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Training & Security 49 CFR Part 172 Subparts H & I

Training/Security Objectives Upon completion of this presentation, you will be able to: Define hazmat employee & hazmat employer Identify the training requirements DOT has in place for hazardous material employees Determine training frequency Determine who must have security awareness training Determine when written security plans are required Identify the main components of security plans

Training Definition Training means a systematic program that ensures a hazardous material (hazmat) employee has familiarity with the general provisions of the 49 CFR Hazardous Materials Regulations (HMR), is able to recognize and identify hazardous materials, has knowledge of specific hazmat requirements applicable to functions performed by the employee, and has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures. 172.700(b)

Hazmat Employer Definition Hazmat Employer means: A person who employs or uses at least one hazmat employee on a full time, part time, or temporary basis; or a person who is self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) transporting materials in commerce; or a department, agency, or instrumentality of the United States Government, or an authority of a State, political subdivision of a State, or an Indian tribe; and who: Transports hazardous materials in commerce; Causes hazardous materials to be transported in commerce; or Designs, manufacturers, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container, or packaging component that is represented, marked, certified, or sold by that person as qualified for use in transporting hazardous materials in commerce. 1A1/X1.8/250/08 USA/1234AC U N 171.8

Hazmat Employee Definition Hazmat Employee means: A person who is: Employed on a full time, part time, or temporary basis by a hazmat employer and who in the course of such full time, part time, or temporary employment directly affects hazardous materials transportation safety; Self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) transporting hazardous materials in commerce who in the course of such self-employment directly affects hazardous materials transportation safety; A railroad signalman; or A railroad maintenance-of-way employee. 171.8

Hazmat Employee Definition This term includes an individual, employed on a full time, part time, or temporary basis by a hazmat employer, or who is self-employed, who during the course of employment: Loads, unloads, or handles hazardous materials; Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container, or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazmat in commerce; Prepares hazmat for transportation; Is responsible for safety of transporting hazmat; or Operates a vehicle used to transport hazmat. To: ABC Company 123 N Main St. Chicago, IL 60601 Corrosive Liquid, Acidic, Inorganic, N.O.S. UN3264 (Phosphoric Acid, Sulfuric Acid) 1H1/X1.8/250/08 USA/1234AC Month: 01 U N From: Infotrac Inc. 200 N. Palmetto St. Leesburg, FL 34748 171.8 (continued)

Federal-State Relationship For motor vehicle drivers, States may impose more stringent training requirements only if those requirements: Do not conflict with federal training requirements; and Apply only to drivers domiciled (living) in that State. STATE VS. FEDERAL 172.701

Hazmat Employer Responsibility Each hazmat employer must ensure that each of its hazmat employees is: Trained. Training may be provided by the hazmat employer or other public or private sources, such as Infotrac, and Tested (certified). Each hazmat employee must demonstrate their knowledge by some means of a test. For example: written test, performance test, oral test, etc. The hazmat employer also must create and retain a current record of training. This will be discussed shortly. 172.702 & 172.704(d)

Training Requirements Training must include: General awareness/familiarization training: Familiarity with the requirements of the HMR Recognize and identify hazmat consistent with the hazard communication requirements Function-specific training: With the requirements of the HMR, Special Permits, etc. Specifically applicable to the functions the employee performs, such as Operator (Driver) training, filling packaging, etc. Safety training: Emergency response information (Part 172, Subpart G) Protect the employee from the hazards associated with hazmat Methods and procedures for avoiding accidents Security training: Security awareness training In-depth security training (security plans) 172.704(a)

Training Frequency – Initial Training A new hazmat employee or one who changes job functions may perform those functions without completing training if: The hazmat employee performs those functions under the direct supervision of a properly trained and knowledgeable hazmat employee; and The training is completed within 90 days. 172.704(c)(1)(i) & (ii)

Training Frequency – Recurrent Training Recurrent training is required at least every 3 years. Relevant training: Relevant training received from a previous employer or other source may be used to satisfy these training requirements provided a current record of training is obtained from the previous hazmat employer. You are late for school! 172.704(c)(2) & (3)

Record of Training The hazmat employer must create and retain a record of current training (including the preceding 3 years) for each hazmat employee and for 90 days after employment. The record of training shall include: The hazmat employee’s name; The most recent training completion date; A description, copy, or reference to the training materials used; The name and address of the company providing the training; and Certification (evidence) that the hazmat employee has successfully completed the test. 172.704(d)

Security Awareness Training Each hazmat employee must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. The training must also include a component covering how to recognize and respond to possible security threats. Security issues Security measures Security threats 172.704(a)(4)

In-Depth Security Training – Security Plan Each hazmat employee of a person required to have a security plan in accordance with 49 CFR 172.800 must be trained concerning the security plan and its implementation. Security training must include: Company security objectives Specific security procedures Employee responsibilities Actions to take in the event of a security breach, and The organizational security structure 172.704(a)(5)

Security Plan – Applicability The purpose of security plans is to address security risks related to the transportation of hazardous materials in commerce. 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: Highway route-controlled quantity of Class 7 (radioactive) material (refer to 173.403). More than 25 kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material (refer to 173.50) in a motor vehicle, rail car, or freight container. 172.800(b)(1) & (2)

Security Plan – Applicability More than one L (1.06 quarts) per package of a material extremely poisonous / toxic by inhalation (hazard zone A) as specified in 173.116(a) or 173.133(a). Shipment of a bulk package having a capacity of greater than or equal to 13,248 L (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids. Arsine UN2188 172.800(b)(3) & (4) (continued)

Security Plan – Applicability A shipment in packages other than bulk packages 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; A select agent or toxin regulated by the Centers for Disease Control and Prevention under 42 CFR part 73 or by April 1, 2007, a select agent or toxin regulated by the United States Department of Agriculture under 9 CFR part 121; or A quantity of hazardous material that requires placarding. 172.800(b)(5)-(7) (continued)

Security Plan – Exceptions Transportation activities of a farmer, who generates less than $500,000 annually in gross receipts from the sale of agricultural commodities or products, are not required to have security plans if such activities are: Conducted by highway or rail; In direct support of their farming operations; and Conducted within 150-mile radius of those operations. 172.800(c)

Components of the Security Plan The security plan must include an assessment of possible transportation security risks and appropriate measures to address the assessed risks. 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 & 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. 172.802(a) & (b)

Components of the Security Plan At a minimum, a security plan must include the following elements: Personnel security Verification of job applicant information. Unauthorized access Process that assures unauthorized personnel do not have access to hazardous material shipments. En route security Assess the most appropriate method of transportation to assure the efficient and secure movement of product. 172.802(a)(1)-(3)

“Good Practices” The following are “good practices” or additional things that you may want to consider when creating security plans: Verification that the hazardous material carrier has an on-going transportation security program. Verify the driver’s or carrier’s identity (highway transportation only). “They are who they say they are.”

“Good Practices” continued Identification of preferred and alternative routing, including acceptable deviations. Avoid, when possible, populated areas, tunnels, and bridges. Avoid unnecessary delays and layovers. A system for communicating with a transport vehicle or its operator. Cell phones Global Positioning Satellite (GPS), etc. A system for a customer to notify the shipper if hazmat is not received when expected. “Good Practices” continued

Substitute Security Plans To avoid unnecessary duplication of security requirements, security plans that conform to regulations, standards, protocols, or guidelines issued by other Federal agencies, international organizations, or industry organizations may be used to satisfy the requirements of DOT’s security requirements (Subpart I-Security Plans, 172.800-172.802), provided such security plans address all of DOT’s security requirements. 172.804

Training/Security Summary Hazmat employee & hazmat employer definition Training frequency: Initial: 90 days for a new hazmat employee or one who changes job functions Recurrent: at least every 3 years Training must include: General awareness/familiarization Function-specific Driver Safety Security

Training/Security Summary All hazardous material employees must receive security awareness training Persons subject to the security plan requirements include certain types of Class 7, Explosives, Poison Inhalation Hazards, Bulk packages, select agent/toxin, and placarding The three main components that make up security plans are: Personnel security Unauthorized access En route security (continued)

DOT Safety Training: Emergency Response Guidebook (ERG)

Safety Training (ERG) Objectives Upon completion of this presentation, you will be able to: Understand how to use the DOT Emergency Response Guidebook (ERG) Identify when hazmat incidents must be reported to the DOT & the National Response Center (NRC) Identify when a detailed hazardous material incident report is required & where it must be sent

Emergency Response Guidebook Emergency response to accidents/incidents DOT has an Emergency Response Guidebook (ERG) which tells response personnel what steps to take to first protect themselves and the public during hazardous materials incidents. The guide is indexed by proper shipping name (name of material) and hazardous material Identification Number (ID Number). It is vital that the proper shipping name, ID Number, label, shipping papers, and placards are correct to ensure the correct emergency response.

ERG Layout The ERG is divided into 4 colored sections: 1) Yellow-bordered pages (ID Number Index) 2) Blue-bordered pages (Name of Material Index) 3) Orange-bordered pages (Safety and Emergency Response Information) 4) Green-bordered pages (Information about Toxic (Poison) Inhalation Hazards (TIH/PIH) and water-reactive materials).

Yellow-Bordered Pages A list of dangerous goods/hazardous materials in numerical order by Identification Number (ID Number). The list displays the 4-digit ID Number of the material followed by its assigned emergency response guide and the proper shipping name (material name). The list can be used to find the appropriate “GUIDE NUMBER” if the assigned Identification Number is known.

Yellow-Bordered Pages Example This slide is an example of how you would look up an ID Number in the yellow-bordered pages of the ERG. NOTE: Find the ID Number on a placard, the shipping paper, or the package. 1263 Paint UN1263 4G/X30/S/08 USA/1234AC UN To: ABC Company 123 Main St. Chicago, IL 60601 From: Infotrac Inc. 200 N. Palmetto St. Leesburg, FL 34748 Yellow-Bordered Pages (continued)

Yellow-Bordered Pages Example ID Guide Name of Material No. No. 1259 131 Nickel carbonyl 1261 129 Nitromethane 1262 128 Isooctane 1262 128 Octanes 1263 128 Paint (flammable) 1263 128 Paint Related Material (flammable) 1264 129 Paraldehyde 1265 128 Isopentane 1265 128 n-Pentane 1265 128 Pentanes Yellow-Bordered Pages (continued)

Blue-Bordered Pages 2) Blue-bordered pages: A list of dangerous goods/hazardous materials in alphabetical order by proper shipping name (material name). The list displays the name of the material followed by its assigned emergency response guide and the 4-digit ID Number. The list can be used to find the appropriate “GUIDE NUMBER” if the material’s proper shipping name (shipping name) is known.

Blue-Bordered Pages Example Now let’s see how the blue-bordered pages of the ERG are used when the proper shipping name is known. NOTE: Find the proper shipping name either on the shipping paper or the package. X Paint, 3, UN1263, II X UN1263, Paint, 3, II Blue-Bordered Pages (continued)

Blue-Bordered Pages Example Name of Material Guide ID No. No. Oxygen generator, chemical 140 3356 Oxygen generator, chemical, spent 140 3356 Paint (corrosive) 153 3066 Paint, corrosive, flammable 132 3470 Paint (flammable) 128 1263 Paint, flammable corrosive 132 3469 Paint related material (corrosive) 153 3066 Paint related material, corrosive, flammable 132 3470 Paint related material (flammable) 128 1263 Paint related material, flammable, corrosive 132 3469 Blue-Bordered Pages (continued)

Orange-Bordered Pages The most important section because it provides all safety recommendations and emergency response information (ER Info) to protect you and the public from hazardous materials/dangerous goods. The individual guides are presented in a two-page format. The left hand page provides safety related information whereas the right hand page provides emergency response guidance and activities for fire situations, spill or leak incidents and first aid. Each guide is designed to cover a group of materials which possess similar chemical and toxicological characteristics. The guide title identifies the general hazards of the dangerous goods/hazardous materials covered.

3 Main Sections – Orange-Bordered Pages Each guide is divided into three main sections: Potential hazards; Public safety; and Emergency Response. Orange-Bordered Pages (continued)

Section 1 – Orange-Bordered Pages The first section describes potential hazards that the material may display in terms of fire/explosion and health effects upon exposure. The highest potential is listed first. The emergency responder should consult this section first. This allows the responder to make decisions regarding the protection of the emergency response team as well as the surrounding population. Orange-Bordered Pages (continued)

Section 2 – Orange-Bordered Pages The second section outlines suggested public safety measures based on the situation at hand. It provides general information regarding immediate isolation of the incident site, recommended type of protective clothing, and respiratory protection. Suggested evacuation distances are listed for small and large spills and for fire situations (fragmentation hazard). The second section also directs the reader to consult the tables listing Toxic/Poison Inhalation Hazard materials (TIH or PIH), chemical warfare agents, and water-reactive materials (green-bordered pages) when the proper shipping name (material name) is highlighted in the yellow-bordered and blue-bordered pages. Orange-Bordered Pages (continued)

Section 3 – Orange-Bordered Pages The third section covers emergency response actions, including first aid. It outlines special precautions for incidents which involve fire, spill, or chemical exposure. Several recommendations are listed under each part which will further assist in the decision making process. The information on first aid is general guidance prior to seeking medical care. Orange-Bordered Pages (continued)

Orange-Bordered Pages Example 42

Green-Bordered Pages 4) Green-bordered pages: This section contains two tables. Table 1 lists, by ID Number, Toxic Inhalation Hazard (TIH or PIH) materials, including certain chemical warfare agents, and water-reactive materials which produce toxic gases upon contact with water. Table 1 provides two different types of recommended safe distances which are “Initial isolation distances” and “Protective action distances”. Reference to the green-bordered pages is made by highlighting the specific entry in green in the yellow-bordered or blue-bordered pages.

Green-Bordered Pages (continued) Table 2 lists, by ID Number, materials which produce large amounts of Toxic Inhalation Hazard (TIH or PIH) gases when spilled in water and identifies the TIH gases produced. These Water Reactive materials are easily identified in Table 1 as their name in immediately followed by (when spilled in water). Note, however, if this material is not spilled in water, Table 1 and Table 2 do not apply and safety distances will be found within the appropriate orange guide. See the ERG for additional information. 44 Green-Bordered Pages (continued)

The Letter “P” The letter “P” following the guide number in the yellow-bordered and blue-bordered pages identifies those materials which present a polymerization hazard under certain conditions. Materials may polymerize violently under high temperature conditions or contamination with other products. Polymerization will produce heat and high pressure buildup in containers which may explode or rupture.

ERG Example What are the 4 colored sections in the Emergency Response Guidebook (ERG)? 1) Yellow-bordered pages (ID Number Index) 2) Blue-bordered pages (Name of Material Index) 3) Orange-bordered pages (Safety and Emergency Response Information) 4) Green-bordered pages (Information about Toxic (Poison) Inhalation Hazards (TIH/PIH) and water-reactive materials).

How to Use the ERG During An Incident Involving Hazmat The three steps that you must remember when using this guidebook during an incident involving dangerous goods/hazardous materials are: Step 1: Identify the material; Step 2: Identify the 3-digit guide number; & Step 3: Turn to the numbered guide.

Step 1: How to Use the ERG During An Incident Involving Hazmat Step 1: Identify the material by using any one of the following: The Identification Number (4-digit ID Number) on a placard, orange panel, shipping paper (documentation), or package. The name of the material on the shipping paper (documentation) or package.

Step 2: How to Use the ERG During An Incident Involving Hazmat Step 2: Identify the material’s 3-digit guide number in either: The ID Number Index (yellow-bordered pages), or The Name of Material Index (blue-bordered pages). Remember, if the guide number is supplemented with the letter “P”, it indicates that the material may undergo violent polymerization if subjected to heat or contamination.

Step 2: How to Use the ERG During An Incident Involving Hazmat If the index entry is highlighted in green, it is a TIH material or a Dangerous Water Reactive Material (produces toxic gas upon contact with water). Identify the ID Number and name of the material in the Table 1 – Initial Isolation and Protective Action Distances (the green-bordered pages). If necessary, begin protective actions immediately. If protective action is not required, use the information jointly with the 3-digit guide. Use Guide 112 for all explosives except for Explosives 1.4 (Explosives C) where Guide 114 is to be consulted. Step 2 (continued)

Step 3: How to Use the ERG During An Incident Involving Hazmat Step 3: Turn to the numbered guide (orange-bordered pages) and read each section carefully.

Unidentified Cargo and Explosives – How to Use the ERG During An Incident Involving Hazmat NOTES: If a numbered guide CANNOT be obtained by following the 3 steps, and a placard is visible, locate the placard in the Table of Placards, then proceed to the 3-digit guide shown next to the sample placard. If a reference to a guide cannot be found and this incident is believed to involve dangerous goods, turn to Guide 111 (mixed load/unidentified cargo), and use it until additional information becomes available. NOTE: Use Guide 112 for all Explosives except for Explosives 1.4C. Use Guide 114 for Explosives 1.4C.

ER Telephone – How to Use the ERG During An Incident Involving Hazmat If the shipping document is available, call the listed emergency response telephone number. If the shipping document or emergency response telephone number is not available, immediately call the appropriate emergency response agency listed in the back of the guidebook. Provide as much information as possible, such as the name of the carrier (trucking company or railroad) and vehicle number. As a last resort, if only the container can be identified, consult the Table of Rail Car and Road Trailer Identification Chart. Remember that the information associated with these containers is for worst case scenarios.

Remember – “Be Careful” You should never assume an incident to be harmless. Always take special precautions during a hazardous material transportation incident.

“Nevers” You should “NEVER”: Assume a harmless situation exists, Touch the material, Track the material elsewhere, Approach the material too close, Position yourself down wind of the incident, Allow others into the affected area, Respond without training or equipment, or Respond alone.

Safety Precautions Here are some basic safety precautions: Approach cautiously from upwind; Secure the scene; Identify the hazards; Assess the situation; Obtain help; Decide on site entry; Respond; Above all – do not walk into or touch spilled material.

Properly Trained You must be properly trained before responding to an incident. Proper response means the following: Wearing proper protective equipment (PPE). Being properly trained in emergency response techniques. Properly trained in protective equipment usage. Using caution when approaching the incident Never going at it alone. Etc.

Who to Call For Assistance – ER Telephone Number Upon arrival at the scene, a first responder is expected to recognize the presence of dangerous goods, protect oneself and the public, secure the area, and call for the assistance of trained personnel as soon as conditions permit. Follow the steps outlined in your organization’s standard operating procedures and/or local emergency response plan for obtaining qualified assistance. Generally, the notification sequence and requests for technical information beyond what is available in the ERG should occur in the following order: Your organization/agency. The emergency response telephone number listed on the shipping paper. Other assistance numbers are listed on the ERGs inside back cover. FOR CHEMICAL EMERGENCY Spill, Leak, Exposure or Accident CALL INFOTRAC – 24-Hour Number: Outside of the United States Call 24-Hour Number: 1-352-323-3500 1-800-535-5053

Who to Call For Assistance If the emergency response telephone is not listed, contact the national assistance agency listed on the ERGs inside back cover. You may also need to call the National Response Center (NRC) at: 1-800-424-8802. (continued)

Immediate Notice of Certain Hazmat Incidents As soon as practical but no later than 12 hours after the occurrence of any incident described under 171.15(b), each person in physical possession of the hazardous material must provide notice by telephone to the National Response Center (NRC). A telephone report is required whenever any of the following occurs during the course of transportation in commerce (including loading, unloading and temporary storage): 171.15(a) & 171.15(b)

Reportable Incidents – Direct Result of Hazardous Material As a direct result of hazardous material: A person is killed; or A person receives injuries requiring hospitalization; or The general public is evacuated for one hour or more; or A major transportation artery (highway/road) or facility is closed or shut down for one hour or more; or The operational flight pattern or routine of an aircraft is altered; or 171.15(b)(1)

Reportable Incidents – Radioactive Materials Fire, breakage, spillage, or suspected radioactive contamination (Class 7) occurs involving a radioactive material (see also 176.48); or 171.15(b)(2)

Reportable Incidents – Infectious Substances Fire, breakage, spillage, or suspected contamination occurs involving an infectious substances (etiologic agents) other than a diagnostic specimen or regulated medical waste; or 171.15(b)(3)

Reportable Incidents – Marine Pollutants There has been a release of a marine pollutant in a bulk package with a quantity exceeding 450 L (119 gallons) for liquids or 400 kg (882 pounds) for solids; or 171.15(b)(4)

Reportable Incidents – Continuing Danger A situation exists of such a nature (for example, a continuing danger to life exists at the scene of the incident) that, in the judgment of the person in possession of the hazardous material, it should be reported to the National Response Center (NRC) even though it does not have to be reported. 171.15(b)(5)

National Response Center (NRC) I’d like to report a spill! Each notice shall be given to the National Response Center (NRC) at: 800-424-8802 (toll free) or 202-267-2675 (toll call). For infectious substances (etiologic agents), notices may be given to the Director, Centers for Disease Control and Prevention instead of notice to the NRC at: 800-232-0124. . 171.15(a)

Report Information Each telephone notice must include the following information: Name of Reporter; Name & address of person represented by reporter; Phone number where reporter can be contacted; Date, time, & location of incident; The extent of injury, if any; Class or division, proper shipping name, & quantity of hazmat involved, if such information is available; and Type of incident & nature of hazmat involvement & whether a continuing danger to life exists at the scene. 171.15(a)

Reportable Incidents – Hazardous Substances (RQ) NOTE: Under 40 CFR 302.6, EPA requires persons in charge of facilities (including transport vehicles, vessels and aircraft) to report any release of a hazardous substance in a quantity equal to or greater than (= or >) its reportable quantity (RQ), as soon as that person has knowledge of the release, to the DOT’s National Response Center (NRC) at 800-424-8802 or 202-267-2675. In other words, any release of a reportable quantity of a hazardous substance must also be reported immediately to the NRC at 800-424-8802. 171.15 NOTE

Written Incident Reports – DOT Form F 5800.1 (01/2004) Each person making a report under section 171.15 shall also make the report required by 171.16 (Detailed hazardous materials incident reports). Each person in physical possession of a hazardous material at the time that any of the following incidents occurs during transportation (including loading, unloading, and temporary storage) must submit a Hazardous Materials Incident Report on DOT Form F 5800.1 (01/2004) within 30 days of discovery of the incident: Click Here To See DOT Form F 5800.1 (01/2004) Click Here For Instructions on Completing DOT Form F 5800.1 (01/2004) 171.15(c) & 171.6(a)

Detailed Hazardous Materials Incident Reports Any of the circumstances set forth in 171.15(b); An unintentional release of a hazardous material or the discharge of any quantity of hazardous waste; A specification cargo tank with a capacity of 1,000 gallons or greater containing any hazardous material suffers structural damage to the lading retention system or damage that requires repair to a system intended to protect the lading retention system, even if there is no release of hazardous material; or An undeclared hazardous material is discovered. 171.16(a)

Providing and Retaining Copies of the Written Reports Each person making a report under section 171.16 must: Submit a written or electronic Hazardous Materials Incident Report (for the location where to send reports, see 171.16(b)) For an incident involving transportation by aircraft, submit a written or electronic copy of the Hazardous Materials Incident Report to the FAA Security Field Office nearest the location of the incident; and Retain a written or electronic copy of the Hazardous Materials Incident Report for a period of two years at the reporting person's principal place of business. If the written or electronic Hazardous Materials Incident Report is maintained at other than the reporting person’s principal place of business, the report must be made available at the reporting person’s principal place of business within 24 hours of a request for the report by an authorized representative or special agent of the Department of Transportation. 171.16(b)

Updating the Incident Report A Hazardous Materials Incident Report must be updated within one year of the date of occurrence of the incident whenever: A death results from injury caused by a hazardous material; There was a misidentification of the hazardous material or package information on a prior incident report; Damage, loss, or related cost that was not known when the initial incident report was filed becomes known; or Damage, loss, or related cost changes by $25,000 or more, or 10% of the prior total estimate, whichever is greater. 171.16(c)

Incident Reports – Exceptions Unless a telephone report is required under the provisions of 171.15 of this part, the requirements of paragraphs (a), (b), and (c) of this section do not apply to the following incidents: A release of a minimal amount of material from: A vent, for materials for which venting is authorized; The routine operation of a seal, pump, compressor, or valve; or Connection or disconnection of loading or unloading lines, provided that the release does not result in property damage. 171.16(d)(1)

Incident Reports – Exceptions An unintentional release of hazardous material when: The material is properly classed as: ORM-D; or a Packing Group (PG) III material in Class or Division 3, 4, 5, 6.1, 8, or 9; Each package has a capacity of less than 20 liters (5.2 gallons) for liquids or less than 30 kg (66 pounds) for solids; The total aggregate release is less than 20 liters (5.2 gallons) for liquids or less than 30 kg (66 pounds) for solids; and The material is not: offered for transportation or transported by aircraft, a hazardous waste, or an undeclared hazardous material. An undeclared hazardous material discovered in an air passenger’s checked or carry-on baggage during the airport screening process. (For discrepancy reporting by carriers, see 175.31 of this subchapter.) 171.16(d)(2) & (3) (continued)

Safety Training (ERG) Summary The Emergency Response Guidebook (ERG) is comprised of 4 colored sections (yellow, blue, orange & green) Certain hazmat incidents must be reported to the DOT & NRC Unless excepted, any unintentional release of hazardous materials from a package must be reported to the DOT on DOT Form 5800.1

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