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Archive for the ‘Safety’ Category

Carriers Fine Shippers for Undeclared Hazardous Cargo

September 24th, 2019 by Howard Skolnik

Filed under: HazMat, Safety, Skolnik Newsletter

A quarter of all liner fires reported to the Cargo Incident Notification System (CINS) relate to mis-declared cargo, particularly hazardous materials. It is an age-old problem that has blighted shipping for too long, rogue shippers willfully breaking the rules to avoid freight rate and insurance premiums on dangerous goods, or committing customs fraud by declaring high value goods as more common items. The invention of the steel container made it even easier to conceal such fraudulent activity, leaving shipping lines with an uphill challenge to combat it.

With the number of container fires rapidly escalating, a few carriers recently announced that they would levy penalties on shippers for mis-declaring cargoes. These fires come at great expense to the carriers and put all on-board cargo at risk, as well as the integrity of the ship. Hapag-Lloyd, which last year shipped nearly half a million dangerous goods, effective September 15, 2019, fine shippers $15,000 for undeclared or mis-declared hazardous cargo. HMM will fine the same amount, while Evergreen announced a penalty of $35,000.

While more carriers are likely to follow the lead, the question of will the threat of financial punishment help to correct the behavior of the less willfully negligent shippers. It is unlikely to change the attitude of any rogue shipper who will still bet on evading the proper shipping regulations. It is hoped that most law-abiding shippers will welcome any measure that will help reduce the risk of their cargo being delayed or destroyed by the irresponsible action of others.

New Regulation for Lithium Battery Manufacturers and Distributors

August 3rd, 2019 by Howard Skolnik

Filed under: DOT/UN, HazMat, Industry News, Safety, Skolnik Newsletter

There is a new requirement for lithium cells and batteries that has the potential of creating a huge wave within the dangerous goods community within the next 2 years. This requirement is known as the “UN 38.3.5 Lithium cell and battery summary” that can be found in the “Recommendations on the Transport of Dangerous Goods Modal Regulations Volume II twentieth revised edition”. In paragraph 38.3.5 it states, “the following test summary shall be made available”. The question becomes “made available to whom”? The intent of the paragraph was meant to mean that the 38.3 test summary be made available by manufacturers and subsequent distributors of lithium cells and batteries to regulatory enforcements officials. The test summary refers to the UN 38.3 testing that is conducted on all new lithium batteries.

The testing on these batteries ensures that batteries are in a condition for transport that ensures that the batteries travel safely through the logistics chain. The testing and subsequent documentation also ensures that counterfeit batteries that have not been tested stay out of the logistics chain. According to 38.3.5 the information that “shall” be provided in the test summary include:

  • Name of cell, battery or product manufacturer, as applicable;
  • Cell, battery or product manufacturers contact information to include address, phone number, email address and website for more information
  • Name of test laboratory to include address, phone number, email address and website for more information
  • A unique test report identification number
  • Date of test report
  • Description of cell or battery to include at a minimum;
    • Lithium ion or lithium metal cell or battery
    • Mass;
    • Watt-hour rating or lithium content
    • Physical description of the cell/battery; and
    • Model numbers
    • List of tests conducted and results (i.e., pass/fail)
  • Reference to the assembled battery or testing requirements, if applicable (i.e. 38.3.3 (f) and 38.3.3 (g));
  • Reference to the revised edition of the Manual of Tests and Criteria used and to amendments thereto, if any; and
  • Signature with name and title of signatory as an indication of the validity of information provided. Lithium Cell and Battery Test Summary Challenge with change.

As with most changes that occur with the regulations, the challenge will be communicating the correct application of this rule to shippers, freight forwarders to ensure that there is an understanding that this document is not necessary for transport. Comprehensive and consistent training is an easy way to ensure that the requirement for this document is understood and implemented correctly. Remember, the document is meant to be made available to enforcement officials that need to refer to it should there be an incident involving a lithium battery shipment.

Easy HazMat Training Options to Remain Compliant

July 30th, 2019 by Howard Skolnik

Filed under: HazMat, Safety, Skolnik Newsletter

More than ever before, improper or non-existent training is being viewed as the major cause of many dangerous goods incidents happening today in the US and abroad. A large percentage of the DOT‘s enforcement actions pertain to the failure of employers to provide appropriate hazardous materials training. In most cases, violations are the result of no function-specific training, or no recurrent training which is required every 3 years. We recommend that employers use outside consultants to establish and monitor the efficacy of a training program. An outside consultant can choose appropriate testing requirements, administer testing and track ongoing compliance. This includes training for new employees as well as re-training for employees that receive additional responsibilities.

While many training programs are available, Labelmaster offers face to face, classroom programs that are recognized as being of particularly high quality. Check here to learn more about these options.

For on-line training, Labelmaster also offers 9 critical courses that are essential for dangerous goods shippers and employers. These classes (https://www.labelmaster.com/shop/training) are easy to administer, can be attended from anywhere in the world, and are available 24/7.

Whether face to face or electronically, there is no reason for HazMat employers to overlook their training responsibilities.

US DOT Embraces Auto Driving

June 25th, 2019 by Howard Skolnik

Filed under: DOT/UN, Safety, Skolnik Newsletter

The United States surface transportation system provides tremendous mobility benefits, including widespread access to jobs, goods, and services. It also connects many remote regions of the country to the larger economy. These benefits, however, come with significant safety challenges, as motor vehicle crashes remain a leading cause of death, with an estimated 37,133 lives lost on U.S. roads in 2017. Traditional safety programs and policies have made road travel significantly safer than in the past, but there is much room to improve traffic fatality and injury rates.

The U.S. Department of Transportation is taking active steps to prepare for the future by engaging with new technologies to ensure safety without hampering innovation. With the release of Automated Driving Systems 2.0: A Vision for Safety, the Department provided voluntary guidance to industry, as well as technical assistance and best practices to States, offering a path forward for the safe testing and integration of automated driving systems. The Department also bolstered its engagement with the automotive industry, technology companies, ii PREPARING FOR THE FUTURE OF TRANSPORTATION and other key transportation stakeholders and innovators to continue to develop a policy framework that facilitates the safe integration of this technology into our transportation systems. Preparing for the Future of Transportation: Automated Vehicles 3.0 (AV 3.0) is another milestone in the Department’s development of a flexible, responsible approach to a framework for multimodal automation. It introduces guiding principles and describes the Department’s strategy to address existing barriers to safety innovation and progress. It also communicates the Department’s agenda to the public and stakeholders on important policy issues, and identifies opportunities for cross-modal collaboration.

Read the full article here