The shipment of hazardous materials has become an important concern for numerous organisations. If these organisations are not careful and the shipments of these hazardous materials are not properly monitored, mistakes are sure to happen that may further lead to more troubles. There are several reasons why mistakes are committed in shipping hazardous materials. On some occasions employees mischaracterise hazardous articles and assume such materials as non-hazardous. There are also instances wherein regulatory differences between various modes of transport are not fully understood by organisations. Another shortcoming is one committed by employees who fail to ensure the qualification and competency of those involved in the shipment process.
Do the above cases sound familiar to you? To understand more about this topic, read and learn from the following discussions about how to avoid the four common mistakes in the shipment of hazardous materials. More importantly, this article further tackles about how to carry out a safe and compliant shipping process of hazardous materials.
Understand the regulatory difference between modes of transportation (air, highway, water and rail)
To explain this, consider the following scenario:
A research lab ships non-infectious patient specimens on dry ice routinely with a ground courier. By highway, dry ice is not regulated. The lab decides to begin offering an express shipment with an air service.
Since dry ice and many common patient specimens that aren’t regulated by highway are regulated by air, the company must therefore, now meet applicable DOT and IATA requirements.
The same logic also applies to national versus international shipments. For example, if a shipper hires a freight forwarder for an overseas hazardous marine shipment, it should be compliant with federal as well as IMDG regulations.
In addition, mistakes regarding the mode of transportation are also made when employees make assumptions based on transportation distances. Just because something is being transported within a short distance does not mean that it’s definitely being transported by land. Remember, you always need to confirm the mode of transportation with your carrier to avoid problems.
Below is a list of the documents you need to make sure your shipment is compliant with based on the mode of transportation.
- Ground: 49 CFR Parts 100-185 including specific provisions of Part 177
- Domestic air using non-IATA operator: 49 CFR Parts 100-185 including specific provisions of Part 175
- Domestic air using an IATA operator: IATA Dangerous Goods Regulations
- International Air: ICAO Technical Instructions or IATA Dangerous Goods Regulations (if operator policy)
- Domestic water: 49 CFR Parts 100-185 including specific provisions of Part 176
- International Water: International Maritime Dangerous Goods (IMDG) Regulations
- Rail: 49 CFR Parts 100-185 including specific provisions of Part 174
Never assume that common articles and substances are non-hazardous
Common items that are potentially hazardous are often transported by employees who are not traditionally thought of as “hazmat employees.” Sometimes the employees are not trained in hazmat shipping and aren’t even aware that there are regulations on these articles; this is where the problem comes in.
Take for example, lithium batteries. These articles are regulated and considered by the DOT as a hazardous material for both ground and air. They are further regulated by ICAO/IATA as Dangerous Goods. The requirements are on hazardous materials are complex and highly variable. In the example of lithium batteries, the requirements depend upon the size of the battery or cell, whether it is shipped alone or with equipment, and whether it is being shipped by air, ground, or water. There are even cases when carriers require special permission before offering and accepting certain lithium batteries for transport.
Here’s a sampling of common potentially-hazardous materials often perceived as non-hazardous:
- Patient specimens
- Genetically-modified micro-organisms and organisms
- Environmental samples for analysis
- Dry ice
- Batteries (lithium, button, or gel cell)
- Scientific instruments with compressed gas cartridges/canisters/cylinders
- Equipment with compressed air chambers or pistons
- Electronic devices/ computer equipment with lithium ion or lithium metal batteries installed
- Contaminated medical equipment and devices
- Pneumatic accumulators
- Charged capacitors
- Magnetized materials
- Devices with fuel cells
- Engines with fuel
Once you know that you are shipping the articles mentioned above, see to it that your employees are aware of it. Assist your employees by giving them a step-by-step manual on how to stay compliant when shipping these common hazardous materials. You may as well assign and designate a person, persons or a department for employees to contact when they need to ship materials that may be hazardous. Moreover, it is best to provide awareness training to all employees who may have shipping accounts. By taking such steps, the organisation is better prepared to handle the shipment of hazardous materials.
Understand the issues surrounding returns and self-transportation
There are times when warehouse, materials management and receiving personnel get involved in activities that are in fact regulated without realising it. Examine the following cases:
A shipping & receiving department may accept a package and discover at a later time, that the item must be returned to the supplier. The receiver may not be aware that the item is hazardous and inadvertently ships it back without following the DOT hazmat regulations.
A warehouse employee may self-transport a hazardous material from one building to another building for company use without thinking twice about any special requirements that may apply.
In case 1, the employer of the receiver becomes responsible for the potential repercussions of offering an undeclared hazardous material for transport. In case 2, the hazardous material being transported may be fully regulated depending upon the circumstances. Thus, this only means to say that even short transports within the company must follow regulations.
Yes, hiring untrained couriers to transport hazardous materials and not preparing them properly to take the job is another common mistake that needs to be corrected. When hiring any third party, employers must prepare hazardous material the same way they would when offering it to a major commercial carrier.
It is also but very important to look at self-transport activities so as to ensure compliance within the organisation. Read and understand the Materials of Trade exception of 49.CFR.173.6, address return issues, and scrutinize the use of local couriers. Once again, it is of paramount importance that all materials management, warehouse, and receiving personnel receive hazardous materials awareness training that covers these specific issues.
Determine the “competency” of hazardous materials employees
Every individual needs continuous training for him to better at his job. Training is especially important for new hires. The same also applies to a new hazmat employee. The training provided is necessary to make him a qualified and competent shipper. It should occur, of course, but its delivery should not be the only step. Imagine you are sending an employee to a training program that addresses 1,300 pages of federal regulations in two days. Certainly, such does not make an employee competent shipper. Enough time is needed for him to familiarize and understand these things.
Due to the complexity of hazmat regulations, it often takes considerable time working with a more experienced employee. At the end of all the hard work and effort, the new hire comes out as proficient in the understanding and use of the regulations, use of applicable software, and hands-on preparation of shipments. The effort indeed pays off!
To keep your organisation in compliance with hazmat shipping requirements, consider developing a cheat sheet for employees to use when shipping materials. The cheat sheet must clearly identify which items are regulated as hazardous, by which modes of transport and according to which applicable regulations. You must also ensure employees are trained and qualified in the use of all applicable regulatory standards.
Take note also that to guarantee that all employees who handle hazmat shipping are competent and qualified, employers should seek experienced hazardous materials shippers to fill such a role.
The checklist below will help you assess the competency of your hazmat shipping employees. You should be able to confidently say yes to all of the following statements as they apply to your employees:
- Employees are able to distinguish all materials commonly misconceived to be nonhazardous – including computer equipment with lithium batteries, devices with charged fuel cells, etc.
- Employees who ship materials are familiar with all of the regulatory requirements that govern the various modes of transportation for both domestic and international shipments.
- All employees are trained in the proper protocol for preparing items and arranging for transport – including shipments by self-transport, shipments being returned to the sender, and shipments being taken by a courier.
- All employees are aware of the serious consequences of improper shipping – penalties and citations, rejected shipments, damaged equipment and vehicles, and even serious injury or death.
- Only employees, who have demonstrated adequate training, qualification, and competency, are allowed to prepare hazardous materials shipments.