Where have we been?

We’ve been working our tails off! While the economy may be down our business continues to grow. Due to increased scrutiny by the FAA and USCG there has been increased demand for compliance packing and documentation for dangerous goods. As enforcement officers inspect more shippers, forwarders, and warehouse operators, Hazmat training demands have also increased, particularly in-house training programs.

Because of the increased demand for hazmat training we are adding a three day initial training class for Dangerous Goods by Air to our June schedule - June 23-24-25 (Monday-Tuesday-Wednesday).

Check your training records -
Our next recurrent training classes for air are June 2 and August 12. Mandatory new security awareness training has been added to these classes.

Check our “Links” at the top right hand side of our Welcome Page -
Go to our FAA link and review the fines issued by the FAA. Most of the fines refer to the fact that the shipper did train his employees.

We’ve had a lot of homework to take care of -
Here are the security initiatives that U.S. businesses have to cope with in the immediate future:

(Copied from the U.S. D.O.T./RSPA website)

• Risk Management Self-Evaluation Framework including security template.
  
• RSPA-03-14982 (HM-232C); Hazardous Materials: Enhancing Hazardous Materials Transportation Security; Interim Final rule and request for comments; Published 05/05/2003; 68 FR 23831.
  
• FMCSA-2001-11117; Limitations on the Issuance of Commercial Driver's Licenses with a Hazardous Materials Endorsement; Interim final rule and request for comments; Published 05/05/2003; 68 FR 23843.
  
• TSA-2003-14610; Amendment No. 1572-1; Security Threat Assessment for Individuals Applying for a Hazardous Materials Endorsement for a Commercial Drivers License; Published 05/05/2003; 68 FR 23851.
  
• RSPA-02-12064 (HM-232); Hazardous Materials: Security Requirements for Offerors and Transporters of Hazardous Materials; Final Rule; Published 3/25/03; 68 FR 14509. (see more information below)
  
• FMCSA-02-11650 (HM-232A); Security Requirements for Motor Carriers Transporting Hazardous Materials; Notice; Published 3/19/03; 68 FR 13250.
  
• FMCSA-02-13376; RSPA-02-12773 (HM-232B); Revision to Periodic Tire Check Requirement for Motor Carriers Transporting Hazardous Materials; Final rule; Published 10/4/2002; Effective Date: November 4, 2002; 67 FR 62191.
  
• FMCSA-02-11650 (HM-232A) TITLE: Security Requirements for Motor Carriers Transporting Hazardous Materials; Supplemental advance notice of proposed rulemaking; extension of comment period; Published 10/8/2002, 67 FR 62681.
  
• FMCSA-02-11650 (HM-232A) TITLE: Security Requirements for Motor Carriers Transporting Hazardous Materials; Advance notice of proposed rulemaking (ANPRM); Published 7/16/2002, 67 FR 46622.

U.S. Hazmat Cargo Security Regulations – effective now!
After many months of waiting, HM-232 RSPA-02-12064 (final rule) was published on March 25, 2003 with the effective date also being March 25. Within 90 days of the effective date, shippers, forwarders, carriers, and warehouse operators who offer or accept hazardous materials/dangerous goods must provide a Hazmat Transportation Security Awareness program to all hazmat employees. Companies who are required to be registered in the DOT/RSPA HAZMAT Registration Program must also institute a more extensive Hazmat Security formal (written) training program dealing with risk assessment, methods of mitigating theft or sabotage, building and vehicle security, employee background checks, and other issues. You can view the final rule directly from here – RSPA-02-12064 (HM-232)

DOT/RSPA permits copying of its Security Awareness CD Program. We use that CD in our initial and recurrent training programs and we furnish copies to each company that sends employees to us for air, highway, and ocean dangerous goods training. A test is not required for this phase of the training. However, our clients are reminded that they should have other employees view and work with this interactive CD. Make sure you add this feature to your training record files for each employee. Although HM-232 applies to Hazmat Employees we suggest that the general awareness program should be voluntarily applied to all employees.

New Proposed Hazmat Training Requirements for U.S. Air Carriers (Part 121 and 135) and their subcontractors, and Part 145 Repair Stations.
Docket Number FAA-2003-15085.

The FAA is proposing detailed training requirements, expanding the curricula, adding categories of employees that will need training, extending training to FAA-approved repair stations, and communicating to employees, subcontractors, and repair stations whether the carrier will or will not carry hazardous materials (dangerous goods).

Air carriers will be divided into two groups – those who will carry dangerous goods, and, those who will not carry dangerous goods. Both types of carriers will be required to do more extensive training in identifying undeclared dangerous goods. Subcontractors providing freight and/or baggage handling services will be required to train all of their employees who perform any those functions. Supervisory employees of both the carrier and the freight and baggage subcontractors will have to receive more extensive hazmat training.

As in the past, the training programs must be approved by the FAA, and the present mandatory one year recurrent training requirement will continue to apply to the U.S. Flag Carriers and the subcontractors.

Undeclared Dangerous Goods –

Whether you are a shipper or a carrier or anything related to them your employees must be able to recognize dangerous goods. Many years ago, long before we ever dreamt of using computers, when we thought a website was the place where spiders hung out, we used to send a monthly note along with our invoices alerting transportation related people about hazardous materials that the average person frequently overlooks in terms of regulations. While we may bore some of you, others may well stop and say “I never thought of that.”

Going back all the way to 1976, when we opened out business, we’ll start off with this list. If you would care to make additional suggestions you can e-mail us at info@r-a-specialists.com.

Hazard Class 4 -
A Number of months ago a frequent visitor to our website pointed out that we never addressed class 4 in our monthly attempts to help people who handle dangerous goods to better understand the classification system and the potential dangers concerning these hazard classes.

Division 4.1
Flammable Solids

• Flammable Solids are solid materials that ignite by friction or are easily ignited, such as:
  

  MATCHES – IGNITE BY FRICTION, and,
  STERNO – EASILY IGNITED

Flammable Solids also consist of substances that are:
“Wetted” Explosives…also known as “Desensitized” Explosives.
These chemicals are explosives in the dry state and capable of exploding when subjected to sudden shock or impact. They are downgraded to division 4.1 when they are submerged in water or a phlegmatiser is added to insure stability and reduce the sensitivity to impact. They become less sensitive to shock because of their mud-like state. Urea nitrate is an example of this type of chemical. As a dry solid it is a 1.1D explosive, meaning it is capable of an instantaneous explosion. Adding 10% or more water and/or phlegmatiser reduces the explosion risk, allowing the product to be downgraded to a flammable solid, division 4.1

What is a “phlegmatiser”? We thought you might ask. It is a solid or liquid that is added to explosives and organic peroxides to reduce sensitivity to impact.

Flammable Solids also include,
“Self-Reactive” Substances – materials that are prone to exothermic reactions, a self-accelerating, very rapid fire as opposed to an explosion. Self-Reactive Substances are sensitive to sunlight and heat and are considered to be extremely dangerous.

You won’t find these chemicals listed by their names in any of the dangerous goods tables. You will find them listed according to chemical name, concentration (%), control and emergency temperatures, and U.N. identification numbers. The % and the temperatures are critical to safety in transportation and storage. The listings can be found in 49CFR 173.224; IMDG, Volume 1, 2.4.2.3.2.3; IATA Appendix C-1; ICAO 2-4-4, Table 2.6; and ADR, Volume 1, Part 2, Chapter 2.2, Section 2.2.41.4.

If the chemical name and/or formulation are not listed in those tables the National Competent Authority must be consulted for shipping advice, in writing.

Caution: since temperature is a significant factor in transporting these items safely they are frequently shipped in refrigerated containers or vehicles. Additional cautions must be indicated on the packages. Handling and location in storage are extremely important. Warehouse employees must be constantly alert to the presence of these materials.

Note: All Proper Shipping Names begin with the phrase “Self-Reactive Liquid” or “Self-reactive Solid” but you must start from the appropriate table for proper identification.

Division 4.2
Substances that are liable to spontaneous combustion

Solid materials that retain heat from the manufacturing process or from the transportation environment and may self-ignite, such as coal, charcoal or carbon, and, pyrophoric liquids or solids that ignite when exposed to air. They do not need a source of ignition. Oily fabrics and fibres and human or animal hair are good examples of spontaneously combustible substances. As the fibre breaks down due to decay it builds up heat and then ignites. Note that “fibres” are further identified as animal, vegetable, or synthetic, with oil.

As with the self-reactive substances, package integrity is vitally important to safety. Frequently these spontaneously combustible substances must be packaged under a blanket of nitrogen gas, which is used to displace air (oxygen) from the packaging.

Division 4.3
Substances which, when in contact with water,
emit flammable gases (Dangerous When Wet)

Calcium and Sodium are two classic examples of dangerous when wet materials.

Calcium, when exposed to moisture, releases hydrogen gas (a flammable gas). Pretty dangerous.

Sodium, when exposed to moisture, ignites and is a severe fire risk. Very dangerous.