The primary reason hazardous material shipments are rejected is because the shipping company has not trained its employees in haz-mat requirements. There are a lot of reasons for a shipment to be rejected such as shipping papers that are not completed properly and inadequate placarding, labeling and packaging.
Frequently, problems stem from companies familiar with the regulations that govern one mode of transportation (air, ground or water) that then attempt to apply those rules and regulations to another. Mastering the variances in multimodal requirements for shipping hazardous materials from one mode to another can take time and, to the less experienced shipper, can be rather troublesome. But a trained hazardous materials shipper is an investment well worth the time and effort.
Utilizing All Modes
The labyrinth of multimodal regulations and the time-consuming task of working through them cause some shippers to use training shortcuts, often with costly consequences. Some companies make a conscious decision to train their staff only in the requirements of shipping hazardous materials by air. The rationale for this decision is that air is the most restrictive mode of transportation, and if you set up your company with knowledge of air requirements, you will always be safe and in compliance with the regulations.
This is problematic for several reasons. Air regulations are the strictest standards, but its not a safe assumption that these guidelines will work for any mode of transportation. Sometimes, companies restrict themselves to use only air transport for hazardous materials, again because they know the regulations for that mode. The financial consequences of sole reliance on air transport can be rather costly when it comes to hazardous materials. Air carriers may simply refuse to ship a particular hazardous material or, more commonly, will add an expensive premium for such shipments.
Similar negative consequences can result from training in and using only truck or ocean transport. A problem may occur if a customer requires faster delivery that can only be provided by air transport. Companies that ship only by surface transportation simply to avoid the stricter air standards can and do miss out on contracts requiring faster delivery.
Frustrated Shipments
Another problem caused by inadequate training is frustrated shipments. Of the estimated 800,000 to 1,000,000 shipments of hazardous materials that occur in the
Costs of frustrated shipments can impact a company in several ways. Productivity is lost when more time and labor is required to correct the problems that led to a shipping agent rejecting the freight. Companies are devoting more dollars to what should be a relatively quick task when the shipment is not prepared correctly the first time. Commonly, frustrated shipments are those in which a company is not familiar with the requirements of a particular mode of transport that is being used due to an unusual or emergency situation. Typically, not getting the goods to their destinations in the time required by the customer can mean losing a customer or losing a contract. Worse, if frustrated shipments occur on a regular basis, the delay in bringing goods to market can mean a drain on profits.
The Difficulties of Multimodal Training
A problem that companies have in training employees in multimodal transportation is keeping up with regulatory changes. Each of the transportation modes is on a different update schedule:
The US hazardous materials shipping regulations codified as
49 CFR Parts 100 to 185 are updated continuously through
Federal Register notices.
The International Air Transport Association (IATA) Dangerous
Goods Regulations are updated on a yearly basis. However, the
basis of the IATA regulations, International Civil Aviation
Organization, Technical Instructions are updated every
two years.
International Maritime Organization Dangerous Goods Code, the UN Recommendations on the Transport of Dangerous
Goods Model Regulations and European Agreement Concerning
the International Carriage of Dangerous Goods by Road are
also updated biannually.
Amendments to these international publications may be made at any time through Errata.
Impact of September 11
There is an increased awareness by the transportation industry and the government of the vulnerabilities inherent in the transportation of hazardous materials since September 11. The primary focus is on licensing drivers, but training is also being scrutinized. Due to this increased vigilance, training records are more likely to be reviewed by compliance officers and carriers. Many recent compliance reviews have been focused strictly on training records.
Successful Multimodal Shipping
The key to successful multimodal shipping is a strong training program. Such a training program should be constructed by utilizing the following:
Keep training records up to date.
Train on every mode the company is using.
Purchase hazardous materials shipping supplies including labels, placards and forms from a reliable source that constantly monitors regulations.
Monitor compliance company and government Web sites.
Make sure all regulatory publications are current.
Use regulatory references that combine the requirements of multiple modes into one publication.
Ensure all required training (including recurrent training) has been completed.
In light of recent events and the globalization of hazardous materials shipping, companies need to find ways to keep up with all of the regulations and constantly modify their training programs. Constant retraining and awareness of regulatory changes are essential to the success of any company that ships hazardous materials.
Tracie Ross is senior regulatory specialist of Research and Development at Labelmaster. She can be reached by e-mail at tracier@alc-net.com. Jeanne Zmich is vice president of Research and Development at Labelmaster. Her e-mail address is jeannez@alc-net.com.
