Last week we began looking at our Top 10 Hazmat Violations for 2020. Let’s finish the countdown to number one. An ounce of prevention is worth a pound of cure!
5. The vehicle was not placarded [49 CFR 172.504(a)]. If a vehicle contains hazardous materials, it must be placarded unless an exception exists. The most common exceptions include:
- Less than 1,001 lbs. gross aggregate weight of Table 2 materials
- A rail car loaded with transport vehicles or freight containers, none of which is required to be placarded.
- Class 9 materials for domestic transportation
- A vehicle containing only Limited Quantity packages.
For a list of exceptions see 49 CFR 172.504(f). When placarding is required, the vehicle must be placarded on both ends and both sides.
4. Shipping papers not accessible [49 CFR 177.817(e)]. A driver of a motor vehicle containing hazardous material must ensure that the shipping paper is readily available to, and recognizable by, authorities in the event of accident or inspection. The driver must do the following.
- Clearly distinguish the shipping paper, if it is carried with other shipping papers or other papers of any kind, by either distinctively tabbing it or by having it appear first; and
- Store the shipping paper within his immediate reach while he is restrained by the lap belt where it is readily visible to a person entering the driver’s compartment (e.g., on the seat next to him) or mounted to the inside of the driver’s side door.
3. No shipping papers [49 CFR 177.817(a)]. When required, the carrier must have shipping papers to transport hazardous materials. Only a few types of hazmat shipments do not require shipping papers. Examples include limited quantity packages shipped by ground, excepted lithium batteries, and excepted radioactive packages.
- There is no standardized DOT hazmat shipping paper form. The offeror may present a bill of lading, invoice, or their own formatted shipping paper.
- When shipping an EPA hazardous waste, the generator must offer a Uniform Hazardous Waste Manifest. If the generator has prepared the manifest on the EPA’s eManifest system, they must present a printed hard copy to the driver.
2. No copy of the US DOT Hazmat registration [49 CFR 107.620(b)]. Each motor carrier transporting hazardous materials must carry a copy of its current Certificate of Registration issued by PHMSA or another document bearing the registration number identified as the “U.S. DOT Hazmat Reg. No.” on board each truck and truck tractor (not including trailers and semi-trailers).
- A good management practice for the carrier is to use a readiness checklist.
- The Certificate of Registration or document bearing the registration number must be made available, upon request, to enforcement personnel.
Finally, representing 11.34% of hazmat violations, the number 1 hazmat violation is…
1. Package not secured in the vehicle [49 CFR 177.84 (a)]. Any package containing hazardous material must be secured against shifting, including relative motion between packages, within the vehicle on which it is being transported, under conditions normally incident to transportation (e.g., shocks, bumps, sharp turns, and vibrations). This can be accomplished by using:
- Wood or metal beams to block and brace the cargo;
- Tie-downs, fasteners, lashing or strapping;
- Crosswise bracing with dunnage air bags;
- Plywood and particle board dividers;
- Honeycomb, dropdown, and other void fillers;
- Fabric load restraints; and
- Overpacks for added protection and stability.
The maximum civil penalty for a hazmat violation is a hefty $81,993 per day. However, it is not difficult to comply with any of these mandates. What is needed is a system for double checking that all is in order before the vehicle leaves the premises.
What Can STARS Do For You?
STARS can create a visual guide for your employees as well as simple checklists to ensure compliance for each step of the shipping process. We can also provide specifically tailored training to cover your materials, shipping devices, and modes of transportation.