Shipping by Road
FMCSA Electronic Logging Device (ELD) Requirements

Red semi truck on highway

FMCSA Goes on Tour

The Eagles, a popular band for several decades, broke up back in the 1980s. A famous quote from one of the band’s members is that they would play as a band again “when Hell freezes over.” Interestingly enough in 1994 the band got back together and went on tour. Of course, the name of the tour was “Hell Freezes Over”. I mention this because the Federal Motor Carrier Safety Administration (FMCSA) is also about to go on tour.

The tour known as the “ELD Implementation National Tour” is a way for FMCSA staff members and experts to present, discuss, and help with the new Electronic Logging Devices or ELDs. An ELD is a device designed to sync with an engine to record driving times. This recording will make for easier and better tracking of a driver’s hours of service (HOS). These ELDs will replace the paper logbooks that certain drivers are required to maintain. To access the Federal Register for the full Final Rule, click here.

The ELD Final Rule was published in December of 2016 and has a 3-phase implementation. Each phase has its own time frame, objective(s), and device requirements.

ELD Rule implementation phases:

  • Phase 1: Awareness and Transition
    • Dates: February 16, 2016 to December 18, 2017
    • Objective: Learning the requirements of the new rule and planning for compliance
    • Devices allowed: paper logs, logging software, Continue Reading…
PHMSA
49 CFR – There’s an App for that?

oCFR Regulation Smartphone app

We’ve Come a Long Way

Technology is everywhere we look now. Think about some of the advertisements on television you see for what is available today in the realm of technology. There is the refrigerator that sends you pictures of its insides and keeps your grocery list. A device that can regulate your thermostat, turn on your lights, and send you reminders about events. Cell phones can now stream videos, search the internet, pay your bills, and still make calls. All of these are just in the past year.

Think back about ten years ago. It doesn’t seem that long ago, now does it? It is around this time that the iPhone craze was starting. In 2008 the iPhone 3G was released. As the second generation of iPhone, it came preloaded with such features as a GPS, special email capabilities, and the App Store. App stands for Application. It is from the App Store that people could download various tools, games, and software. Around this time, Apple began to advertise with the slogan, “There’s an App for that”.  You can watch one of the original commercials here.

So, why all the history? Because there is a new app available from the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA). This app called “oCFR” (Online Code of Federal Regulations), which allows access to a simplified, mobile version of Continue Reading…

Single Packaging
Latin, Vince Lombardi, & Packaging Selection

Man preparing shipment

Practice Makes Perfect

Most of us have heard the phrase, “Practice makes perfect”. I did when learning my multiplication tables. Others hear it in reference to playing sports. What is interesting is the phrase originates from the 1500’s. In Latin, it is ‘Uses promptos facit‘ which translates to ‘use makes mastery’. Vince Lombardi, American football player and coach, said it differently. For him, “Practice does not make perfect. Only perfect practice makes perfect” was the correct way to say it. The intent is the same. The only way to get batter at something is to practice it.

So how does that relate to making the correct packaging selection for shipments of hazardous materials? A shipper should practice using the regulation and the UN Specification Markings together before making any decisions on packaging. When working with clients in transportation training sessions I always remind participants that packaging is two-fold. You have to use what the regulations say and what the marking on your packaging allows. Let’s do a practice problem to show what I mean.

Steel Drum MT0M502

Practice Problems:

Problem #1:

Can a shipper put 16 Liters of UN1114 Benzene into a steel drum with a non-removable head for a US Ground shipment using 49 CFR? Benzene has a specific gravity of 0.876 g/ml. The drum has the code 1A1 / Y1.8 / 250 / 16 on it.

Solving Process/Logic: First, the shipper has to understand what the specification marking Continue Reading…

World Hepatitis Day Logo
World Hepatitis Day

Eliminate Hepatitis Banner

Are your Signs Accurate?

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), an estimated 1.34 million people died globally from this disease in 2015. In comparison, numbers that high match those caused by tuberculosis, malaria, and HIV/AIDS. According to the World Hepatitis Day website, “Currently, 90% of people living with hepatitis B and 80% living with hepatitis C are not aware of their status.” We all need to be educated. This is not a disease found in just one country or in one particular ethnicity. Here is the chance to educate ourselves. Check out the website dedicated to the even this year at http://www.worldhepatitisday.org/en/about-us

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. Note that Type E is very dangerous for pregnant women.

Listed below are some key facts about each type of Hepatitis taken from the WHO website. For more information visit http://www.who.int/hepatitis/en/

Key Facts of Hepatitis Types

  • Type A – transmitted through ingestion of contaminated food and water or through direct contact Continue Reading…
Safety
National Forklift Safety Day – June 13

Forklift

Forklift Safety

There’s an old joke out there about what happens when you play a country song backwards. According to the joke you get your girl, dog, and truck back. Rascal Flatts even did a song about it. It is a pretty good tune. Take a listen here.

So, how does a song about getting a truck back relate to forklifts and forklift safety? Well, by definition a forklift is a powered industrial truck. Since the joke and song talks about trucks you can see the connection. Forklifts are used to lift, move, and place various materials weighing anywhere from a few thousand pounds up to 90 tons. These powered industrial trucks must comply with OSHA standard 29CFR 1910.178. You can access a copy of the standard at this link.

National Forklift Safety Day

In 2016, accidents and incidents involving powered industrial trucks were listed in the top ten OSHA violations. To stress the safe use of the vehicles, need for operator training, education of non-users the Industrial Truck Association (ITA) has set aside Tuesday, June 13 as National Forklift Safety Day. This is the fourth year for such an event. Having a written standard, good safety policies and regulations surrounding the safe use of these machines isn’t enough. It requires every day awareness and commitment from drivers, managers, and other personnel in the areas with these trucks to stay safe.

If you are in the Washington, DC area check Continue Reading…

PHMSA Penalties Increase

Chemical Drums Disposal

Enforcement of Hazardous Materials Program Procedures

Many have heard the phrase, “money makes the world go around”. The phrase was made popular by the stage and film show “Cabaret”. In fact, that phrase is the name of one of the songs in the show. For a snippet of the song featuring Liza Minnelli, listen here.

What does this phrase have to do with the US transport regulations you may ask? It comes down to a particular section of 49 CFR. In Subpart D of Part 107 Hazardous Materials Program Procedures is a section entitled “Enforcement”. Within that subpart are the possible penalties a company could be assessed for violations to the requirements of 49 CFR. In particular, take a look at Sections §107.329 regarding the maximum civil penalties which could be assessed to a company.

Maximum Penalties Increase

Here’s where things get tricky. Anyone working with these regulations is familiar with the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.  Quite a mouthful, I know. This act basically requires federal agencies to adjust civil penalties each year to account for inflation. The Pipeline and Hazardous Materials Safety Administration (PHMSA) is a federal agency. As such, on April 19, 2017, those penalties increased. Per the announcement:

The maximum civil penalty for a knowing violation is now $78,376, except that the maximum civil penalty is $182,877 for a violation that results in death, serious Continue Reading…

Safety
OSHA Safe + Sound Week

Safe + Sound Week 2017

Safe + Sound Week is June 12 – 18

Back in the 14th century, sailing ships were a primary means of trading goods. To protect goods on these vessels they were insured against loss or damage.  The best news for the insurance companies was to receive word that the ship had returned “safe and sound”. The word “safe” was an indication of all crew members were accounted for without injury. The word “sound” told the company the ship had not suffered any serious damage. Since then we continue to use the phrase in our daily life.

The week of June 12-18 has been designated as the inaugural Nationwide Safe + Sound Week. The week is presented by Occupational Safety and Health Administration (OSHA), National Safety Council, American Industrial Hygiene Association (AIHA), American Society of Safety Engineers, the National Institute for Occupational Safety and Health just to name a few. The goal is to “raise awareness and understanding of the value of safety and health programs”. All businesses and companies are encouraged to participate.

The focus of the week is on three core elements. It covers management leadership, worker participation and find and fix hazards. Here is a brief overview of each taken from the OSHA website.

Core Elements:

  • Management leadership is a demonstrated commitment at the highest levels of an organization to safety and health. It means that business owners, executives, managers, and supervisors make Continue Reading…
Airplane Icon
FAA Short Audit Answers

Cargo loading on aircraft

Common Errors When Shipping by Air

At a recent training, the group hosting invited someone from the Federal Aviation Administration (FAA) to come and speak. Throughout the brief discussion, the speaker mentioned things she sees most often while doing site audits. Listed below are a few of the main items. See if you can guess what the officer sees during audits that is not accurate.

  1. Retention of Shipping Papers: In IATA, the retention of documentation is found in Section 8.0.2.2. According to this section the declaration of dangerous goods “must” be maintained for a minimum of 3 months. There are no state or operator variations attached to this section which may be why people get caught. In United States’ variation USG-01 it clearly tells shippers the document must be maintained by not less than 2 years.
    • Error Found: Only 3 months’ worth of documentation can be produced during an audit.
  2. Use of Technical Names: Entries in the blue pages listed with a star (*) symbol tells the shipper a technical name is needed.  Section 4.1.2.1(d) outlines how to determine the name, the number or names, and the type of names allowed. “The technical name must be a recognized chemical or biological name or other name currently used in scientific and technical handbooks, texts and journals. Trade names must not be used.
OSHA Safety
Compliance Language

Current Dangerous Goods Regulations

Terminology in Regulatory Manuals

Language, as defined by the Merriam-Webster dictionary, is the formal system of words or signs that people use to express thoughts and feelings. Learning a new language is often a complex undertaking. It is also a time that lends itself to funny stories. While living in Austria for a few years taking German lessons was part of our visa process. We were encouraged to practice often. On one of my first attempts was to buy a certain pretzel. Somehow my request came out as asking for the “slow one” rather than the “long one”. My husband told a co-worker he “believed” he was a pencil. While neither request caused harm, it was confusing to the German speakers who heard us. I mention this because the language of transport regulations can be confusing as well until you have a good handle on the language used in them.

Let’s take a look at two simple words. We will compare their “everyday” usage with how they are used for transporting hazardous materials or dangerous goods. The two words will be “should” and “may”.

Word #1: Should

In normal usage, this word indicates certain obligations or expectations. Take for example the statement, “John should be ready by now.” By using the word “should” in the sentence, the expectation is that John is ready or prepared for whatever situation he finds himself. In Continue Reading…

Placarding
Correct Usage of a Dangerous Placard?

Placards on a truck

An Interesting Combination

A recent training class took me to Iowa. Since it is so close to me, I decided to drive there rather than play the airport game. During the drive an old favorite song of mine came on the radio. The song is by Don Henley and called “The Boys of Summer”. In that song is the following lyric: “Out on the road today / I saw a Deadhead sticker on a Cadillac / A little voice inside my head said / “Don’t look back, you can never look back.” Take a listen:

What’s funny is shortly after hearing that song I passed an 18-wheeler truck. On the back and side of the truck was a “Dangerous” placard and a “Class 5.2” placard. A picture of each is shown here. In a very simplistic sense, placards are big hazard labels, roughly 9.84 inches on each side. They are placed on vehicles to warn people about the hazardous materials on or in that vehicle.

Hazard Class 5.2 Placard
Hazard Class 5.2 Placard
Dangerous Placard
Dangerous Placard

The 49 CFR has some unique rules for placarding, but what was on that truck struck me as interesting. I’ve never seen those things together before.  It is usually 1 or the other. Being a safety nerd I checked my regulations when settled in my hotel room. Placarding information is found in Section 172.500 of Continue Reading…