What To Do and What Not To Do
Examples of disastrous hazardous materials events are not hard to find. They range from minor contaminants that spill out of containers and onto the road or into the sewer system—to massive explosions that can lead to physical harm or worse.
One example that often comes to mind for Jamie Hofer, manager of safety data compliance at Yellow, is a 1988 case from Kansas City, Missouri, where six firefighters were killed after a trailer storing explosives caught fire and eventually exploded. According to investigation reports after the incident, the trailer likely did not have any hazardous material labeling or placards to indicate the contents as firefighters attempted to put out the fire.
Hofer says these types of events are devastating, but entirely avoidable when carriers and shippers work together to properly label, carry and store hazardous materials in every step of their transportation journey.
“There is a lot of trust,” Hofer said of the relationship between carriers and shippers. “We are heavily reliant on the shipper to appropriately describe, package and label the freight.”
During a recent SMC³ LTL 204: US LTL Transportation Law & Regulations seminar focusing on HazMat best practices, Joe Tillman, instructor at Christian Brothers University, moderated a panel discussion including Hofer, Jamie Haines, safety coordinator at Yellow, and John Wagner, distribution manager at VWR. Throughout the hour-long session, the panel touched on a handful of tips and valuable advice supply chain professionals can use to improve their HazMat practices and avoid many of the harsh fines and unfortunate tragedies that may await in a complicated hazardous materials landscape.
WHAT TO DO | Build good training habits
The first step shippers and carriers can take to help promote safe transportation practices and protect themselves from non-compliance penalties is to focus on training teams to be prepared for anything they may see as they load up and ship out freight.
According to Haines: “We rely on our drivers heavily to help with this. They are our eyes out there in the field. We train and provide multiple refreshers at tailgate meetings so they are constantly familiar and aware of the changing rules—how should things be locked and braced, what to look for in paperwork?”
This goes for shippers too, Haines says. One of the primary reasons freight gets held up is due to lack of appropriate packaging and labeling during pick up.
“A lot of shippers don’t understand they are required to have HazMat training and their employees are required to have training,” Haines said. “It will help them to prepare their shipments and expedite the process.”
WHAT NOT TO DO | Don’t Confuse OSHA and DOT labeling requirements
While the OSHA HazCom Standard and DOT Hazardous Materials Regulations (HMR) may cover many of the same things, they aren’t identical regulations, and they have different goals. Most commonly, HazCom—which follows the GHS classifications—will account for more minor hazards such as respiratory and skin sensitizers, germ cell mutagens, carcinogens, and others, as it seeks to avoid the long-term effects of hazardous materials exposure. Of course, HMR has its own list of unique regulations as well. For this reason, Haines says carriers and shippers need to be well versed on both and be prepared to double check that labels are correct when a GHS label and bill of lading do not match.
“You see a lot of GHS marks on packages now,” Haines said. “It is getting better, but in the beginning, a lot of our drivers were really confused on why they would see a corrosive label on a package that was not described as a corrosive on the bill of lading. Basically, when a GHS label is on the package, OSHA considers it a corrosive substance for handling purposes, but the DOT does not regulate it as a corrosive.”
WHAT TO DO | Communicate frequently with transportation partners as needs and regulations change
It may seem like a no-brainer, but keeping carrier and shipper partners informed of ongoing changes to labels and product classifications is critical to maintaining a smooth operation. Even traditional bill of lading information, such as the need for a liftgate or forklift at the final destination, takes on additional importance when hazardous materials may sit idle in the trailer if carriers do not have the right equipment to unload. In LTL situations, carriers also need to have a granular understanding of the composition of your freight to avoid placing certain hazardous materials alongside others that may create even greater risk.
“It all comes back to communication,” Tillman said. “Having the right labels and making drivers aware of what is in there.”
Looking for more important tips to support your HazMat transportation workflows? Sign up for the SMC³ LTL 204: US LTL Transportation Law & Regulations course. As part of SMC³’s cutting edge hybrid learning curriculum, students will have an opportunity to hear weekly from industry experts and work through a self-paced curriculum of emerging regulatory industry topics. Learn more about this course and other courses on the schedule here.