Shipping by Road
TDGR US Import Cross-Docking – All We Want are the FAQs…*

Cross-Docking is Reshipping

On February 8 Transport Canada issued an addition to FAQ regarding the Transportation of Dangerous Goods Regulations (TDGR) Part 9, s. 9.4. This section deals with the re-shipping of dangerous goods (DG) received by road from the US when safety marks differ from those specified in the TDGR. In general, (more on this later**), TDGR 9.1 allows receipt of US shipments to first destination with the safety marks that were legally applied under 49 CFR at the US shipping point.

Cross-Docking

The FAQ defines “cross-docking” as “the process of transferring dangerous goods from one vehicle to another before reaching their final destination”. Changing drivers or tractor units does not trigger the term. When DG are cross-docked, Transport Canada considers this to be “re-shipping” and the provisions of TDGR 9.4 apply (note: although the FAQ refers to “reshipping” in quotes, the term is not specifically defined in the TDGR other than as described by s. 9.4).

Reshipping

Basically, the requirements in s. 9.4 are to remove placards which do not meet TDGR requirements and replace them with TDGR-compliant versions. Examples of these could be US “DANGEROUS” placards; or those with the midline adjusted (e.g. Class 7, 8, 9); or worded and “combustible” placards.
In addition, if means of containment (soon to become “packaging” we hope!) have labels or other safety marks differing from TDGR requirements, then the shipping paper must be annotated accordingly as indicated in s. 9.4 (2).

Part 10 is not referenced in the FAQ, but presumably similar logic will apply to cross-docking rail car shipments (TDG s. 10.4) – or to transfers between rail/road vehicles.

Just the FAQs

Although the author hasn’t seen anything in official consultation documents, statements in casual conversations on two occasions indicate that the current practise of including interpretative guidance as italicised text within the body of the regulations will likely be discontinued. Apparently, this very useful (in my humble opinion) practise is at odds with regulatory convention that expects only the mandatory legal requirements to appear in the regulation. FAQ are the preferred vehicle for the type of information we currently see italicised within the TDGR.

The FAQ referred to in this Blog is available at:
http://www.tc.gc.ca/eng/tdg/awareness-materials-and-faq-1159.html#a99_0

* with apologies to Sgt. Joe Friday/Jack Webb’s often misquoted statement:
http://www.snopes.com/radiotv/tv/dragnet.asp

** Reciprocity has its limits
Although we often hear of “reciprocity” for shipments inbound from the US, we must remember that it has limits. As referenced in the above-mentioned FAQ, the “inhalation hazard” version of Class 2.3 and 6.1 labels or placards are not acceptable even to first destination. The “regular” versions, applied with qualifying marks as required by TDGR SP 23 also need to be present. Similarly things done by US special permit- although potentially to be accepted to first destination under the CG I International Harmonization proposal- will not necessarily be approved for reshipping. Perhaps once the CG II is finalised we’ll have another Blog on this aspect…

Lithium
Lithium Battery Labels as of Feb 1, 2017

Both 49 CFR and TDG are expecting to harmonize lithium battery labels into the regulations; however, both regulations are pending. HM-215N (49 CFR) was recalled, and will not be reissued for at least 60 days.

Transport Canada has not provided an ETA on the harmonization.

Find out the correct labels to use below:

 

PHMSA Update
U.S. Final Rule HM-215N on International Harmonization Delayed

Regulatory Freeze Delays Final Rule HM-215N

The Pipelines and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) has withdrawn a Final Rule that was intended to be published in the Federal Register on January 26.

The Final Rule, HM-215N, would have updated the U.S. “Hazardous Materials Regulations” to reflect international standards, improving U.S. abilities to import and export hazardous materials as well as reflecting improved safety standards. However, due to the new administration’s Regulatory Freeze executive memorandum, regulatory changes that had been sent to the Federal Register but not already approved must be immediately withdrawn for “review and approval” before being reissued. While the text of the Final Rule had already been published on PHMSA’s website on January 18th, it had not yet appeared in the Federal Register. The Regulatory Freeze took effect as of January 20.

Since this update is relatively non-controversial for stakeholders in the transportation industry, and will improve the ability of the United States to compete internationally, it is hoped that the review and approval time will be short. However, until the Final Rule can be published, the hazmat community must wait for the anticipated harmonization of U.S. regulations with international standards. These include proposed changes such as:

  • the adoption of the latest versions of the UN Recommendations on the Transport of Dangerous Goods, the ICAO Technical Instruction’s on the Safe Transport of Dangerous Goods, the International Maritime Dangerous Goods Code and Canadian “Transportation of Dangerous Goods Regulations”;
  • the extension of Transport Canada equivalency certificates to the U.S. portions of transborder shipments;
  • a set of new shipping descriptions for products such as polymerizable substances;
  • a new special provision for substances that require stabilization during transport, enabling the use of temperature controls when chemical stabilization becomes ineffective;
  • change in the classification and hazard communication for uranium hexafluoride; and
  • the harmonization of lithium battery transport provisions, including the new Class 9 label and Lithium Battery Handling Mark. Fortunately, these new marks have a transition period in the ICAO Technical Instructions until 2019.

Right now PHMSA is unable to confirm when they can resubmit the Final Rule. It will, it’s hoped, be soon, so U.S. companies can establish a unified set of procedures for national and international shipments.

If you have questions about these proposed changes and how they can affect your operations, please contact ICC Compliance Center at 1.888.442.9628 (USA) or 1.888.977.44834 (Canada).

Lithium
Lithium Battery Worlds Collide

One of my favorite episodes of the show Seinfeld is the one where worlds collide. In the episode Elaine asks George’s girlfriend Susan to a show. On the surface this seems harmless. According to Kramer, this is a bad thing because when George’s “sanctuary world” and his “girlfriend world” collide there will be an explosion.

I had a case of my worlds colliding over the holidays. Let’s see what the results were. The attached pictures are from a leaf blower my husband received as a Christmas gift. It is a nice gift that will help us with yard work in the future. The description on the box says it comes with a charger for the included 40 volt, 2.0 ampere-hour rechargeable lithium-ion battery. On the back was the Lithium battery handling information. I didn’t pay much attention to it due to being in a cookie coma from the holidays.

Lithium battery label on box

Upon arrival home and while unloading the car, my husband noticed the information on the box and pointed it out to me. He then asks, “Should this be on here?” Needless to say, once we were fully unpacked I grabbed my regulations just to see.

Using the information on the box let’s review some points for shipping Lithium-ion batteries. Bear in mind this was purchased at a store where it was on the shelf. I have no way of knowing if it was shipped in this box.

  • Step 1: Is this lithium-ion battery is “contained in equipment” or “packed with equipment”?
    • Answer: The battery was not inserted into the blower but in a separate box beside it. This means it would have been “packed with equipment”.
  • Step 2: What is the watt-hour rating?
    • Answer: This was easy enough since the box said the battery had a 2 ampere-hour capacity and a voltage of 40 volts.  Using the following formula:

Watt-hours = Ah (ampere-hours) x V (voltage)
Watt-hours = 2 Ah.  X 40 volts
Watt=hours = 80 watt-hours

  • Step 3: What would be the proper identification number, shipping name, hazard class, and packing group (ISHP) if this had been shipped?
    • Answer: Since the manufacturer is within the US, I looked at the US ground regulations, 49 CFR. It is a Lithium-ion battery that was packed with equipment. Using the Hazardous Materials Table (HMT) that tells me the proper ISHP would be UN3481 // Lithium-ion batteries packed with equipment // Class 9 // no packing group.
  • Step 4: What sort of packaging requirements are there?
    • Answer: Again the HMT gave me that information in column 8. Luckily for UN3481 the packaging information is all found in Section 173.185. The only Special Provisions listed in the table are for air shipments. Much of this section didn’t apply to my query because I wasn’t shipping this. However, this section is also where all of the marking, labelling, exceptions/exemptions and hazard communication information is found.
  • Step 5: Where does the leaf blower fit and why was that particular safety information used?
    • Answer: This goes back to the information from Step 2. The watt-hour rating of 80 put me into Section 173.185(c) for exceptions. In that section is where the hazard communication information is found. In that was the proof I needed to say, “It is ok for this information to be on this box.” The box only has 1 lithium battery and the box is using the “handling marking” shown in paragraph (c)(3)(ii). The regulation says the following:

(3) Hazard communication. Except for a package containing button cell batteries installed in equipment (including circuit boards), or no more than four lithium cells or two lithium batteries installed in the equipment:

(i) For transportation by highway, rail and vessel, the outer package must be marked with the information in the following paragraphs (c)(3)(i)(A) to (D), or the handling marking in paragraph (c)(3)(ii) of this section:

(A) An indication that the package contains “Lithium metal” and/or “Lithium ion” cells or batteries, as appropriate, or alternatively, the word “batteries” may be used for packages containing cells;

(B) An indication that the package is to be handled with care and that a flammable hazard exists if the package is damaged;

(C) An indication that special procedures must be followed in the event the package is damaged, to include inspection and repacking if necessary;

(D) A telephone number for additional information.

(ii) For transportation by air, the outer package must be marked with the following handling marking, which is durable, legible, and displayed on a background of contrasting color:

Old lithium battery label

So there it is the results of my worlds colliding. There were no explosions, tidal waves, or earthquakes. There were no deaths from licking cheap envelopes, which is a reference to Susan’s fate. It was just an exercise of taking ICC Compliance Center’s “7 Steps to Compliance” idea and making them work for me. Of course, my head may explode when HM215-N is finalized and the information in this section of 49 CFR changes.

As always, ICC Compliance Center is here for all of your hazard communication and lithium battery needs. Call us today for lithium battery training, new class 9 labels or new handling marks, and new lithium battery shipping materials. We have it all.

Oil drum spill
When Are You Required to Report a Hazardous Spill?

Reportable Quantities & Environmental Release

Unfortunately accidents seem to happen at the most inconvenient times. Whether you fall, crash, slip, or spill, it is often the aftermath that defines who we are. After all, there is no use crying over spilled milk. However if you spill hazardous goods, the aftermath can be a bit more complicated.

It is important when hazardous materials are spilled that it is addressed in a way that prevents any further damage to the environment or health of the community. But when is it necessary to report a hazardous spill to the proper authority? The Federal Government has established Reportable Quantities (RQ) for instances when hazardous substances are released in the environment. If a hazardous substances released in the environment in an amount that is equal or exceeds its RQ, it is required that it is reported to the federal authorities. A list of Reportable Quantities san be found in the latest 49 CFR.

Chemical Spill Guidelines

Specific guidelines are in place if hazardous materials are spilled during transportation. Whether you are loading, driving, unloading, or storing hazardous materials, you are required to adhere to the same guidelines. There are times when hazardous goods are transferred from one carrier to another. According to the D.O.T, whenever material is being transferred from one carrier to another, the upstream carrier remains responsible until the material is fully in the possession of the downstream carrier, no matter who is unloading the material.

Once the material has been delivered to the final intended consignee and the goods are no longer in transit, the final consignee becomes responsible for filing the report for spills that occur during the unloading process. If during the transportation of hazardous goods a spill takes place that meets or exceeds the reportable quantity (RQ), immediately contact the National Response Center (NRC).

You will need to provide the following information per the Environmental Protection Agency (EPA):

  • Your name, location, organization, and telephone number
  • Name and address of the party responsible for the incident; or name of the carrier or vessel, the railcar/truck number, or other identifying information
  • Date and time of the incident
  • Location of the incident
  • Source and cause of the release or spill
  • Types of material(s) released or spilled
  • Quantity of materials released or spilled
  • Medium (e.g. land, water) affected by release or spill
  • Danger or threat posed by the release or spill
  • Number and types of injuries or fatalities (if any)
  • Weather conditions at the incident location
  • Whether an evacuation has occurred
  • Other agencies notified or about to be notified
  • Any other information that may help emergency personnel respond to the incident

If you have questions about chemical spills or reportable quantities, contact us here at ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-44834 (Canada).

Danger Placard
Does My Personal Vehicle Need Placards? – Answering Regulatory Helpline Questions

One of the great services offered by ICC Compliance Center to our customers is our Regulatory Helpline. Current customers can call in and have basic questions answered for free. Our Specialists are trained in all of the transport regulations for the US and Canada. We also answer questions surrounding HazCom2012 and WHMIS 2015. A great benefit of our service is getting the customer a “right” answer. Occasionally it may require some information gathering, but we still give you an answer. Being relatively new to our Helpline, I tend to take a bit longer to get an answer.

I mention this because of an interesting question that came in last week. A customer called and posed the following question:

If I want to move a container of oxygen in my personal vehicle, does [my vehicle] have to be placarded?

On the surface this seems easy enough to answer, but in reality that is not the case. As I discovered a good bit more information was needed to formulate a “right” answer.

Answer Step 1:

What is meant by “a container of oxygen”? This information is needed for several reasons. We have to determine if what the caller has is truly a hazardous material/dangerous good. For example, is it pure oxygen or is it a blend of oxygen and nitrogen similar to a SCUBA tank? One is much more dangerous in the event of a fire than the other. In this case, the container is of pure oxygen.

Answer Step 2:

What is the description of the container? The assumption is the container is a cylinder. If so, what size? There could be exemptions in place depending on how large or small the container is. The caller said it is a steel cylinder that weighs 15 kilograms and it has TC on the outside.

Answer Step 3:

Where is this person located? We need to have this information so that the proper regulations can be checked. If the caller was in the United States, but I used Canada’s transport regulation to answer that may not have worked. In this case the caller is from Canada. This is helpful because there was a mention of using a “personal vehicle”. In the U.S. this could have led to a discussion of Materials of Trade exemptions. Since Canada does not have that type of exemption it would make no sense to go over them with the caller.

Answer Step 4:

Now we almost have the whole picture. We have a steel cylinder full of pure oxygen that weighs 15 kilograms. It is being transported in a personal vehicle in Canada. With all of that information, the caller MAY meet the 150 kilogram Gross Mass Exemption in the Canadian Transportation of Dangerous Goods regulations per Section 1.15. This prompted one more question. Was this cylinder purchased by the caller at a location open to the general public? The answer was “yes.”

Final Answer:

The final answer is “no”, the caller is not required to placard his personal vehicle to transport a cylinder of oxygen. Per the 150 kilogram Gross Mass Exemption, he does not need a shipper’s declaration, training or … any sort of “dangerous goods safety marks”. This section also includes placards. He may voluntarily display it per Section 4.1.1 of the regulation but there are multiple provisions.

So while this looks like a complicated process, it is in fact not. As long as we have all of the information, answering your questions can be quite easy. Give us a call today to see just how easy it is – ICC Regulatory Helpline 855.734.5469. We are here to help. As always, ICC Compliance Center is here to help you with all of your regulatory needs.

Single Packaging
Can You Spot the Errors on this UN Package?

Test your dangerous goods knowledge and see if you can find all five errors/missing information on this UN performance package.

Don’t be discouraged if you find this difficult — we can help! We have a dedicated regulatory staff available to our customers. Call ICC today!

Find out how your answers compare to the answer key next week!

 
Be the first to receive a link to the answers as soon as they are available by signing up for ICC’s newsletter below.

  • This field is for validation purposes and should be left unchanged.

Lithium
Samsung Galaxy Note 7 BANNED

Don’t Bring Your Note 7 with You on a Plane

More bad news for Samsung Galaxy Note 7 owners. Not only do you have to worry about them catching on fire, but now, you can’t even bring them with you when you travel by air.

The U.S. Department of Transportation (DOT), with the Federal Aviation Administration (FAA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA), announced it is issuing an emergency order to ban all Samsung Galaxy Note7 smartphone devices from air transportation in the United States.

This emergency order bans all Samsung Galaxy Note 7 devices from “being on their person, in carry-on baggage or in checked baggage on flights to, from or within the USA.

The emergency order can be found here:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-25322.pdf

In September, Samsung announced the recall of over 1.9 million Galaxy Note7 devices. The Consumer Product Safety  Commission says that Samsung received 96 reports of lithium batteries overheating, including 13 burns and 47 reports of property damage. The CPSC recall notice can be found here: https://www.cpsc.gov/Recalls/2017/Samsung-Expands-Recall-of-Galaxy-Note7-Smartphones-Based-on-Additional-Incidents-with-Replacement-Phones


If you need to ship lithium ion or metal batteries by themselves, packed in equipment or  contained in equipment contact ICC for training and supplies to ensure that they are transported safely.

PHMSA Update
U.S. Publishes Proposed Rule HM-215N on International Harmonization

It’s autumn — we’re surrounded by orange leaves and orange pumpkins, and children are thinking about Halloween. Regulators, on the other hand, are thinking about something else orange. A new edition of the Orange Book (the UN Recommendations on the Transport of Dangerous Goods) is out.

The Pipeline and Hazardous Materials Safety Administration (PHMSA), under the U.S. Department of Transportation (DOT), has made a commitment that U.S. transportation will stay well-harmonized with international regulations. So, now that the 19th Edition of the Orange Book is upon us, we must prepare for changes to the Hazardous Materials Regulations (HMR) of Title 49 of the Code of Federal Regulations (49 CFR).

DOT’s rules on international harmonization can be identified by their HM-215 docket numbers. On September 7, 2016, PHMSA issued a notice of proposed rulemaking, HM-215N. This rulemaking is intended to harmonize the HMR with the latest regulations on hazardous materials, including:

  • 2017-2018 Edition of the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI),
  • Amendment 38-16 to the International Maritime Dangerous Goods Code (IMDG),
  • Canada’s “Transportation of Dangerous Goods Regulations” (TDG) up to an amendment incorporated on May 20, 2015,
  • 6th Revised Edition of the UN Manual of Test and Criteria, and
  • 6th Revised Edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

What changes can we expect?

As always, PHMSA does not simply cut and paste from the latest Orange Book. Instead, it reviews how international changes will interact with current U.S. regulations, and attempts to balance harmonization with international requirements against specific U.S. safety concerns. Some of the major changes proposed will include:

Provisions for polymerizing substances – PHMSA will add to the Hazardous Materials Table (HMR), section 172.101, four entries for a new type of hazard called polymerizing substances in Division 4.1. They will also establish classification criteria defining what are polymerizing substances, specific packaging authorizations and safety requirements for these unstable materials. These requirements will include stabilization methods and operational controls.

Polymeric beads – PHMSA proposes to add a procedure for declassifying polymeric beads if they don’t give off dangerous amounts of flammable gas, based on the UN Manual of Tests and Criteria.

Modification of the marine pollutant list – The list of marine pollutants in Appendix B to the HMT is a remnant of an earlier system under which aquatic hazards were determined by environmental authorities such as MARPOL. The Orange Book has for some time used a system of classification criteria instead of the list. In other words, a marine pollutant in the Orange Book and the IMDG Code is any chemical that tests positive as an environmental hazard. PHMSA will maintain the old list as a starting point for classification, although it will allow the use of the IMDG criteria for chemicals not listed, and this amendment will update the list to reflect current knowledge of marine hazards.

Hazard communication for lithium batteries – Lithium batteries have remained a thorn in the side of hazmat shippers as well as regulators, as the international community still scrambles to establish a fool-proof method of transporting these items. Under the 19th Edition of the Orange Book and the ICAO TI for 2017-2018, a new Class 9 label specific for batteries has been introduced, as well as a new simplified Lithium Battery Handling mark for low-powered batteries. PHMSA plans to incorporate these to match. Also, the Lithium Battery Handling mark will made mandatory.

Engine, internal combustion/Machinery, internal combustion – Under this proposal, the entries existing for “Engine, internal combustion” would be assigned their own UN numbers and hazard class based on the type of fuel – for example, a gasoline engine would be put in Class 3, UN3528, while a propane-powered engine would be put in Division 2.1, UN3529. The entries for UN3166 will be eliminated.

Harmonization with Canadian regulations – PHMSA proposes to eliminate several costly and annoying areas of non-harmonization with Canadian TDG regulations that have been addressed by the U.S.-Canada Regulatory Cooperation Council (RCC). PHMSA proposes to recognize cylinders approved under Transport Canada. Also, Canadian equivalency certificates (the Canadian term for permits for equivalent level of safety) may be used for shipments coming into the U.S., until the first destination. These changes will be made along with Transport Canada, who will amend TDG to give similar reciprocity for cylinders and permits regarding shipments coming into Canada.

PHMSA has already moved forward on some issues that the UN is only now addressing. For example, the proposal notes that while the Orange Book has created an exemption for ping-pong balls under the entry for UN 2000, Celluloid, PHMSA has already declared in a letter of interpretation that the U.S. does not consider such articles to “pose an unreasonable risk to health, safety or property during transportation.” This comes as a significant relief to those who enjoy a rousing game of table tennis.

You can view the Notice of Proposed Rulemaking at PHMSA’s rulemaking archive. Comments on the proposed changes may be received by November 7, 2016, by mail, fax, hand-delivery or the Federal Rulemaking Portal at http://www.regulations.gov.


If you have any questions about these proposed changes and how they can affect your operations, please contact us here at ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).

Shipping by Road
A Closer Look at Truck Safety

In the United States, there are close to ten million people in trucking-related jobs. Over 2 million tractor-trailers hit the roadways each year, logging nearly 450 billion annual miles. These trucks account for 70 percent of freight transported in the US, with several trillion dollars of cargo delivered in North America each year.

For a delivery system that’s so critical to our nation, the safety risks associated with the trucking industry are huge.

OSHA reports that an average of 475,000 large trucks are involved in accidents each year, causing over 5,000 deaths and 142,000 injuries. A quarter of those belong to the truck drivers (although the truck operators are only responsible for 30 percent or less of the accidents.) In addition to driving-related accidents, regulators issued numerous citations for improper guards on equipment, lack of personal protective equipment, improper grounding of equipment and lack of proper fall protection.

The sad reality is that employees in the trucking industry have more work-related fatalities than any other occupation, with a full third of these deaths taking place off of the roadway. The industry also accounts for more non-fatal injuries requiring medical attention than any other form of employment, with the most prevalent injuries being sprains and strains. One of the most prevalent types of serious occurrences is back-overs, with many hundreds of employees being struck each year.

So what can be done?

Establish Proper Protocols

OSHA estimates that 70 percent of businesses do not have an established safety and health plan. Simply posting bulletins and laying manuals on tables do not protect workers. Proper protocols need to be established that address equipment, gear, weather, vehicles, communication, signage and more.

For example, when unloading goods, people on foot should stay out of the loading zone. Personnel should not be downhill of moving cargo, and all employees should be free of trailers and wheels before a truck is moved. These seemingly common sense items should never be left to common sense alone; they need to be stated.

All protocols should be unique to your environment. Nobody else’s worksite looks like yours or presents the same specific challenges. From visibility to geological, geographic and meteorological features, address your strengths and weaknesses. And prepare a plan that will send every employee home safely each and every day.

Training

Once the protocols are established, train your employees on them. If you are going to reduce accidents and prepare a safe work environment, training cannot be taken lightly. OSHA and a number of other agencies will provide training for you. All you have to do is ask.

Training needs to be conducted on everything from equipment to personal protective gear. When dealing with trucks, you need to address the visual limits of the drivers, blind spots, communication signals and acknowledgments, spotters, loading, unloading, etc.

For example, a back-over incident is when a vehicle that’s backing up strikes a worker while they’re either standing, walking or kneeling behind the vehicle. Common reasons for back-overs include:

  • Spotters for one vehicle who don’t see a second vehicle backing up without a spotter
  • Workers riding on trucks who fall off and get run over
  • Trucks backing without a spotter, so they don’t see a worker in their blind spot
  • Backup warning signals that are not operational

Most of these incidents could be prevented with proper protocols and training. Requiring trained spotters to be present on all backups reduces incidents significantly. Further, training employees about the location of a truck’s blind spots helps them avoid ending up in one.

Loading and Unloading Equipment

The modern trucking industry has come a long way from the days of the handcart. From gangways and loading ramps to platforms and bridges, your equipment needs to meet your operational needs. Too often, a one-size-fits-all approach is taken with equipment, and this leads to safety hazards.

When ordering your equipment, make sure your vendor knows the sizes of your trucks, the dimensions of your loading and unloading area, the configuration of the operations, and so on. They can work with you to design a custom solution that will maximize your employee safety.

In addition to equipment that fits, don’t forget to think about visibility. On the work site, orange and yellow have special meanings. Make sure your employees and equipment are highly visible and easy to see.

Fall Protection

Whether you are opening a hatch or working on a tarp, when you leave the ground, you are subject to a fall. OSHA standards require fall protection any time you’re at least 4 feet, 6 feet or 8 feet off of the ground, depending on your operation. Granted, the best fall system is one that does not have you on top of the truck, but when that’s unavoidable, fall protection needs to be in place. Consider beam and trolley systems, access platforms, lifelines and more. Safety cages are also always good options, and automatic tarping systems could be considered fall protection since it keeps employees off of the truck.

When working in inclement weather, canopies protect your employees from the elements and significantly reduce the chances of a fall. Spill containment equipment keeps slick or hazardous materials from ending up under your employee’s feet. Gaps and drop-offs should be secured near all lift gates and loading docks.

Many times employees will attempt to inspect or fix a problem when the truck is outside of the standard work area. These instances relate back to developing good protocols and training, especially in the case of roadside repairs or emergency service work.

In 2015, the top three most cited violations by OSHA were, once again, fall protection, hazard communication and scaffolding. Don’t let any of your employees become one of these statistics.

Maintenance

According to the United States Department of Labor: “Truck or rail tank car loading … is one of the most hazardous operations likely to be undertaken at any manufacturing or storage facility. Workers engaged in the loading or unloading of suspension-type highway trailers may be at an increased risk of injury due to the inability of damaged trailers to support the weight of the powered industrial truck used to load or unload the trailer.”

Prior to engaging in loading and unloading activities, take the time to inspect the trailers and ensure they have been properly maintained. The same goes for power trucks. The right time to find out there’s a mechanical issue is not when you are in the middle of moving a massive load.

Safety is job one. With a few precautions, some quality training and proper equipment, your employees will love coming to work because they know they will be going home safely at the end of the day.