the need to enforce them. Compliance is not just for hazmat employees, but the companies that employ them, too. Regulations easily could have been strong recommendations from leading lights and government bureaus. However, in this scenario, some businesses involved in hazmat transport might have declined. Maintaining safety standards may seem like expenses that could be cut. Why comply when shortcuts are allowed?

This is the mindset that will result in hazmat transportation disasters.  Failure to comply with regulations specifically designed to maintain safety around such goods has resulted in death and destruction. There should never be shortcuts!

Regulations exist in part to remind hazmat providers and shippers about the dangerous nature of the goods they handle and profit from. If the urge to protect human life is not enough to compel companies to comply, then hefty penalties for noncompliance will have to do.

Undergo Hazmat Compliance Training Today

The best way to learn how to comply with these regulations is to receive training. Hazmat University offers a variety of comprehensive hazmat compliance training programs. All of our courses are entirely online, which means you can complete them on your own schedule from anywhere.