Hazmat Transportation: Have a Safe Trip
When moving hazardous materials, shippers can’t just send them packing. From preparing for compliance to keeping employees in the loop, here’s how shippers plan for risk-free travels.
Seemingly overnight, even a product that has been used in numerous devices for decades can be considered a hazardous material. Take lithium-ion batteries, for example. In February 2016, the International Civil Aviation Organization (ICAO) announced a new safety measure prohibiting, on an interim basis, all shipments of lithium-ion batteries as cargo on passenger aircraft. Lithium-ion batteries made the news again in September 2016, when the Federal Aviation Administration advised airline passengers not to turn on, charge, or even stow in their suitcases any Samsung Galaxy Note 7 devices. This followed reports of the phones’ lithium-ion batteries igniting. ICAO develops international civil aviation standards and recommended practices.
The announcements show how quickly a product can be considered a hazardous material. Once it is, it’s subject to additional regulations when being transported. "Shippers need to realize that many items, such as lithium batteries, are considered hazardous materials when offered for transportation," says Bob McClelland, dangerous goods manager with UPS Airlines in Louisville, Ky. "To offer such goods, shippers generally have to be trained and/or educated in the requirements to ship that item."
Please Handle With Care
Organizations that want to safely ship or transport hazardous materials need educated employees and effective processes and systems. Failing to act with care and follow applicable regulations can cause injuries and fatalities. It also can ruin a company’s bottom line. Penalties for violating the rules can run into hundreds of thousands of dollars. The reputational risk, should a company’s habit of skimping on safety measures be found to have contributed to an accident, can be ruinous.
"You can’t simply hope for the best when you ship dangerous goods," says Matt Parrott, director of transportation with A.N. Deringer Inc., a provider of integrated supply chain solutions based in St. Albans, Vt.
About 2.6 billion tons of hazardous materials were shipped in 2012, according to Hazardous Materials: 2012 Economic Census: Transportation, a U.S. Department of Transportation report. About 60 percent moved by truck, 24 percent by pipeline, 11 percent by water, and 4 percent by rail.
Those numbers can vary when it comes to specific materials. The breakdown for chemicals is about 55 percent by highway, 20 percent by rail, and 20 percent by water, says Bryan Schlake, instructor of rail transportation engineering with Penn State, Altoona. Railroads tend to have a lower accident rate than trucks because drivers are more regulated, he notes. Because railroads don’t go everywhere, however, many shipments end up on trucks at some point in their journeys.
Rules, Rules, and More Rules
In hazardous material transportation, the Pipeline and Hazardous Materials Safety Administration (PHMSA) plays a role similar to a project manager, says Steven Hunt, president of Oregon-based Shipmate Inc., a hazardous goods training and consulting firm. The PHMSA’s mission is "to establish national policy, set and enforce standards, educate, and conduct research to prevent incidents." It also prepares the public and first responders to reduce consequences if an incident does occur. The Department of Transportation publishes and enforces the rules.
Most regulations governing the transportation of hazardous materials are contained in the Federal Code of Regulations (FCR), Title 49, Parts 100-185. The regulations run for pages, and hazmat shippers and carriers need to understand them.
"Hazardous transportation is highly regulated, and there’s a good reason for that," says Bob Rose, an editor at Neenah, Wis.-based safety manual publisher J.J. Keller. "If it wasn’t, there’d be a lot of holes in the earth."
The Federal Motor Carrier Safety Administration outlines responsibilities that hazmat shippers must meet in order to comply with regulations. First is determining whether a substance meets the definition of a "hazardous material." Completing this step is both critical and difficult. "It is from the proper identification of the hazardous materials that the other requirements are based on," the FMCSA states. Shippers trying to determine if a substance is hazardous can turn to Title 49, section 172.101, of the FCR, which includes the Hazardous Materials Table.
Shippers also need to include specific information with each shipment. "In many cases, shippers write down a phone number and think they’ve complied, but they haven’t," Hunt says. He developed a mnemonic (which forms the name of his company) to help shippers remember the information they need to provide when offering hazardous materials for transport:
- Shipping name: This typically is a chemical name, such as dichloroethylene or trichloroethane.
- Hazard class: This tells in which of the nine classes the material belongs. (See sidebar below.)
- Identification number: This can be found on the Hazardous Materials Table.
- Packing group: I is great danger, II is medium danger, III is minor danger. Certain commodities, such as gases and lithium batteries, don’t have assigned packing groups, Hunt says.
- Mass/volume: This should indicate the total quantity of hazardous materials covered in the description, with an appropriate unit of measurement.
- Additional descriptive information: This may include any special permits, a notice that the substance is poisonous or toxic, or other information.
- Telephone number: This number should be monitored 24/7 while the material is being transported, and should reach a knowledgeable individual who has access to emergency response information.
- Emergency response information: This must include the immediate hazard posed by the material, the risk of fire or explosion, and the immediate precautions to be taken in the event of an accident, spill, or leak, among other information.
In addition, the packages containing the materials need to include the proper shipping name and identification of the hazardous material contained within. The names need to be in English, durable, and not obscured by other labels. Some packages of hazardous materials require additional information.
Put a Placard On It
Bulk packaging, freight containers, unit load devices, transport vehicles, or rail cars containing any quantity of hazardous materials also must comply with placarding requirements. The placards, which must measure at least 250 millimeters (9.84 inches) on each side, let others quickly identify the type of hazardous material contained within, whether explosive or non-flammable gases. They must be placed on each side and end of the vehicle or container.
The placards are "amazingly important," says Glenn Riggs, senior vice president, corporate logistics operations and strategy with Odyssey Logistics, a third-party logistics provider based in Danbury, Conn. "For the emergency response crews, the placards are life or death." They let responders quickly identify the substance that spilled or ignited or otherwise started an accident, so they can determine how to act.
Both carriers and drivers of hazardous materials need appropriate certification. Drivers need a Hazardous Material Endorsement, which requires completing an application, being fingerprinted, and providing identifying documents, such as a driver’s license and passport. The fingerprint enables the government to conduct a criminal background check, while the test covers information such as the proper segregation of commodities and the use of the emergency response system.
Carriers handling certain types of hazardous materials must obtain Federal Hazardous Materials Safety Permits. "These carriers must maintain a certain level of safety in their operations and certify they have programs in place as required by the Hazardous Materials Regulations and the HM Permit regulations," the FMCSA states. Obtaining a permit requires, among other qualifications, a satisfactory safety rating, a satisfactory security program, and proof of insurance.
When it comes to the rules governing the transportation of hazardous materials, "there’s always some degree of tweaking," says Chris McLoughlin, risk manager at C.H. Robinson, a provider of multimodal transportation services and third-party logistics. For instance, in September 2016, the PHMSA proposed an amendment to the regulations to maintain consistency with international standards. This will include changes to proper shipping names, hazard classes, packing groups, and air transport quantity limitations, among others.
Similarly, more changes to battery regulations are coming, McClelland says, noting that the United States has yet to align with the ICAO rules, although it’s expected to do so for U.S.-to-U.S. shipping early in 2017. The ICAO will implement new lithium battery markings in 2017, as well as new requirements to mark packages containing batteries in equipment, such as laptops and cell phones, when more than two packages are in the shipment.
A regulation adopted in May 2015 enhanced tank car standards and operational controls for high-hazard flammable trains, or HHFTs. "The regulation was a big game changer in the rail industry," Schlake says.
The rule was written to deal with the increasing number of trains carrying oil and gas produced from fracking, Riggs notes. Among other changes, the rule imposes speed restrictions, regulates the trains’ braking systems and routing, and changes tank car design standards to improve safety.
The Department of Transportation and the PHMSA currently are studying the levels and structure of insurance held by railroad carriers transporting hazardous materials, and comparing it to the full liability potential for damages resulting from an accident. "The issue in question: Is there a need for some form of supplemental insurance? Is the level of insurance out there adequate?" says Scott Jensen, director of issues communication with the American Chemistry Council. The study is scheduled for completion in April 2017.
Not all changes increase regulations. The Hazardous Waste Generator Improvement Rule, proposed in August 2015, will help retailers and others that may occasionally generate very small quantities of hazardous waste, says Tim Semones, chief operating officer with Plano, Texas-based Quest Resource Management Group, which specializes in designing and managing custom, comprehensive waste minimization solutions. At the moment, for instance, a container of charcoal lighter that spills in a grocery store is technically hazardous waste. The grocery store must follow the applicable regulations.
The proposed bill will allow these businesses to streamline the process. For instance, they can send damaged goods to a central point to be collected, segregated, and tracked, as long as the location is managed by the corporation. Currently, each location needs a program in place to manage the waste. "The cost savings to the retailer is huge," Semones says.
Along with federal regulations, shippers and carriers need to be familiar with the many state regulations regarding hazardous material transportation. For instance, 26 states require transporters of hazardous wastes to obtain special permits or licenses, and 15 states require them to register with the state, according to the National Conference of State Legislatures.
Ready for the Trip
Managing the myriad, changing regulations governing the movement of hazardous materials starts with educated employees. "It is vital for carriers and shippers involved in the transportation of hazardous materials to have personnel on staff who are knowledgeable about the federal hazmat regulations and make safety a top priority," says Megan Bush, manager of safety policy with the American Trucking Associations.
This includes shippers who work with a logistics solution provider. "As a 3PL, we have a firm belief that our customers understand all the rules and regulations that go along with shipping hazardous materials," Parrott says. After all, the shippers need to complete airway bills, certify the hazard class of the material, and provide information on the hazardous substance, among other responsibilities. In short, they need to know what they’re asking the carrier to transport.
Shippers also need to know their carriers, says Joe Beacom, vice president and chief safety and operations officer with Landstar, Jacksonville, Fla., which provides integrated transportation solutions. Shippers should ask about a carrier’s safety record, which is available through the FMCSA’s Safety and Fitness Electronic Records (SAFER) system. The site also allows shippers to check the status of a carrier’s permit to transport hazardous materials.
It’s also smart to ask about the carrier’s experience working with the commodity being shipped, and to confirm it has experts available 24/7 if an emergency occurs. "The biggest step is having a dialogue about how to resolve issues," Beacom says.
The carrier should have insurance and be financially stable. "Shippers don’t want a carrier that operates on razor-thin margins and might cut corners," Riggs says.
Traceable, Visible, Accountable
Technology is another key to safe hazardous material transportation. Managing the movement of hazardous materials requires "traceability, visibility, and accountability," says Richard Howells, global vice president of extended supply chain with software solutions provider SAP. Traceability helps shippers track down goods in case of a recall, visibility allows them to see where the materials are, and accountability lets them know who touched the product and who has the authority and skill to move it.
Modeling technology enables companies to create a digital representation of an entire supply chain, including the relevant regulations, says Toby Brzoznowski, executive vice president with Llamasoft, a supply chain solutions provider based in Ann Arbor, Mich. This allows the organization to identify an optimal logistics network that also complies with regulations.
The universe of robust transportation management systems at all price points continues to expand, Beacom says. That makes it easier for even smaller shippers to more effectively manage the regulatory and documentation requirements that accompany hazardous material transportation.
Technological advances extend to the containers and packaging used with hazardous materials. The American Transportation Research Institute continually works to improve safety devices, such as braking systems, forward visibility, and blind spot detection, McGloughlin says.
UPS has devised and implemented fire-resistant aircraft containers, fire containment covers for cargo pallets, and quick-donning full-face oxygen masks for crew positions on every aircraft. "These steps and others provide a multi-layered approach that drastically reduces the risk of a significant incident due to an issue with lithium batteries or other hazardous material on an aircraft," McClelland says.
Leading the Charge to Innovation
The innovations will continue. Some researchers are working on devices that measure the state of charge in lithium-ion batteries, for example. It’s not easy; the batteries decay in an exponential, rather than linear rate, and if the state of charge is reduced too much, the battery becomes nothing more than a paperweight, Hunt says. Yet, this work should lead to products that can be transported with less risk.
Another area receiving attention is Positive Train Control (PTC), which allows a train to be remotely controlled if, for instance, the conductor becomes incapacitated. In 2008, Congress mandated PTC implementation on certain passenger railroad lines, as well as those that transport materials that are poisonous or toxic when inhaled.
The original PTC implementation deadline of Dec. 31, 2015 was extended to Dec. 31, 2018. The initial deadlines "didn’t fully recognize the complexity of the technology," Jensen says, adding that the technology needs to work on all rail systems in operation. But it’s clear that Congress wants to move forward. A Federal Railroad Administration status update in August 2016 underscored "the need for railroads to implement Positive Train Control as quickly and safely as possible."
Another technology that may play a greater role in hazardous material transportation is the Internet of Things (IoT), Howells says. As this technology advances, and as the cost of sensors drops, it will be possible to monitor shipments to ensure, for instance, that those requiring controlled temperatures remain free of tampering.
While technology and training help companies ship hazardous materials more safely, logistics professionals also need to continually review their supply chains to identify ways to reduce inherent dangers. That could mean reducing product toxicity, or shortening the distances the hazardous materials have to move, Schlake suggests.
As logistics professionals look for ways to reduce these dangers, they also need to ensure the hazardous materials in their supply chains move safely, efficiently, and in compliance with regulations. That requires informed employees; processes and systems that provide visibility, facilitate compliance, and streamline recordkeeping; and packages and containers that keep their materials safe.
Hazardous Material Classifications
The U.S. Department of Transportation organizes hazardous materials into the following nine classes:
- Flammable liquids and combustible liquids
- Flammable solids, spontaneously combustible and dangerous when wet
- Oxidizers and organic peroxides
- Poisons (toxic) and poison inhalation hazards
- Radioactive materials
- Corrosive materials
The spectrum of materials considered hazardous ranges from radioactive materials to items “consumers might have under their sink at home,” says Chris McLoughlin, risk manager at C.H. Robinson, a provider of multimodal transportation services and third-party logistics.
Along with the material itself, volume comes into play when calculating just how hazardous a shipment is. Acetone, a primary component of nail polish remover, is a flammable liquid. A small bottle typically can be moved safely. “But 7,000 gallons of acetone in a tank becomes dangerous because of both vapors and flammability,” says Glenn Riggs, senior vice president, corporate logistics operations and strategy with logistics solutions provider Odyssey Logistics.