Impacts from 9/11 continue to affect our once-standard business procedures. Now, shipments into and out of the US are being carefully watched at all seaports for verification of goods, packaging, documentation, and more. In some cases, entire containers are being subjected to extreme tests including full cargo X-Ray, partial verification of contents, and a complete unloading and reloading of the container contents. For all these inspections, the related costs are not quoted as a part of the container transit expense — but these charges will be passed on to the customer. Inspection fees can range from about $500 to $1,000 USD, and there can be charges for storage time and detention. While we cannot object to this elevated security measure, we can prepare for the potential charges that might be incurred should a shipment be subjected to one of these inspections. At Skolnik, we believe a 50/50 split between the shipper and consignee is a fair understanding.
STEEL DRUM INDUSTRY NEWS, TRENDS AND ISSUES
Archive for July, 2003
For the past year, the pressure to train haz-mat employees has been emphasized. There have been some questions about who qualifies for required training, and the DOT has been clear that from manufacturing to sales, all those that can affect Hazardous Material transport or storage must be trained. What seems to be a great company benefit resulting from training is that employees are becoming aware that some of their routine procedures cannot continue without suffering heavy regulatory fines. For example, paint samples (a flammable liquid) were sometimes sent via mail or overnight courier, but in haz-mat training, one learns that this type of shipment is no longer allowed. In other scenarios, shipments of poison, fuel, and machine engines with vapor or fumes present are also not allowed. In fact, if an employee were to unknowingly violate these regulations, the employer could receive a fine of up to $100,000.00. Though just one example of exposure, understanding proper haz-mat regulations is one key for companies to remain compliant and not suffer regulatory violation fines.
Applicability of the Hazardous Material Regulations is determined by location. If in transport, storage, or disposal, a package moves onto or crosses through a public right-of-way (ie: railroad track, river, alleyway, or street) the Hazardous Material Regulations (HMR 49, Parts 171-180) apply. Packages not in compliance will be subject to fine. On private property, a packaged hazardous material does not have to comply with the HMR. In a recent letter to DOT, a company asked if HMR compliance was necessary when moving products within their corporate campus, yet over a set of railroad tracks on their property. The DOT response was that yes, even though the tracks ran through a private property, the track bed is considered a public right-of-way, and therefore, movement over the tracks must be in accordance with HMR.