October 2013

Compliance is as Easy as A-B-C


transportation-iconI began my career as a Dangerous Goods Consultant more than 20 years ago when I was working at the U.S. Coast Guard’s Marine Safety Office in Los Angeles-Long Beach, CA. I was the Division Chief for the Port Safety & Security and Container Inspection Divisions.
Although I enjoyed my job immensely and working with the fine young men and women of the U.S. Coast Guard even more, I found it very difficult and time consuming to process hundreds of civil penalty actions against those that violated the U.S. Dept. of Transportation’s (DOT) Hazardous Materials Regulations (HMR) in one form or another.
Although there were certainly a number of law-breakers that deserved to have the hammer dropped on them, most were one-time offenders that committed some rather benign error or omission. Because there was a “zero tolerance” policy in effect, our warnings were given in the form of civil penalty actions that ranged in price from a few hundred dollars to several tens of thousands of dollars.

I wondered what the solution might be—and then it dawned on me! We (the U.S. Coast Guard) should train the shippers, forwarders and steamship lines on how to comply with the regulatory requirements.

I put together a manual and invited 650 people to attend the “almost-free” training course at a local hotel. To my surprise, we had more than 600 positive responses, but sadly, had to close the door at 375 because we were exceeding the maximum occupancy for the ballroom. The training went well and it launched a rather exciting and lucrative career for me.

Now that I look back on it, I think compliance is really rather easy. It’s as simple as A-B-C. A few letters of the alphabet, when stringed together into simple mnemonics, can help the shipper and carrier understand some of the most complex regulatory requirements. A mnemonic is

“…any learning technique that aids information retention. Mnemonics aim to translate information into a form that the human brain can retain better than its original form. Even the process of merely learning this conversion might already aid in the transfer of information to long-term memory…Their use is based on the observation that the human mind more easily remembers spatial, personal, surprising, physical, … humorous, or otherwise ‘relatable’ information, rather than more abstract or impersonal forms of information.”

For example, one of the more common violations of the HMR is the incorrect basic description sequence. Prior to 2012, the basic description sequence on hazardous materials shipping papers was: (a) proper shipping name, including correct technical or chemical names, if they applied; (b) hazard class, division and compatibility group; (c) identification number; and (d) packing group, if applicable. I had created a simple acronym to help my students remember the basic description sequence: S-H-I-P, which represented the: (a) Shipping name; (b) Hazard class, division and compatibility group; (c) Identification number, preceded by the letters “UN” or “NA” as appropriate; and (d) Packing Group, if it applied.

All was good until the U.S. DOT changed the requirements to reflect the international system of dangerous goods documentation, which requires the identification number to be listed first. Knowing that I-S-H-P is not a word, I changed the mnemonic to I SHIP. I ship hazardous materials all the time—I ship them on a boat, train, truck and plane. I S-H-I-P: Identification number, Shipping name, Hazardous class Including the division and compatibility group, and Packing group, if it applies.

By creating simple acronyms and memory aids, my students are able to recall the most important requirements with the HMR.

Another example is the information required on packages containing dangerous goods, or over-packs containing hazardous materials packages:

On Packages:   TULIP

T Transportation information (including shipper & consignee name & address)
U UN or DOT specification packaging marks
L Labels, including the required hazard warning & cargo handling labels
I Identification number, preceded by the letters UN, NA or ID, as appropriate
P Proper shipping name, including the correct
technical and chemical names

On Over-packs:  PILOT

P Proper shipping name
 I Identification number
L Labels
O Overpack mark
 T Transportation information

A few more that you might find helpful:
When trying to remember the required information on a hazardous materials shipping paper, remember the acronym:


S Shipping name including the correct technical and chemical names, if applicable
H Hazard class, division and compatibility group, if applicable
I Identification number, preceded with the letters UN, NA or ID as appropriate
P Packing group
M Mass (weight) and Volume
A Additional descriptive information (such as permits and approvals, flashpoint)
T Telephone number in the event of an emergency
 E Emergency response information that addresses six emergency situations

The emergency response information is required to be provided on a hazardous materials shipping paper using one of the three methods, as follows:
W Written on the dangerous goods declaration A Attached as separate document (such as a Safety Data Sheet)
X X-referenced to a third, but available document (e.g., an Emergency Response Guide)

When involved in or responding to a hazardous materials spill or release, remember this important word:
G Get away;
 I Isolate (or Identify), and
N Notify others

By using these simple learning tools, one can develop a deeper, better understanding of the regulatory requirements and, maybe, just maybe, have a little fun while doing it. SPRAY