The Federal Motor Carrier Safety Administration (FMCSA) has published its new Form 150 B to be used to obtain a hazmat safety permit, according to information from the National Tank Truck Carriers (NTTC). While this program will be effective as of January 1, 2005, carriers need not file as of or before that date.
"Keep in mind that this permitting program is in addition to, not in lieu of, the annual hazmat registration program conducted by the Research and Special Programs Administration for which carriers pay an annual fee," says Cliff Harvison, NTTC president. "There is no such fee for the hazmat permit. Many of the carriers will be faced with shipper requirements that mandate a permit as of the first of the year. Simply stated, many in the shipper community are not aware of the staggered implementation of this program; so carriers may find it in their best interests to apply for a permit as soon as possible, and they can do that now. Carriers may have to check with affected shippers to determine their policy on this matter."
Whether or not carriers need a permit, they must update their motor carrier identification data every two years. To see how and when to do this go to NTTC’s Web site at tanktruck.org, click on News and Updates and review the first two items on that page for details on when carriers must update.
Today, the updating (required of all carriers every two years) and permitting (for those who require a permit) have been combined in the Form 150 filing. However, there is nothing to prevent carriers from filling out Form 150 B now in order to obtain the permit.
For tank truck carriers, three groups of commodities will require a permit: commodities classified as poison inhalation hazard (PIH) (sometimes referred to as toxic inhalation hazard (TIH)); liquefied natural gas (not liquefied petroleum gas such as propane, butane, etc); and any bulk transportation of anhydrous ammonia (domestic or international).
Some commodities such as combustible liquids may have PIH/TIH as a secondary hazard. If so, they need a permit. Carriers should check this out with shippers.
When carriers obtain the permit, they will be required to keep a notation of the Department of Transportation (DOT)-assigned permit number in the vehicles hauling permitted loads. That number can be on shipping papers, a copy of the permit itself, or on other records available on the vehicle.
"The permitted vehicle (and/or its driver) will have to have the telephone number of a carrier representative who can verify that the vehicle is in the general area of the expected route of the shipment," Harvison says. "Any resulting phone call must be answered, directly. In other words, answering machines or recorders will not comply. In most cases, this may require a manned 24/7 phone contact."
Permitted carriers must have a written communications plan and the vehicle (and/or driver) must have the capability of contacting the carrier at (both) the beginning and end of each duty tour as well as at the times of pickup and delivery. DOT will permit phone or radio calls and/or electronic tracking to meet this requirement.
A log of those communications (for example, a corporate communications log or driver’s log) must be maintained for six months. Once carriers have completed the Form 150 B paperwork, it may be transmitted to DOT either by surface mail or fax. On-Line filing via the Internet is not available at this time.
If carriers choose surface mail, send the completed paperwork to: the FMCSA, MC-RIS, 400 7th St SW, Washington DC 20590. The fax number for filing is 703-280-4003.
"NTTC strongly recommends filing all permit applications via fax," Harvison adds. "The post 9/11 anthrax attacks have made surface mail deliveries within the Washington DC area agonizingly slow."