Hazardous Transportation Use of the Regulations

profileragtag3
ANSWEREXAMPLES.docx

ANSWER EXAMPLES

The regulation that I feel is most important is Title 49 CFR, Part 172, and Subpart B-Section 172.101. This section lists the hazardous materials table which provides the hazardous materials and their proper shipping specifications. It states the names and names that they are listed as, for shipping purposes. The Hazard class, identification number, label code, any special provision for shipping, packaging information, and transportation quantity limits and what kind of shipping vessel or aircraft they are allowed on or forbidden from. Since most of the hazardous materials violations we read about in our previous forum had to do with this information I feel as though this is what makes it important. If the persons packaging as well as those on loading onto transportation type had knowledge of these proper handling and allowable materials and quantities, most fines and safety concerns could be addressed well ahead of any potentially disastrous situation from occurring. Since packaging, labeling, and preparing for shipment is the first step in transportation of hazardous materials this is the baseline for understanding the enforceable standard. Appendix B also lists marine pollutants which are important for appropriately labeling. I do believe that this is a lot of information to remember, and probably won’t be on hand at all times of preparation for shipment and this could be a main reason for negligence in shipping. Therefore, proper testing of knowledge of anyone handling specific materials should be verified by companies who employ these personnel to handle shipments. A cheat sheet would be useful to keep on hand to mitigate risk.

"Title 49 Subtitle B Chapter 1 Subchapter C

§172.400a, each person who offers for transportation or transports a hazardous material in any of the following packages or containment devices, shall label the package or containment device with labels specified for the material.

(1) A non-bulk package;

(2) A bulk packaging, other than a cargo tank, portable tank, or tank car, with a volumetric capacity of less than 18 m3 (640 cubic feet), unless placarded in accordance with subpart F of this part;

(3) A portable tank of less than 3785 L (1000 gallons) capacity, unless placarded in accordance with subpart F of this part;

(4) A DOT Specification 106 or 110 multi-unit tank car tank, unless placarded in accordance with subpart F of this part; and

(5) An overpack, freight container or unit load device, of less than 18 m3 (640 cubic feet), which contains a package for which labels are required, unless placarded or marked in accordance with §172.512 of this part.

(b) Labeling is required for a hazardous material which meets one or more hazard class definitions, in accordance with column 6 of the §172.101 table and the following table:" (Appendix A to §172.101-List of Hazardous Substances and Reportable Quantities)

With any type of hazardous material one the of the most important things is identification of what is being shipped. Without this, we are at risk of combining materials that should not be combined with each other and risking a greater chance of hazard to ourselves or a greater chance of the spill or leak becoming a fire or explosion. Secondly there with the identification it is important to know and recognize health hazards of those persons or living things surrounding the areas of the spill.

Various type of boxes, containers, and other types of packaging are sent in the thousands every single day and without identification there is a greater likeliness that some type of incident will occur.

From day to day operations of packages I constantly received at my warehouse when acting in our shipping and receiving department I could not tell you how many times operations slow down as well as a result of improper labeling, we have to know what we are dealing with when handling these materials and that goes for Material Data Safety Sheets (MSDS) as well.

Looking back at all the oil spill disasters, the casualties, economic and environmental impacts demonstrate we have a problem. The fact these oil spill incidents are ongoing, it presents a unique perspective on the importance of safety when oil is being transported. A comprehensive response plan is critical and prompts me to elaborate on the 49 CFR, Part 130, and Subpart B-Section 130.31-130-33. This regulation was enacted by the Department of Transportation (DOT) and regulated by the Pipeline and Hazardous Materials Safety Administration (PHMSA). And it applies to the transportation of oil by motor vehicles and rolling stock for prevention, containment, and response planning requirements.

Hauling flammable substances by railroad over long distances through cities, towns, and over bodies of water is a perfect recipe for disaster. In 2010, one million barrels of oil were being shipped out of the U.S. by train each month. By mid-2014, that number rose to 25 million barrels. Imports from Canada increased by 50-fold. A small town was evacuated in North Dakota after a train carrying oil derailed and exploded. In West Virginia, one thousand people were evacuated and many homes were destroyed causing the governor to declare a state of emergency. After the 2013 derailment in Canada killed 47 people, it prompted (DOT) to enact new safety regulations (Twitter, 2015).

These are only a few incidents involving oil spills. experience tells us it can take many years to clean up. The 3.19 million barrels of oil spilled in the gulf from the BP disaster should have taught us a valuable lesson (Gulf Oil Spill, 2019). Not only did the spill take years to clean, we’re still not certain on the effect it has on our health, marine life and wildlife.