THINKING of federal hazardous materials regulations as traffic laws may help simplify the 1,000-page federal code, said Robert Craig of the Transportation Safety Institute (TSI), Oklahoma City, Oklahoma. While the code may seem overwhelming on first glance, breaking it down in its three categories eases understanding. The categories include identification and communication, packaging, and operational rules.
"All of these are trying to achieve safety for the people and property," Craig said. He also emphasized that many regulations are the result of past hazardous materials incidents.
Under the category of identification and communication are regulations for placards, product names and classifications, and emergency response papers. Packaging regulations direct what material may be in what kind of package. Operational rules include the segregation tables related to which products can be shipped together, or be near each other, and which have to be separated.
Craig conducted a hazmat training workshop at the annual OPSEM2000 meeting sponsored by the National Association of Chemical Distributors September 13-15 in Dallas, Texas.
The workshop is one of many TSI provides for the transportation industry. The school was created in 1971 by the Department of Transportation (DOT) and is administered by the Research and Special Programs Administration (RSPA). TSI includes training and technical assistance on many subjects.
One of the subjects Craig discussed was the 10-column hazmat table. He pointed out that a product may fall under one designation for domestic transportation and another for international shipping.
Shipping papers must contain the name of the product, its hazmat class/division, an identification number, and the packaging group in which it belongs. The papers must be within arm reach of drivers and left on the driver's seat when the vehicle is unattended. An emergency response document also must be within reach of the driver. It must contain a basic description of the product, immediate hazards to health information, first-aid measures, and a 24-hour emergency response telephone number. The person assigned to the telephone response must be knowledgeable in hazmat, he said.
At the same time, an additive in a product may change the product status. For example, if acetone (a hazardous material because of its low flash point) has an additive that sets the flash point above 100 degrees, the product no longer is considered hazardous.
Additionally, some products may not be classified as a hazardous material, such as polychlorinated biphenyl(PCBs). However, because of their threat to the environment, they are considered a hazardous substance and require special handling. The Environmental Protection Agency (EPA) determines environmental harm while DOT sets hazardous materials classifications, Craig said.
He pointed out that packaging includes cargo tanks, and clarified two definitions: packaging means any kind of container that is empty of product, and a package means a container has product.
In-depth hazmat training and other subjects provided by TSI includes courses in cargo tank regulatory compliance, transportation of hazardous materials, DOT safety regulations for driver and the vehicle, and for preparation for a company federal or state review, and infectious substances transportation.
More advanced courses include instructor training, hazmat transportation, specialized explosives, and specialized hazardous wastes and substances.