Staying Compliant as a Hazmat Carrier

May 10, 2016 – There are many components of the Federal Motor Carrier Safety Regulations (FMCSRs) that motor carriers must comply with. With so much focus on regulations such as Hours of Service and Drug and Alcohol Testing, it’s easy to forget that Hazmat carriers have their very own set of regulations to comply with.

Although incredibly important to the safety of our roadways, the regulations surrounding the transportation of hazardous materials are vast and complex. If you need an example of this, simply take a look at the Hazardous Materials Table, which contains over 3,000 shipping substances that are all considered hazardous.

To help simplify the process, here is an overview of the core requirements you must follow to operate legally as a hazmat carrier.

Registration

Not only must hazmat carriers register with the Pipeline & Hazardous Materials Safety Administration (PHMSA) each year, but they must retain each certificate for a minimum of three years. In addition, a copy of the carrier’s current registration certificate must be kept in each vehicle.

Security Plans

Hazmat carriers are required to implement a detailed plan that addresses company specific information, including risks associated with their operations, procedures taken in the event of an accident and the following information:

• Procedures regarding background checks on applicants;
• Assessment of the likelihood of unauthorized individuals gaining access to hazardous materials and/or vehicles and prevention measures;
• Specific routes and storage facilities primarily used;
• Identification of an individual who is responsible for managing, distributing and updating the plan.

Security plans must be distributed to all personnel involved in the operation and transportation of hazardous materials. If updates are made, addendums must be distributed as well.

Communication & Route Plans

The regulations state that hazmat carriers must try, to the best of their ability, avoiding heavily populated, crowded areas as well as tunnels, alleys and narrow passageways. Prior to a trip, the carrier and/or driver must develop a written plan detailing the routes that will be used. A copy of this plan must be retained in the vehicle.

A communication plan that enables the driver and carrier to have regular contact must also be in place. At a minimum, drivers must make contact at the beginning and end of each trip. Records of contact made during each trip must be maintained for a period of six months.

Training Requirements

There are various training requirements that pertain to all hazmat employees which include:

• General awareness training to ensure employees obtain basic knowledge of the regulations, as well as an ability to identify hazardous materials;
• Security awareness training to be completed within 90 days of beginning employment;
• Job function training regarding specific positions, roles and responsibilities;
• Safety training which includes emergency response information and procedures specific to each job function;
• In-depth security training centered on the carrier’s security plan and safety procedures. This must be completed within 90 days of beginning employment and repeated every three years. Furthermore, if the security plan is updated at any time, training must be completed within 90 days of the update.

Shipping Papers & Placarding

One of the most common violations hazmat carriers receive is the incorrect preparation of shipping papers. It makes sense considering the daunting Hazardous Materials Table mentioned at the beginning of this article plays a significant role in applicable information. Fortunately, the PHMSA provides a Guide for Preparing Shipping Papers which can be found at:

https://hazmatonline.phmsa.dot.gov/services/publication_documents/Guide%20for%20Preparing%20Shipping%20Papers.pdf

Likewise, they provide a Hazardous Materials Markings, Labeling and Placarding Guide located at:

http://phmsa.dot.gov/pv_obj_cache/pv_obj_id_B7F8DEE98FD84C56E80389202FAE7EA34E9C2100/filename/chart%2015.pdf

We all know accidents happen. And regardless of the type of business you operate, an accident can have a devastating effect. Now put hazardous materials into the mix and the effect could be catastrophic. Therefore, no matter how tedious it may seem, it is crucial for all hazmat carriers to understand the regulations and to strictly comply.

Need help setting up a Hazardous Materials Security Plan? Call (800) 253-5506 to speak with a Foley representative today!