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Your HAZMAT
quiz for September , 2002:
Just roll your mouse
over the 
for the answer!
Due to the length of this month's
newsletter you can have the month off, sort of
- the quiz has only one question:
From a U.S.
D.O.T. quiz:
Because of the "square-on-point"
configuration, a hazard label is considered to
have what shape?
(a) Square (b) triangle
(c) oblong (d) round (e) diamond
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well with aol browser.
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Comments about this quiz? You can send
them to:
info@r-a-specialists.com
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This month we honor the innocent
victims of the vicious attacks of September 11, 2001. We have
set up a link to one of the many websites that have honored the victims,
their surviving families, and the countless heroes who answered the
calls for assistance. The link is in our "Hot Links" section of this
page, right under this newsletter. The victims will never be forgotten.
The fanatics who perpetrated the attacks will not be forgotten either,
but for far different reasons.
Please turn on your speakers
and click on that link and be prepared for some very emotional
moments.
The aftermath of 9-11 has fostered many changes
in the American way of life. Almost every division of federal, state
and local government has instituted new security programs that will
have a lasting impact on how Americans will conduct business, travel,
and their personal lives.
The Research and Special Programs Administration
of the Department of Transportation has a number of proposed rules
dealing with security concerns and the transportation of dangerous
goods (hazardous materials).
HM-228 - requirements for carriage by aircraft.
"These changes would modify or clarify requirements to promote
safer transportation practices; promote compliance and enforcement;
eliminate unnecessary regulatory requirements; convert certain exemptions
into regulations of general applicability; finalize
outstanding petitions for rulemaking; facilitate international commerce;
and make these requirements easier to understand. In response to
requests by members of the regulated community, the comment period
for the advanced proposed rule is extended until
September 30, 2002".
There are a number of proposals and requests for comments dealing
with training, documentation, packaging, and enforcement. Undeclared
dangerous goods and better methods of reporting these violations
are important features of this proposed regulation.
HM-232 - Hazardous Materials: Security Requirements
for Offerors and Transporters of Hazardous Materials.
This proposed regulation places some severe burdens on shippers,
forwarders, and carriers and has attracted more comments than we
personally can recall over many years.
The highlight of this proposal is the mandatory requirement for
manufacturers, shippers, storage facilities, forwarders, and carriers
to implement a training program and train all of their hazmat employees
in a formal security program within 90 days after the adoption of
the final rule. Other features will include additional documentation
and DOT Hazmat Registration requirements. This is likely to be a
very costly rule change. Check the U.S. D.O.T. website for the final
rule. http://hazmat.dot.gov/
"HM-232A - Security Requirements for Motor Carriers
Transporting Hazardous Materials.
Advance notice of proposed rulemaking (ANPRM); Published
7/16/2002, 67 FR 46622.
SUMMARY: The Research and Special Programs Administration
and the Federal Motor Carrier Safety Administration are examining
the need for enhanced security requirements for the motor carrier
transportation of hazardous materials. The two agencies are seeking
comments on the feasibility of specific security enhancements and
the potential costs and benefits of deploying such enhancements.
Security measures being considered include escorts, vehicle tracking
and monitoring systems, emergency warning systems, remote shut-offs,
direct short-range communications, and notification to state and
local authorities".
This proposed rule is likely to be a very costly compliance issue
for the trucking industry. When we brought this up at a recent training
class you could hear the screams of anguish for blocks around the
training facility. Hey! We don't make the rules. We just tell you
about them!
" RSPA-02-12773 (HM-232B) TITLE: Revision to
Periodic Tire Check Requirement for Motor Carriers Transporting
Hazardous Materials; Notice of proposed rulemaking (NPRM); Published
7/16/2002, 67 FR 46624.
SUMMARY: The Federal Motor Carrier Safety Administration
is proposing to eliminate an outdated requirement for certain motor
vehicle operators to stop periodically to check their tires. Eliminating
this requirement will enhance the security of hazardous materials
shipments".
This proposed rule should make everyone happy. The driver will
be permitted to perform his required safety inspection before and
after the trip and each time that the vehicle is parked as opposed
to once every 2 hours or 100 miles.
The
Dangerous Goods Advisory Council will be conducting its 2002
Annual Conference and Transportation Exhibition in Tempe, AZ on November 7-9, 2002. Contact the DGAC at
www.dgac.org
for details.
This year's agenda is "Dangerous
Goods in Dangerous Times"
Hope to see you in Tempe.
Our August NewsLetter
Our gripe about placing hazard labels incorrectly on packages of
dangerous goods caused quite a number of comments. Most carrier
personnel said that despite the rules they would not reject shipments
on such a minor issue. A number of shippers pretty much agreed with
the carriers. One enforcement officer (a highway patrolman) said
he never gave it any thought.
In 49CFR the rule is 172.407(a), (b), and (c).
As Yogi used to say "you can look it up"!
We are aware of at least one interpretation by RSPA that if the
box were not large enough it would be OK to place
the hazard label on the package in the square shape.
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