Hazardous Materials Safety Nathan J. Renie, Customs and Border Protection - Chicago, IL

HazMat Safety There are over 17 Million different chemicals in use around the world each day.

HazMat Safety HazMat Compliance HazMat Security

HazMat Compliance The transporting of Hazardous Materials internationally requires the cooperation of hundreds of individuals and various government agencies. In the United States three government agencies have regulations which apply to HazMat: DOT, EPA, and OSHA.

HazMat Compliance The DOT Hazardous Materials Regulations specify requirements for the safe transportation of hazardous materials in commerce by rail, air, sea, and motor vehicles.

HazMat Compliance The DOT HazMat regulations cover transportation related activities by shippers, brokers, freight forwarders, warehouses, carriers, packaging manufacturers, and many others. These regulations apply to all aspects of the transportation of an item from packaging to its final point of delivery.

HazMat Compliance DOT HazMat regulations are enforced by… DOT FAA Federal Highway Administration Federal Railroad Administration The Coast Guard CBP

HazMat Compliance Federal Law provides for civil penalties up to $25,000 for each HazMat violation. For willful violation of the laws there are stiffer penalties including imprisonment of willful violators.

HazMat Compliance DOT HazMat regulations include requirements for… Training Classification and Identification Protective Packaging Hazard Communication Incident Reporting

HazMat Training

HazMat Training Employee awareness will be the most important part of your HazMat program. The more exposure your workforce has to information pertaining to HazMat the better equipped they will be to handle an issue or serious incident.

HazMat Training Before any employee performs a function subject to the DOT HazMat Regulations, that person must be provided initial training in the performance of that function.

HazMat Training If a new regulation is adopted, or an existing regulation has changed, that employee must be instructed in those new or revised requirements prior to the performance of the new function.

HazMat Training If an employee has not been trained in a specific task relating to new or revised HazMat regulations they may perform the task under the direct supervision of a properly trained individual for a period of 90 days.

HazMat Training Every employee working with HazMat must receive initial training and periodically be retrained at least every three years.

HazMat Training The training should cover three specific categories: General Awareness Function Specific Training Safety Training

HazMat Training General Awareness Should provide employees a familiarity with the HazMat Regulations. Employees should be able to recognize and assess a HazMat situation.

HazMat Training Function Specific Training Should be applicable to the trainee’s daily work. This training could be quite brief and may be easily incorporated into OJT.

HazMat Training Safety Training Should include emergency response procedures, protective measures, and methods of avoiding accidents.

HazMat Training Employers are responsible for the proper training, testing, and record keeping

HazMat Compliance DOT HazMat regulations include requirements for… Training Classification and Identification Protective Packaging Hazard Communication Incident Reporting

HazMat Classification and Identification

HazMat Classification and Identification The DOT HazMat Regulations set forth the criteria for determining the hazard class and the proper shipping name for hazardous materials.

HazMat Classification and Identification Proper labeling or placarding is vital to public safety. The more information available to emergency responders and during an incident the better.

HazMat Classification and Identification Hazardous Materials are broken down into nine numbered classes.

HazMat Classification and Identification Each hazard class is generally made up of materials with similar properties and shipping requirements. This allows for identification of the basic dangers involved with the material.

HazMat Classification and Identification Explosives Gases Flammable and Combustible Liquids

HazMat Classification and Identification Flammable solids, combustible materials, and dangerous when wet materials Oxidizers and organic peroxides Toxic materials and infectious substances

HazMat Classification and Identification Radioactive Materials Corrosive Materials Miscellaneous dangerous goods

HazMat Classification and Identification More specific information about materials is provided by the placard (which may break the hazard class down further into divisions) and the display of the UN number, a four digit code which allows emergency responders to identify the chemical being shipped.

HazMat Classification and Identification The HazMat table in 49CFR172.101 provides extensive information about the requirements for specific materials. This is the same table used by regulatory agencies when they determine compliance with the regulations.

HazMat Classification and Identification Proper compliance with the classification and identification portion of the HazMat regulations will eliminate most violations.

HazMat Compliance DOT HazMat regulations include requirements for… Training Classification and Identification Protective Packaging Hazard Communication Incident Reporting

HazMat Protective Packaging

HazMat Protective Packaging The packaging required for HazMat is the first line of defense in preventing a release during transportation.

HazMat Protective Packaging DOT HazMat regulations specify various performance levels for packaging HazMat.

HazMat Protective Packaging The type of protective packaging used is dependent on the nature of the material to be packaged. All packaging must be designed to prevent a release during normal transportation or storage of the material.

HazMat Protective Packaging Normal transportation of these materials can often involve significant changes in temperature and ambient pressure. The protective packaging must take this into account.

HazMat Protective Packaging Shipments of liquids must be sealed correctly and have proper labels to indicate the correct orientation of the container.

HazMat Protective Packaging All inner packages must be adequately secured and cushioned in order to prevent spillage or breakage during normal transport.

HazMat Protective Packaging Substances that may react with each other may not be placed within the same packaging.

HazMat Protective Packaging Inadequately packaged HazMat should not be transported, accepted for transportation, or offered for transportation.

HazMat Compliance DOT HazMat regulations include requirements for… Training Classification and Identification Protective Packaging Hazard Communication Incident Reporting

HazMat Hazard Communication The elements of hazard warning information are to be communicated through shipping documents, packaging markings and labels, placards, and written emergency response information.

HazMat Hazard Communication Shipping Documents

HazMat Hazard Communication Shipping documents can be in the form of a bill of lading, freight bill, hazardous waste manifest, or another shipping document.

HazMat Hazard Communication At a MINIMUM, a properly prepared shipping paper clearly identifies HazMat by its proper shipping name, hazard class and division, UN identification number, packing group (if applicable), and total quantity.

HazMat Hazard Communication Additional hazard warning and handling information, such as “POISON” and “CARGO AIRCRAFT ONLY” must also be entered on the shipping documents.

HazMat Hazard Communication Package Markings

HazMat Hazard Communication Package markings and labels convey information such as, the shipping name, UN identification number, and hazard class of HazMat.

HazMat Hazard Communication Information on the outside of a package will allow carriers and warehouse staff to comply with proper loading and stowage protocol. This information could prevent potentially dangerous situations, such as inadvertently contaminated foodstuffs.

HazMat Hazard Communication HazMat markings must be durable, visible, in English, and comply with proper size and color specifications.

HazMat Hazard Communication Placards

HazMat Hazard Communication HazMat warning placards must properly be displayed on the outside of motor vehicles, freight containers, and other bulk shipments of Hazardous Materials.

HazMat Hazard Communication The HazMat placard gives a clear description of the contents of a large shipment of Hazardous Materials to the general public, emergency responders and others.

HazMat Hazard Communication Emergency Response Information

HazMat Hazard Communication Emergency response information and an emergency response telephone number must be provided by the offerer and maintained by the carrier for use in the mitigation of an accident involving HazMat.

HazMat Hazard Communication The offerer must also provide information concerning immediate health hazards, fire or explosion risks, immediate precautions that must be undertaken in the even of a spill, first aid information, and and emergency response telephone number of an individual who is knowledgeable of incident response information for that particular material.

HazMat Hazard Communication Material Safety Data Sheet – A list, provided by the manufacturer, which contains detailed information, including comprehensive safety information, about a single product. The information provided can vary from manufacturer to manufacturer, and from the various forms of the same chemical.

HazMat Hazard Communication Emergency response numbers = CHEMTREC, CHEM-TEL, INFOTRAC, 3E Company, etc. Many manufacturers will include contact information for individuals within their company in their MSDS.

HazMat Hazard Communication The information included on the shipment and in the shipping documents is intending to inform those people working with or around the HazMat shipment of the nature of the product.

HazMat Hazard Communication The information you provide will ensure the HazMat is safely handled, never stored with incompatible goods, and will likely be used by emergency personnel in the event of a serious incident.

HazMat Compliance DOT HazMat regulations include requirements for… Training Classification and Identification Protective Packaging Hazard Communication Incident Reporting

HazMat Incident Reporting The DOT & FAA HazMat Regulations require carrier to report all incidents involving HazMat. These incident reports are maintained in a database that will allow them to identify and correct problems which occur during transportation and storage.

HazMat Incident Reporting The proper reporting will allow the detection of serious problems and the regulations may be amended.

HazMat Incident Reporting Hazardous Materials Information Center 1-800-467-4922 Mon-Fri 9AM-5PM Eastern http://hazmat.dot.gov

HazMat Compliance DOT HazMat regulations include requirements for… Training Classification and Identification Protective Packaging Hazard Communication Incident Reporting

HazMat Compliance Your community depends on you to take the extra step to protect them from danger. An estimated 85% of all HazMat incidents are the result of preventable human errors. One incident can have tremendous consequences.

HazMat Security

HazMat Security DOT has additional regulations which require the development and implementation of a security plan if you offer or transport the following…

HazMat Security HazMat that must be placarded under federal regulations HazMat in a bulk package having a capacity of greater than or equal to 3,500 gallons for liquids or gases or more than 468 cubic feet for solids A select agent or toxin regulated by the CDC under 42 CFR Part 73

HazMat Security At a minimum your security plan must address: Personnel Security Unauthorized Access En route Security

HazMat Security Employers are responsible for training their employees and implementing their security plan. Compliance is currently being enforced!

HazMat Security Suggestions for HazMat security…

Risk Management Self-Evaluation Framework HazMat Security Plan Risk Management Self-Evaluation Framework (RMSEF) http://hazmat.dot.gov/rmsef.htm Based on the result of the RSEF develop your security plan to improve weak areas.

HazMat Security Plan The RMSEF utilizes the following steps Scoping Knowledge of Operations Assessment Strategy Action Verification Evaluation

HazMat Security Plan Scoping – Determining the scope of operations that should be subject to security risk management. Identify the types of HazMat you handle and the modes of transport which are used.

HazMat Security Plan Knowledge of Operations – Review your current security procedures and related safety programs.

HazMat Security Plan Assessment – Analyze potential security threats and identify security control points where improvements can be made.

HazMat Security Plan Strategy – Prioritize and group security risk and decide on preventative procedures. Create a written security plan summarizing those procedures.

HazMat Security Plan Action – Implement the plan! Verification – Implementation of the security plan must be monitored. Evaluation – Determine if your goals are being met and if your strategy is getting results in the field.

HazMat Security Plan Other suggestions…

HazMat Security Plan Encourage your employees to report any and all suspicious activity. Implement routine inspections. Conduct regular meetings on security topics.

HazMat Security Plan Establish a partnership with local emergency responders.

Utilize technology to track shipments HazMat Security Plan Utilize technology to track shipments GPS tracking Cell phones

HazMat Security Plan Escorts for sensitive shipments. Limiting the amount of stops en route. Limiting the number of entrances at a facility. Asking counterparts in industry.

HazMat Security Plan DOT regulations require all employees to be trained in the company’s security plan.

HazMat Security Plan The training should cover the following: Company Security Objectives Specific Company Security Procedures Employee responsibilities Action to take in the even of a security breach Organizational security structure

HazMat Security Training DOT regulations also require all employees working with HazMat to have general security training. This may be incorporated into their initial HazMat awareness training or the company’s security plan training. Your local DOT HazMat office has free training materials available.

Hazardous Materials Information Center HazMat Security Hazardous Materials Information Center 1-800-467-4922 Mon-Fri 9AM-5PM Eastern http://hazmat.dot.gov

HazMat Security How do we inform the public and involved personnel without giving too much information to criminals and/or terrorists?

HazMat Security Placarded shipments of HazMat do not necessarily make a effective target for terrorists.

HazMat Security As the technology develops alternatives to the placarding regulations are on the horizon. RFID (radio frequency identification tags) GPS vehicle tracking systems Centralized Information System

HazMat Security All signs point to placards as an irreplaceable source of readily available hazard information.

HazMat Security Discuss security issues with your fellow employees.Many of the best ideas come from problems solved in the field. YOUR security solution could be the best!

HazMat Safety In summary…

HazMat Safety DOT HazMat regulations are enforced by several agencies and cover everyone involved with the handling of the shipment.

HazMat Safety DOT HazMat regulations include requirements for… Training Classification and Identification Protective Packaging Hazard Communication Incident Reporting

HazMat Safety As well as the following security requirements for HazMat offerors… Security Plan Security Plan Training General Security Training

HazMat Safety A workforce well-trained in DOT HazMat regulations and HazMat security is your best defense against serious incidents. An investment in prevention will eliminate many potential problems and minimize the severity of accidents.

HazMat Safety THE END

Hazardous Materials Information Center HazMat Safety Hazardous Materials Information Center 1-800-467-4922 Mon-Fri 9AM-5PM Eastern http://hazmat.dot.gov