As you read this article, your company could be at risk right now for fines or even an incident caused by a piece luggage. “Luggage?”, you’re wondering. In fact you’re probably thinking: “There’s no luggage in my supply chain. Our stuff moves in corrugated boxes, with “green” packaging, and proper paperwork, etc.” But if your company has a traveling sales force, or engineers or executives who travel with samples, components, production-related materials, or personal electronic devices, your company and your people could be violating the law, as well as endangering fellow passengers and themselves, and exposing your company and employees to fines and/or imprisonment. Let’s look at a couple of categories you hope are under control at your company.
Dangerous Goods or Hazardous Materials
Most domestic Hazardous Materials, also referred to as HazMat or Dangerous Goods, fall under the jurisdiction and differing definitions of three Federal agencies: DOT (Department of Transportation); EPA (Environmental Protection Agency); and OSHA (Occupational Safety and Health Administration). In addition, the NRC (Nuclear Regulatory Commission) regulates nuclear materials; plus there are international and foreign country regulations which may differ from their U.S. counterparts.
The regular inbound and outbound shipments made by your company probably comply with all of the applicable rules and regulations regarding packaging, paperwork, and handling. These are usually managed by trained experts who know how to ship safely and follow all required steps. But what happens when a salesman takes a “harmless sample” to a customer, or an engineer brings a sample home, not realizing it is a “Reportable Quantity” (requiring paperwork and precautions) under Federal regulations? (The “Reportable Quantity” for some Hazardous Materials, by the way, can be as small as fractions of an ounce). If caught by TSA at the airport, that person’s trip could be over – as could his career! The easy way to avoid this problem is two-pronged: thorough research and informed policies. Just make sure that no materials leave or enter your facilities in the custody of an employee or customer unless the responsible Safety and Logistics departments have thoroughly researched that item and pre-approved specifically who will be carrying what particular material(s), and what packaging will be required. And then strongly enforce and reinforce these policies to make sure they are followed by anyone who could potentially carry such materials on behalf of your company.
Harmless Items Which Are Not So Harmless
Another hidden safety problem concerns the batteries we travel with. Check your pockets, briefcase, and backpack right now: how many batteries do you travel with? Do you carry extras? Those moving in the devices they power normally present no danger, unless they have been dropped or otherwise damaged and a resulting internal short causes overheating and possibly a fire. If properly cared for, these present no threat. However, any spare batteries you carry should concern you. First, make sure that all electrical contact points are covered to avoid shorts and be sure they stay dry.
Next, ensure that they are protected at least as well as when installed in their device. A soft backpack is not the best place to carry one of those awkwardly-shaped spare laptop batteries. If one takes the wrong hit, it could short and cause a fire right there - or when next used in the laptop. Finally, be aware that some regulations limit the amount of extra batteries a traveler can carry on or put in checked baggage.
How Do You Get The Message to Your Travelers?
At a large company I once worked for, employees traveling internationally were managed as part of the Supply Chain, and as logistics Director I had to provide them with specific directions on customs declarations and regulations, the proper use of Carnets, product safety, and the other elements discussed in this article. Some companies might instead use their in-house or outsourced travel department to disseminate this information. Others have no program at all, presenting the most dangerous situation of all. If this describes your company, get something in place, fast. Hire an outside HazMat expert if necessary, to quickly develop and implement procedures. Ignorance of the law is no excuse. And the lack of a HazMat education program for affected travelers could make the fines and jail penalties of any violation quite severe.
This article is part of the monthly series authored by ISM’s Logistics & Transportation Group Board Members, who are current practitioners, consultants, and educators. In future columns, they will continue sharing their views on a number of Supply Chain topics.
George Yarusavage, CTL, C.P.M., CICSM, is a principal in Fortress Consulting, LLC, specializing in Transportation, Logistics, and Sourcing issues. He is also the Treasurer of ISM’s Logistics & Transportation Group and can be reached at gyarusavage@yahoo.com, or (203) 984-4957. Membership in the L&T Group is open to all ISM members who are responsible for or have an interest in the Logistics & Transportation fields.
Dangerous Goods or Hazardous Materials
Most domestic Hazardous Materials, also referred to as HazMat or Dangerous Goods, fall under the jurisdiction and differing definitions of three Federal agencies: DOT (Department of Transportation); EPA (Environmental Protection Agency); and OSHA (Occupational Safety and Health Administration). In addition, the NRC (Nuclear Regulatory Commission) regulates nuclear materials; plus there are international and foreign country regulations which may differ from their U.S. counterparts.
The regular inbound and outbound shipments made by your company probably comply with all of the applicable rules and regulations regarding packaging, paperwork, and handling. These are usually managed by trained experts who know how to ship safely and follow all required steps. But what happens when a salesman takes a “harmless sample” to a customer, or an engineer brings a sample home, not realizing it is a “Reportable Quantity” (requiring paperwork and precautions) under Federal regulations? (The “Reportable Quantity” for some Hazardous Materials, by the way, can be as small as fractions of an ounce). If caught by TSA at the airport, that person’s trip could be over – as could his career! The easy way to avoid this problem is two-pronged: thorough research and informed policies. Just make sure that no materials leave or enter your facilities in the custody of an employee or customer unless the responsible Safety and Logistics departments have thoroughly researched that item and pre-approved specifically who will be carrying what particular material(s), and what packaging will be required. And then strongly enforce and reinforce these policies to make sure they are followed by anyone who could potentially carry such materials on behalf of your company.
Harmless Items Which Are Not So Harmless
Another hidden safety problem concerns the batteries we travel with. Check your pockets, briefcase, and backpack right now: how many batteries do you travel with? Do you carry extras? Those moving in the devices they power normally present no danger, unless they have been dropped or otherwise damaged and a resulting internal short causes overheating and possibly a fire. If properly cared for, these present no threat. However, any spare batteries you carry should concern you. First, make sure that all electrical contact points are covered to avoid shorts and be sure they stay dry.
Next, ensure that they are protected at least as well as when installed in their device. A soft backpack is not the best place to carry one of those awkwardly-shaped spare laptop batteries. If one takes the wrong hit, it could short and cause a fire right there - or when next used in the laptop. Finally, be aware that some regulations limit the amount of extra batteries a traveler can carry on or put in checked baggage.
How Do You Get The Message to Your Travelers?
At a large company I once worked for, employees traveling internationally were managed as part of the Supply Chain, and as logistics Director I had to provide them with specific directions on customs declarations and regulations, the proper use of Carnets, product safety, and the other elements discussed in this article. Some companies might instead use their in-house or outsourced travel department to disseminate this information. Others have no program at all, presenting the most dangerous situation of all. If this describes your company, get something in place, fast. Hire an outside HazMat expert if necessary, to quickly develop and implement procedures. Ignorance of the law is no excuse. And the lack of a HazMat education program for affected travelers could make the fines and jail penalties of any violation quite severe.
This article is part of the monthly series authored by ISM’s Logistics & Transportation Group Board Members, who are current practitioners, consultants, and educators. In future columns, they will continue sharing their views on a number of Supply Chain topics.
George Yarusavage, CTL, C.P.M., CICSM, is a principal in Fortress Consulting, LLC, specializing in Transportation, Logistics, and Sourcing issues. He is also the Treasurer of ISM’s Logistics & Transportation Group and can be reached at gyarusavage@yahoo.com, or (203) 984-4957. Membership in the L&T Group is open to all ISM members who are responsible for or have an interest in the Logistics & Transportation fields.
