1. FAA / DOT Inspections Cornell University Bill Leonard 2013 CUHWC

2. Bill Leonard 6 Years US Navy – Nuclear Power School 15 Years at Cornell University – Manage Radioactive Waste Program – Manage DOT Hazardous Materials Program – Assist with Chemical Waste Program CDL w/Hazmat, Pesticide Applicator, Hazmat Team, CHMP

3. Outline History of FAA Inspections at Cornell – FAA (Federal Aviation Administration) Recent FAA Inspections Internal DOT Audits First Motor Carrier Inspection – New York State DOT US DOT Number DOT regulatory changes and updates

4. DOT Inspection History 2003 – 2 FAA Agents, 53 citations, $9000 fines 2007 – 2 FAA Agents, 10 citations, Warning Notice 2009 – FAA Agent reviews EH&S webpage, notice of update 2011 – 1 NYS DOT Investigator 2012 – 1 FAA Agent,8 citations, Warning Notice 2013 – 1 FAA Investigation

5. FAA Inspection 2012 Phone message FAA Agent to arrive at 11 am Inspection based on records reviewed at FedEx Express facility Phone call to campus shipper made 2 days earlier

6. FAA Inspection 2012 Briefing Copies of shipping paperwork – 33 Dangerous Goods forms (mostly Cat A) – 1 Airway Bill (dry ice) Discussed – Paperwork issues – Phone call to shipper – Locations he planned on visiting – Broken DOT flowchart link

7. FAA Inspection 2012 (EH&S) Copies of all EH&S shipping papers Training – List of all campus DOT trained staff Added certification statement – Course/Class curriculum General Awareness/Function Specific/Security Awareness DOT Security Plan

8. FAA Inspection 2012 (campus) Animal Health Diagnostic Center – Asked to walk through a shipment – Record review Training Dangerous Goods forms Package Closure Instructions Regulations – Findings 18 shipments over passenger limit 1 chemical return without training Lab staff classifying materials on shipment form

10. FAA Inspection 2012 (campus) Vet Medical Center – Asked to see Category A packaging 4GU package? Used package – Asked to walk through shipment Inner and secondary package closed inside BSL-3 – Record review Never happened

11. FAA Inspection 2012 (campus) Biotechnology Building – Dry Ice shipper Asked for training records – Findings Training out of date Air waybill completed incorrectly

12. FAA Inspection 2012 (campus) Biotechnology Shipping/Receiving – Asked for copies of DG form – Findings First shipment was rejected Second shipment lost volume? Undeclared hazmat shipment Added information to proper shipping name

13. FAA Inspection 2012 (actions) Suspended shipper DOT training – Hired ERC to provide DOT training – Required re-training of all inspected shippers Sent shipping notice to campus Informed FAA Agent

14. FAA Inspection 2012 (final results) Received Warning Notice – Cited 6 shipments over passenger limit – Cited 2 untrained shippers Noted in letter “you have taken corrective action, the FAA has decided not to pursue Civil Penalty Action”

15. FAA Inspection 2013 Phone call from FAA – UPS reported undeclared dry ice package – Contents potentially infectious? “Human” Inspection or self disclosure Findings – Shipment made by lab partner – No DOT training – Samples not infectious

16. UPS Photos

17. FAA Inspection 2013 Actions – Required DOT training – Sent Dry Ice notice to campus – Planned meeting with building safety committee Results – Warning notice

18. DOT Audits FedEx – Quarterly review of DG and air waybills – Form review, 24 hour info, PSN, limits Shipper – Training – Access to Regulations – UN packaging and closure instructions – Demonstrate the steps to complete an shipment – Copies of DG forms – What to do if contacted by a Federal Agency

21. US DOT number Do I need one for our farm services truck that is over 10,000 GVWR? – Farm vehicles are exempt, but not our waste trucks – Who manages the US DOT number? Grounds Finance office Facilities Operations (transportation services) – Look up US DOT number Wilson lab (3 trucks) – Update of US DOT number registration

22. NYS DOT Motor Carrier Inspection April 2011 US DOT number renewal and update – 3 trucks to 79 trucks, – Added hazardous materials December 2011 Motor Carrier Inspection by NYS DOT Investigator – Driver records on operators GVWR >10,000 lbs CDL’s, medical certificates, driving history, time logs – Vehicle records on all vehicles GVWR >10,000 lbs Maintenance files, driver inspections

23. NYS DOT Inspection (hazmat) Questions via conference call – Do we transport Hazmat? – Do we use a shipping paper? – How do we label our shipments? – Do we use placards? – Where are our shipping paper’s when properly seated and belted? – Do we have a Route Plan?

24. Route Plan? Triggered by radioactive placards for LSA – Could not specify the requirement for such plan Only required for HRC quantities of RAM Safety Plan – HRC quantity of RAM – > 1 liter PIH zone A – >450 liter PIH zone B – >13,248 liter PIH zone C or D – >13,248 liter liquefied gas with >85% methane

25. DOT Inspection or Safety Audit? NYS DOT inspection became safety audit – Treated as a new number Facilities Operations hired a DOT consultant – Review all transportation functions – Provided guidance and example forms

26. US DOT number requirements Applied to any vehicle or driver of a vehicle – GVWR > 10,000 lbs – Truck and trailer with combined GVWR >10,000 Exceptions – Operation of Fire trucks and Rescue Vehicles – Certain farm vehicles and drivers – Transportation performed by the Fed. Gov’t, a state, or any political subdivision of a state…

27. US DOT number requirements Driver’s – Application for employment Must contain previous driving information – Safety performance history (previous employers) – State driving records previous 3 years – Annual driving record review including violations – Drivers road test (practical)

28. US DOT number requirements Vehicle and time logs – Time log (start/finish) Less than 100 mile radius and returns to headquarters Less than 12 hour shift separated by 8 hours off – Inspection, Repair and Maintenance Records – Driver’s vehicle inspection report Specific items listed (including trailers if used) Drivers signature Mechanics signature

29. DOT Regulatory Updates Closure instructions (recent update 90 days) FedEx – Dry ice no longer allowed in just styrofoam boxes Lithium Batteries UN Number size on packages – 2017 for Domestic – 2014 for Air (IATA currently) 6 mm / 30L or 30 Kg / 12 mm

30. DOT Regulatory Updates Jan 2013 – UN number first and Cargo Only Jan 2014 – Organic Peroxide placard Oct 2014 – Class 6.2 and 9 label

31. DOT Reference Sheet Packaging Carry on items Emergency Response info Shipping Hazardous Chemicals under OSHA Definition of Commercial Motor Vehicle (CMV) CMV Requirements USDOT Number Exemptions

32. Questions? Don’t forget your reference sheet Bill Leonard Hazardous Materials Specialist