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…
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 MissionDOT Mission
“...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
DOT MissionDOT Mission
“...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
DOT HazMat TrainingDOT HazMat Training
Fast?
Efficient?
Accessible?
Convenient?
“So why are they always busting my chops about shipping a little package?”
DOT HazMat TrainingDOT HazMat Training
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.
DOT HazMat TrainingDOT HazMat Training
“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.”
DOT HazMat TrainingDOT HazMat 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.
Hazardous Material DefinitionsHazardous Material Definitions
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
Hazardous Material DefinitionsHazardous Material Definitions
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 #
RecordkeepingRecordkeeping
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. Identification Number..... UN 1090 2. Proper Shipping Name....
Acetone 3. Hazard Class/Division..... 3 4. Packing Group................ PG II
Identification NumberIdentification Number
UN1263, Paint, 3, PGII
Proper Shipping NameProper Shipping Name
UN1263, Paint, 3, PGII
Hazard ClassHazard Class
UN1263, Paint, 3, PGII
Packing GroupPacking Group
UN1263, Paint, 3, PGII
Shipping PapersShipping Papers
Hazmat entries must include:• Basic Description• Total quantity shipped• Any additional data• ER information• Certification
FedEx UpdateFedEx Update
Beginning 1/1/2011• Must use typed or computer generated shipping
papers for HazMat
Beginning 8/1/2011• HazMat paperwork must be submitted electronically.
Shipping by air or international?Beginning 1/10/2011• HazMat paperwork must be prepared using software
with compliance checks.
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?