DOT HazMat Shipping Compliance

DOT HAZMAT SHIPPING COMPLIANCE

KPA – Company ProfileKPA – Company Profile

• Nationwide compliance expert on Safety, Environmental, HR

• Colorado Headquarters

• 23 Years Experience • 3000 + Clients

– Dealerships, Service, Repair

• 20 Offices Serving 41 States

• Compliance products and services

– OSHA– DOT– EPA– Workers’ Comp– Background checking– Onboarding– Harassment – Red Flags– Onsite inspections– Online and onsite

training and tracking– And many more…

Presented byPresented by

Peter ZaidelKPA Product [email protected]

303-228-2397

QuestionsQuestions

• If you have questions during the presentation, please submit them using the “Questions” feature

• Questions will be answered at the end of the webinar

Webinar OverviewWebinar Overview

• Why training?• Recent regulatory activity• The audit process and regulator procedures• DOT Shipping Requirements• Preparing for Shipment• Shipping by Air• Parts and Mobile Services• Training Options

This webinar does not provide certification

DOT, FAA, TSA oh my!DOT, FAA, TSA oh my!

DOT HazMat TrainingDOT HazMat Training

“...ensuring a fast, safe, efficient, accessible and convenient transportation system that meets our vital national interests and enhances the quality of life of the American people, today and into the future...”

DOT’s mission is


“...ensuring a fast, safe, efficient, accessible and convenient transportation system that meets our vital national interests and enhances the quality of life of the American people, today and into the future...”

DOT’s mission is


Fast?

Efficient?

Accessible?

Convenient?

“So why are they always busting my chops about shipping a little package?”


ValuJet Flight 592

1996 Florida Everglades crash that killed 110 people.

In 1996 a subcontractor failed to properly mark, label and package a shipment of oxygen generators in the plane’s cargo hold.

This hazardous materials shipment caused a fire that quickly brought down the plane into the Florida Everglades, killing all of the passengers and crew aboard.


“Let me stop you right there – our facility almost never ships HazMat items”

“We now have a policy that we do not ship hazardous materials at all, so we don’t need the training.”


• ValuJet tried to avoid dealing with HazMat regs by issuing a policy that they wouldn't transport HazMat.

– Thus ValuJet personnel weren't trained to watch for HazMat.

• A vendor presented the O2 generators as non-haz.

– If ValuJet staff had been properly trained, they would have connected "oxygen generator" with the definition of "Oxidizer" Hazard Class, and refused the shipment.

• If they had known to refuse the shipment it would have saved 110 people's lives.

Recent Regulatory ActivityRecent Regulatory Activity

DOT Standard Penalty Description of issue

49 CFR 172.702 $860,000 Toyota – 6 boxes containing shock absorber or paint

49 CFR 172.702 $192,500 Valvoline – 1 box containing 4 gallons of tire dressing

49 CFR 172.702 $150,000 Honda – 1 fuel pump with residual fuel

49 CFR 172.702 $72,000 Chrysler – 12 containers of Tire and Wheel Cleaner

49 CFR 172.702 $59,500 Acura – 1 Lead Acid Battery

Dealer shuts down FedEx FacilityDealer shuts down FedEx Facility

$50,000+ in fines

Regulatory ProceduresRegulatory Procedures

1. Go to Airports2. Pull HazMat Shipping Papers3. Visit facility and audit signer of air bill4. Call 24 hour emergency # while on site5. Audit facility programs and procedures

Inspectors have a weekly quota for audits

IS REQUIRED TO REPORT IT!

A receiver of an improperly packaged shipment

The AuditThe Audit

• Function specific training completed• List 24 hour shipping hotline• Recertified every 3 years• Certified within 90 days of hire

DOT Shipping Requirements

Hazardous Material DefinitionsHazardous Material Definitions

Hazardous material (Hazmat), means a substance or material, which has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated. The term includes hazardous substances, hazardous wastes, marine pollutants, and elevated temperature substances.


Hazmat Employer means a person who uses one or more employees in connection with:

– Transporting hazmat in commerce; or– Causing hazmat to be transported or shipped in commerce; or– Representing, marking, certifying, selling, offering,

reconditioning, testing, repairing or modifying packaging as qualified for use in the transportation of hazmat


Hazmat Employee means a person who is employed by a Hazmat employer and directly affects hazmat transportation safety including:

– An owner-operator of a motor vehicle which transports hazmat– A person (including a self-employed person) who:– Loads or handles hazmat;– Tests, reconditions, repairs, modifies, marks, or otherwise

represents packaging as qualified for use in the transportation of hazmat;

– Prepares hazmat for transportation;– Is responsible for safety of transporting hazmat; or– Operates a vehicle used to transport hazardous materials

Training Requirements Training Requirements

DOT Hazmat employees must receive training:• Within 90 days of new hire• Every 3 years• When proficiency or understanding is not demonstrated

DOT Hazmat employees must receive the following training:• General Awareness Training• Function Specific Training• Security Awareness Training

24 Hour Emergency Contact Information24 Hour Emergency Contact Information

• Monitored at all times the hazardous material is in transportation, including storage

• The person monitoring the number has knowledge of the material and emergency response information

• Placed on hazardous material shipping papers

Regulatory UpdateRegulatory Update

Third Party 24 Hour Emergency Number• Must link back to original Shipper• Facility Name on Shipping Papers• Account Number on Shipping Papers

Facility Name 24 hour number Account #

http://www.chemtrec.com/Chemtrec/default.htm

DOT Hazmat Program DOT Hazmat Program

Use KPA binder to maintain your DOT Hazmat Training information and certificates

– Certificates must be kept for 3 years for current employees and 90 days for employees that have recently resigned

Add Training to Parts employee new hire packet and those signing hazardous materials shipments

Preparing for Shipment

The Hazardous Materials RegulationsThe Hazardous Materials Regulations

The process of complying with the HMR centers around the Hazardous Materials Table (HMT):

Filling out the Shipping PaperFilling out the Shipping Paper

Basic Description

1. Proper Shipping Name....Acetone

2. Hazard Class/Division..... 3 3. Identification Number..... UN

1090 4. Packing Group................ PG II These four elements MUST appear in this order!

Proper Shipping NameProper Shipping Name

Hazard ClassHazard Class

Identification NumberIdentification Number

Hazardous Materials TableHazardous Materials Table

Shipping PapersShipping Papers

Hazmat entries must include:• Basic Description• Total quantity shipped• Any additional data• ER information• Certification

Specification PackagingSpecification Packaging

To Be Designated as a “DOT Approved Container” HM Containers Must Meet Performance Tests

United Nations symbolMaximum container weightUN1A2/Y/S/100

96/USA/1443

Type of container

Year of manufacture

Country of manufacture Manufacturer’s DOT number

Packing group

Container is for solids

Packaging will have a Certification #

• DROP TEST• LEAKPROOFNESS TEST• HYDROSTATIC PRESSURE TEST• STACKING TEST

LabelingLabeling

• Identify & communicate the hazards within the package

• Correspond to the hazard class/division of the material in the package

• 24 different DOT labels• Column 6 of the HMT (172.101) determines the

label(s) required for a material

Completing the Shipment

Shipments by AirShipments by Air

• IATA Dangerous Goods Regulations• FedEx and UPS Requirements• International Shipments• Increased scrutiny

Parts Trucks and Mobile ServiceParts Trucks and Mobile Service

• Materials of Trade (MOT) exemption• Shipping Papers and Emergency Response• Exempted materials• Interstate Commerce

Training OptionsTraining Options

• Online• Offsite• Onsite

Don’t forget the 24 hour emergency number

Questions?

Business

DOT HazMat Shipping Compliance