Proper Hazmat Training Needs to Catch Fire
Hazmat shipments are a common feature of U.S. supply chains. Yet for many businesses, training does not match the frequency with which these products are moving. In 1996, 800,000 movements of hazardous material were made daily in the United States, according to U.S. Department of Transportation (DOT) estimates. Conservative estimates today put that number closer to 1.2 million daily hazmat movements.
Batteries, paint, and perfume top the list of common hazmat violations, a group that also includes cologne, film remover, hairspray, printing ink, nail polish, and an assortment of engine parts for land, marine, and air transport.
From 2000 to 2003, the Federal Aviation Administration (FAA) actively promoted a program that issued formal press releases for all hazmat fines equal to or greater than $50,000.
Analyzing a sampling of the FAA fines leads to some conclusions that should interest logisticians moving hazardous materials. The analysis also shows that support service personnel contribute significantly to the unsafe and non-compliant movement of hazardous products.
From this analysis, two key issues need to be addressed:
- The problem of non-compliance with hazmat regulations is not unique to any sector of the economy and is unaffected by company size or mission.
- The bulk of the fines are for shipments of relatively small amounts of actual hazmat products.
Here's an example that typifies these types of fines. Heavy equipment manufacturer Terex was fined for shipping paint; but Terex is not in the paint supply or the equipment-painting business. So the fine was not directly related to its primary product, normal order process, or core competency.
The Right Stuff
The issue seems to be providing training to the right staff. In this area, the commercial sector takes its lead from the compliance/enforcement agencies, which all focus on shippers, receivers, and transporters. Other entities cannot easily access the more typical aggregate or macro data for proper analysis ≠ they can only respond and react to an immediate triggering event. Their operational managers never get to see the big picture.
The 49 CFR (Code of Federal Regulations for Hazmat Materials) is well-written and contains well-defined training requirements. But the way the enforcement community, especially the DOT, has interpreted and applied that requirement has not set the proper tone and has moved training in the wrong direction.
The DOT, Pipeline and Hazardous Materials Safety Administration (PHMSA), and the FAA do not properly review non-compliance data or individual cases to identify trends and understand business implications. Those organizations only look at the "hazards," ignoring the business operations that created those violations.
Since the implementation of HM-181's hazmat protocol more than 10 years ago, the DOT has continued to use the narrowest lens when addressing function-specific training and the application of 49 CFR in the commercial world. Enforcement has essentially focused on the shipping cycle. But the bulk of the problems, and therefore liability issues, stem from the "order" or "logistics/customer service" cycle and that concept continues to get sort shrift from regulators.
From a practical standpoint, proper training can be accomplished relatively inexpensively with minimal impact on production/operations. Providing appropriate instruction speeds order processing while reducing organizational and individual exposure and liability.