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Creating an Effective Shipping Program

Creating an Effective Shipping Program David R. Gillum, MS Laboratory Safety Officer University of New Hampshire http://www.unh.edu/ehs/shipping.htm © 2004-2007. University of New Hampshire. Introduction A shipping program is needed to help you achieve:

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Creating an Effective Shipping Program

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  1. Creating an Effective Shipping Program David R. Gillum, MS Laboratory Safety Officer University of New Hampshire http://www.unh.edu/ehs/shipping.htm © 2004-2007. University of New Hampshire.

  2. Introduction • A shipping program is needed to help you achieve: • Standardization in shipping techniques. • Conformity to carrier requirements. • Compliance with international, federal, state and local regulations. • Most importantly, a shipping program will help avoid potential fines and imprisonment.

  3. Imprisonment • A person who knowingly violates the Federal hazardous material transportation law shall be fined or imprisoned for not more than 5 years, or both. (49 CFR Part 107.333)

  4. Shipping Fines/Penalties • Potential shipping fines and penalties • Civil: $32,500 maximum per day of offense: • Not less than $275 per day of offense. • Criminal: $500,000 maximum and/or up to 5 years in prison. • Agencies that may levy fines include: • Department of Transportation (DOT). • Bureau of Industry and Security (BIS). • Federal Aviation Administration (FAA). • Federal Motor Carrier Safety Administration (FMCSA). • Research and Special Projects Administration (RSPA). • Coast Guard. • Others. $ $ $

  5. Example DOT Fines • University Of Pennsylvania Health System, Inc. • Shipped regulated medical waste in unauthorized packaging. • $4,900. • Pepsi-Cola & National Brand Beverages, Ltd. • Shipped carbon dioxide in cylinders that had not been visually reinspected or hydrostatically retested within the last five years; • Included a shipping paper that listed an incorrect 24-hour emergency response telephone number; • Failed to provide recurrent employee training or create and retain records of training testing. • $7,350.

  6. Example DOT Fines • Exxon Corporation • Shipped combustible liquid, n.o.s.* (containing terpene hydrocarbons) in a portable tank marked as meeting the DOT 57 specification that had not been hydrostatically retested within the past 2.5 years; • Shipped jet perforating guns in packages not marked with a proper shipping name and identification number and not affixed with the required hazard class warning label. • $4,500. * Not otherwise specified.

  7. Reasons for DOT Shipping Fines • Civil Penalties (49 CFR Part 107.329) • Knowingly or willfully: • Violating the Federal hazardous material transportation law. • Shipping or transporting hazardous materials illegally. • Illegally manufacturing, fabricating, marking, maintaining, reconditioning, repairing, or testing packaging or containers which are represented, marked, certified or sold as being qualified for use in the transportation of hazardous materials. • Criminal Penalties (49 CFR Part 107.333) • Knowingly violating a provision of the Federal hazardous material transportation law or an order or regulation issued thereunder.

  8. Example FAA Fines • Revlon - $60,000 on March 31, 2003 • Improperly shipped three one-ounce glass containers of perfume through UPS. • Suitt Construction - $70,000 on March 18, 2003 • Improperly shipped a concrete cutting saw containing gasoline, a flammable liquid, through FedEx (Federal Express) • Durability, Inc. - $84,000 on March 18, 2003 • Improperly shipped a 118 ounce metal container of lacquer through UPS. • World Courier, Inc.- $84,000 on January 16, 2001 • Improperly shipped an infectious substance affecting humans (Aspergillus species) by air.

  9. Reasons for FAA Fines • Hazardous materials were not properly packaged, marked, classified, documented, etc. for shipment. • Failed to train employees to properly package and handle hazardous materials. • Failed to provide emergency response information. http://www.faa.gov/apa/PR/SAFETY/Safety_Archive.cfm

  10. Summary of Fines and Penalties • Failure to meet shipping regulations mayresult in the loss shipping privileges. • Hefty fines and imprisonment may also be served to individuals who ignore DOT and IATA regulations. • Only trained persons and certified organizations may ship or receive shipments of hazardous materials.

  11. When is a shipping program needed? • A written shipping program is necessary when your organization ships or receives: • Hazardous chemicals. • Compressed gases. • Infectious materials. • Radioactive materials.

  12. Writing the Program • Brainstorm and develop a simple outline: • Acquire administrative support. • Identify current practices. • Identify training requirements. • Identify individuals affected. • Identify who needs to be trained. • Identify recordkeeping requirements. • Considerations: • Regulatory requirements. • Carrier-specific requirements. • Institutional-specific requirements.

  13. Acquire Administrative Support • Discuss the following with senior administration: • Regulatory requirements. • Potential fines and incarceration. • Potential loss of shipping privileges. • Potential for bad publicity.

  14. Identify Current Practices • Identify any current shipping procedures or practices. • Identify where hazardous materials are shipped or received, including: • Central locations. • Individual locations. • Remote locations.

  15. DOT Training Requirements • Required for facilities or personnel who: • Ship hazardous materials. • Package, mark, or label hazardous materials for transportation. • Load or unload hazardous materials. • Transports hazardous materials. • Receives or forwards packages containing hazardous materials.

  16. DOT Training Requirements • “Hazardous Materials Employees” • Any employee who directly affects hazardous materials transportation. • Includes personnel who: • Loads, unloads, or handles hazardous materials; • Manufactures, tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packaging as qualified for use in the transportation of hazardous materials; • Prepares hazardous materials for transportation; • Is responsible for safety of transporting hazardous materials; or • Operates a vehicle used to transport hazardous materials. • Must be trained in general awareness/hazard familiarization, function-specific, safety, and security-awareness training every three years.

  17. DOT Training Requirements • “Hazardous Materials Employees” also includes personnel responsible for: • Filling hazardous materials packagings. • Closing or securing hazardous materials packagings. • Selecting, providing or affixing placards. • Filling out or reviewing shipping papers. • Certifying hazardous materials are in proper condition for transport. • Providing or maintaining emergency response information. • Transferring hazardous materials at an intermodal transfer facility from one bulk packaging to another for the purposes of continuing transport.

  18. DOT Training Requirements • US Department of Transportation (DOT) • Does not specify sources of training. • Does not specify minimum hours of training. • Does not certify training courses, instructors, and/or schools. Regulations: 49 CFR 172.700-704

  19. DOT Training Requirements • It is the employer’s responsibility to determine the adequacy of the training being presented: • Training may be in any appropriate format including lecture, conference, self paced instruction, interactive video, etc. • Frequency of training: • Initial training within 90 days of employment. • Refresher training every three years.

  20. DOT Training Requirements • General awareness/familiarization: • General awareness and familiarization training is intended to raise the hazmat employees awareness of the HMR and the purpose and meaning of the hazard communication requirements. All hazmat employees must have this training. • Function-specific training: • Function specific training is intended to teach the necessary knowledge, skills, and abilities for an individual's job function. • Safety training: • This training provides information concerning the hazards posed by materials in the work place and proper personal protective equipment. The training may include basic emergency response procedures but is not intended to satisfy the requirements of 29 CFR 1910.120. • Modal specific requirements: • Any additional training required by 49 CFR Parts 174, 175, 176, or 177.

  21. IATA Training Requirements • International Air Transport Association (IATA) • Training applies to anyone who ships air-regulated hazardous materials • Frequency • Initial training required before air shipments are made. • Recurrent training must take place within 2 years of initial training. • Trainers and courses may be IATA certified.

  22. Record Keeping Requirements • DOT regulations require a copy of all shipper’s declarations be retained for 375 days. • Hazmat employers must retain a copy of training records for: • 3 years, or • 90 days after an employee leaves their hazmat position or company. • The training records must include: • The hazmat employee’s name. • The most recent training completion date of the hazmat employee’s training. • A description, copy, or the location of the training materials used to meet the training requirements. • The name and address of the person providing the training. • Certification that the hazmat employee has been trained and tested.

  23. Applicability • Shipping regulations are applicable (under most circumstances), when a person or organization ships or transports hazardous materials by: AIR RAIL SEA ROAD

  24. Regulations • Domestic Laws (U.S. Shipping Regulations) • 49 CFR Sections 171-180: • Hazardous materials regulations: • Part 174: Carriage by rail. • Part 175: Carriage by aircraft. • Part 176: Carriage by vessel. • Part 177: Carriage by public highway. • 42 CFR Section 72. • Shipping etiologic agents. • 15 CFR Part 774, Supplement 1, Chapter VII: • Export requirements.

  25. Regulations • Foreign Laws • Requirements for import and export permits: • International. • Domestic: • Interstate. • Intrastate.

  26. A Good Shipping Program • Once completed, the shipping program should help you: • Properly ship hazardous materials. • Avoid potential fines and imprisonment. • Explain hazard labels and placarding. • Demonstrate proper packaging requirements. • Impress friends at parties. 

  27. Don’t Re-Invent the Wheel • Excellent resources exist to help you with the development of your shipping program, including: • University of New Hampshire: • http://www.unh.edu/ehs/shipping.htm • FedEx: • http://fedex.com/us/services/express/addservopt/dangerousgoods/ • UPS: • http://www.ups.com/content/us/en/resources/prepare/hazardous/index.html • USPS: • http://www.usps.com/ • http://www.usps.com/cpim/ftp/pubs/pub52.pdf • Private companies/consultants specializing in hazmat shipping training.

  28. Thank you! • Andy Glode, UNH Shipping Specialist • Bradford Manning, UNH OEHS Director • Ken Brown, UNH Hazardous Materials Coordinator • Rebecca Ryan, BU Biosafety Officer • Jeffrey Owens, GSU Biosafety Officer • Debra Sharpe, SRI EH&S Manager

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