Fire Safety
Fire Prevention Week 2019

Anyone that has taken a training class with me discovers my secret love of superheroes.  There is just something about them that makes life fun.  They show up in all sorts of places during training.  From signatures on shipping documents to addresses on packages, it is just a little something to make training a little less boring.  I bring this up because the National Fire Protection Association (NFPA) has designated the week of October 6th-12th as Fire Prevention Week.  This year’s theme is – Not every hero wears a cape.  Plan and Practice Your Escape.

According to the NFPA website, some home fires can limit a family to only one or two minutes of time to get out and reach safety.  Let that sink in for just a little bit. Two minutes is not a lot of time to make life saving decisions.  This is why the goal of this year’s week is to have people make their own home escape plans AND to practice them. 

There are tons of resources on the NFPA site to help you.  Simply go to  https://www.nfpa.org/Public-Education/Staying-safe/Preparedness/Fire-Prevention-Week to see all of the options.  There are videos, activities for children, games and safety tip sheets. Many of these are free to download and use. In an effort to learn more about this year’s theme, I downloaded the Escape Planning Tips sheet on the website.  Continue Reading…

IATA
IATA 61st Edition Significant Changes

The Labor Day Holiday generally symbolizes the end of summer for many people.  For many businesses it is the end of their fiscal year.  For parents in many areas it means back to school.  For the Pipeline and Hazardous Materials Safety Administration (PHMSA) it means releasing notices of proposed rulemakings.  We also have OSHA publishing their Top Ten Violations.  Finally, it is time for IATA to publish the list of significant changes for their upcoming edition.

Keep in mind, these changes are in the 61st edition of the IATA.  It goes into force January 1, 2020.  The other thing to remember is these are just a list of “significant” changes.  Some of the changes always seem a bit cryptic to me.  Plus, I’m one of those folks that takes the old one and compares it to the new one to better understand exactly how it changed.  Guess it comes from being a visual learner.

If you should want to read the list of changes, it can be found here.  A brief overview of some of the changes are shown below for quick reference.  There is a little something for everyone in the industry.  As you read through, there are some times where I added some information to supplement the change as it is stated on the publication.

Brief Summary of Some Proposed Changes by Section:

Superstitions in Reference to Safety – Take 3

Another Friday the 13th is upon us.  This is the third time we will look at a few superstitions to see if there is any benefit to us in regards to safety.  Keep in mind I am using superstition in a broad sense. For this blog, a superstition is any idea or belief that may not be entirely rational or scientific but is still used today.

Superstition #1:  Holding Your Breath While Passing a Cemetery

Death is always an odd subject that triggers varied reactions in people.  For many it is a sad time due to the loss of a loved one or friend.  A wake and funeral are held to honor their passing.  For others it is a chance to celebrate someone’s life, like the Second Line Parades in New Orleans.  For this particular superstition, you are supposed to hold your breath to prevent recently passed or evil spirits from possessing you to live life again.

From a transport point of view, this probably isn’t too great of an idea and should never be done.  In fact, there are several published articles in medical journals stating the negative effects of holding your breath for too long.  Some of the negative impacts are issues with blood sugar, coordination and even neurological damage.  Imagine a truck driver holding his breath as he passes a cemetery, especially a large one that Continue Reading…

PHMSA Civil Penalties Increase 2019

Effective July 31, 2019 the fines for civil penalties within the Department of Transportation are increased.  This increase impacts the Federal Aviation Administration (FAA), the Pipeline of Hazardous Materials Safety Administration (PHMSA), the Federal Railroad Administration (FRA), the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA). 

The fines are increased as a result of the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.  This happens every year, so you would think it would have an abbreviation at this point.  This act basically requires federal agencies to adjust civil penalties each year to account for inflation.  A list of the increases for 49CFR is shown below.  These are found in 49CFR Part 107. A definition for “Penalties of non-compliance” is found in 171.1.  To see the full ruling with the changes to the other agencies, go here

PHMSA Adjustments:

  • Maximum penalty for a hazardous materials violation is $81,1993.
  • Maximum penalty for hazardous materials violation that results in death, serious illness, or severe injury to any person or substantial destruction of property is $191,316
  • Minimum penalty for hazardous materials training violations is $493.   
  • Maximum penalty for each pipeline safety violation is $218,647
  • Maximum penalty for a related series of pipeline safety violations is $2,186,465
  • Maximum penalty for liquefied natural gas pipeline safety violation $79,875
  • Maximum penalty for discrimination against employees providing pipeline safety information = $1,270

Keep in mind Continue Reading…

World Hepatitis Day

Since 2010, World Hepatitis Day is observed on July 28th.  The goal is to raise awareness of hepatitis as well as the prevention and treatment of the disease.  According to the World Health Organization (WHO), hepatitis cause two in every three liver cancer deaths and overall 1.34 million deaths a year.  We all need to be educated.  This is not a disease found in just one country, a particular ethnicity or age.  Here is the chance to educate ourselves. 

Hepatitis is the inflammation of liver tissue.  It is most commonly caused by a virus and there are five main ones commonly referred to as Types A, B, C, D and E.  Types A and E are usually short-term (acute) diseases.  Types B, C, and D are likely to become chronic.  Type A is contracted by direct contact with fecal matter or drinking water contaminated with fecal matter.  that has the virus in it.  Type E is the result of indirect contact with fecal contaminated food and water.  This is why many people are under the misconception that you can only get hepatitis in 3rd world countries where sanitation is not the best.  Types B and C are caused by contact with an infected person’s bodily fluids such as blood. Type D can only happen if someone is currently infected with Type B.

This year’s theme is to “Find Continue Reading…

Eureka Moment with Batteries

Every year when teaching the concept of density to high schoolers, I would use the story of Archimedes and the king’s crown. They really enjoyed the part of him running naked through the streets shouting, “Eureka, I have found it.” Since that time, the concept of “eureka moments” has become a thing. The moment you finally realize, understand, or discover something is a “eureka moment”.

My most recent one occurred while updating ICC’s lithium battery courses. You see, I’ve always struggled with a few paragraphs in 49CFR 173.185. The paragraphs in question are (c)(1)(iii) and (c)(1)(iv) for those smaller or “excepted” cells and batteries. My brain just couldn’t comprehend or truly understand what they were telling me. Add to that the changes brought in by the interim final rule HM-224I and my brain was just fried. Both paragraphs are shown below for your reference.

173.185(c)(1)(iii)
Except when lithium cells or batteries are packed with or contained in equipment in quantities not exceeding 5 kg net weight, the outer package that contains lithium cells or batteries must be appropriately marked: “PRIMARY LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”, “LITHIUM METAL BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”, “LITHIUM ION BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT” or labeled with a “CARGO AIRCRAFT ONLY” label specified in §172.448 of this subchapter.

173.185(c)(1)(iv)
For transportation by highway or rail only, the lithium content of the cell Continue Reading…

Lithium ION Battery Phrase Confusion with HM-224I

Laurel and Hardy the comedy duo from the 1930’s coined the phrase, “Well, here’s another nice mess you’ve gotten me into.” Sadly, I believe this is the situation DOT created with HM-224I which is an interim final rule published in March.  When this new rule is taken into account along with the general frustration many shippers face when shipping lithium batteries, it is easy to see how the mess was made.

Basically, here’s what happened.  The 49 CFR can be used to make air shipments along with going by ground and vessel.  In the “old” version of the regulations, you were allowed to put lithium ion batteries on passenger planes as long as the net weight of the batteries was below 5 kg.  Well, DOT has finally admitted it is NOT a good idea to put lithium ion batteries on passenger aircraft.  They also wanted to be in closer alignment with the IATA which restricted ion batteries to cargo planes just a few years ago.  This is where HM-224I comes into play.

One of the biggest changes is the addition of a phrase to section 173.185 for small powered or excepted batteries.  It is paragraph (c)(1)(iii) that is causing the most trouble.  Keep in mind nothing changed with the existing phrases in this paragraph. It is simply a matter of a new one being added.  Also, this paragraph Continue Reading…

International World Day for Safety and Health at Work

The International Labour Organization (ILO) was created in 1919.  It is a United Nation’s agency that sets standards, policies and programs for the work force.  Comprised of workers, employers and governments the main goals are to “promote rights at work, encourage decent employment opportunities, enhance social protection and strengthen dialogue on work-related issues.”  Each branch, if you will, has equal footing in regards to what programs and actions are implemented.  

Starting in 2003, the ILO started “International Worker’s Memorial Day” as a way to bring awareness to workers and the workplace including accidents, diseases, safety and health.  It has evolved into the “International World Day for Safety and Health at Work” and is celebrated every year on April 28.  This date also coincides with the International Commemoration Day for Dead and Injured Workers. 

Since the ILO is celebrating 100 years of existence in 2019, they are looking back at what the past 100 years and using that experience to look at the current and future workplace.  The theme to this year’s event is “A Safe and Healthy Future of Work: Building on 100 Years of Experience”.  There is a fantastic video on the ILO site found here that focuses on this year’s theme.  The longer report covers the changes to the workforce overtime and what are some of the upcoming changes.  The numbers in it are staggering when viewed from a global perspective.  It is well worth the read and is free to download.

Thinking about how Continue Reading…

OSHA HazCom 2012
OSHA Stance on Wearable Lithium Batteries

Here’s the thing. I am a TV junkie. A huge amount of my time has been dedicated to researching new shows, setting them up on my DVR, and watching said shows. One that has my attention right now is “The Rookie” starring Nathan Fillion. In the show, he is a 40-year old rookie cop in Los Angeles. It has my attention for multiple reasons aside from the obvious. The main REGULATORY one is the fact that every officer on the show wears a body camera. It got me to thinking … surely those body cameras come with rechargeable batteries. If so, what happens when in the course of the show, one of those cameras is damaged? My brain then jumped to what about workers who wear battery powered devices.

Believe it or not, OSHA recently published in their newsletter an article called, “Preventing Fire and/or Explosion Injury from Small and Wearable Lithium Battery Powered Devices”. You can find the article at https://www.osha.gov/dts/shib/shib011819.html.

In this article, they do a good job describing batteries and cells as well as how they work. There is also a lengthy section on lithium battery hazards including what can cause enough damage to create fire and explosion risks. These include such things as physical impacts, usage/storing at temperatures too high or too low and failure to follow the manufacturer’s instructions.

As to ways to prevent injuries Continue Reading…

ICC's Regulatory Helpdesk
49CFR Precedence Table

Every now and then as a trainer I get a question that appears to come out of nowhere. When those happen, classes become quite lively. These questions can happen before training starts, as it is happening or even after we are done. The human brain is a pretty amazing organ that way.

One case in particular happened after a training occurred last April. Yes, even a year later, we still provide Regulatory Support to our customer via our Customer Service line. To set the stage, this particular company took our 49CFR class. The class goes through all the steps needed to transport a hazardous substance correctly and within compliance of 49CFR. Now, we didn’t spend very much time on classifying materials in that courses simply because by this point you know what you are shipping and just need training on how to do that. Class went along without a hitch.

Fast forward now to last week and I received an email. The gist of the email is as follows:

We have a product that is both flammable and corrosive and are having trouble getting both hazard class labels to fit on the box. Can we use the Precedence Table in 173.2a to label the product as just a class 3 and omit the class 8 label?

What’s odd about this particular question is our standard transport class which this company Continue Reading…