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COUNTERMEASURE
Objective: To reduce the frequency of hazardous materials incidents occurring during loading and unloading by implementing a regular preventive maintenance program for loading/unloading equipment.
Description: Hazardous materials incidents at loading/unloading sites can be costly to a company and dangerous to its Hazmat employees. Preventive maintenance of loading and unloading equipment should be the first step in combating the occurrence of these incidents.
Questions for Management:
1. Is equipment maintenance carried out on a regular basis?
2. Are personnel qualified to carry out maintenance procedures?
Tips for Management:
* Ensure that pipe and hose markings are maintained regularly.
* Consider installing excess flow valves when appropriate.
Tips for Hazmat Employees:
* Report any equipment in need of repair or routine maintenance.
* Warn coworkers not to use equipment if it is in need of repair.
References: 49 CFR Parts: 172.700; 177 Subpart B; 392.7; 396.3; 396.13. A7, A8, C1, C11, C12, G1.
VEHICLE MAINTENANCE M2
COUNTERMEASURE
Objective: To reduce the frequency of hazardous materials incidents caused by defective equipment by implementing a vehicle preventive maintenance program.
Description: A poorly maintained vehicle may lead to a hazardous materials incident. A comprehensive preventive maintenance program for vehicles can reduce the frequency of such preventable incidents and save the company time, money, and embarrassment.
Questions for Management:
1. Are repairs carried out in a timely manner?
2. If a vehicle requires service, is it clearly marked to avoid its inadvertent use?
3. If a problem is identified on one vehicle, are similar vehicles in the fleet inspected for that problem?
Tips for Management:
* Verify that a preventive maintenance program is in operation.
* Verify that a system of daily driver reporting, such as the DVIR, is in operation.
Tips for Hazmat Employees:
1. Inspect the brake adjustment and tire pressures.
2. When refueling, turn engine off and control fuel flow at nozzle.
3. Ensure venting and pumping systems are operational and well maintained.
References: 49 CFR Parts: 177.804; 180.407; 396.3; 396.11; 396.13; 396.25; 397.15. C1, G4, G8.
SAFETY EQUIPMENT MAINTENANCE M3
COUNTERMEASURE
Objective: To reduce the frequency of hazardous materials incidents due to poorly maintained safety equipment by implementing a safety equipment preventive maintenance program.
Description: Safety equipment is necessary to protect company personnel and equipment from potentially hazardous situations. If poorly maintained, safety equipment itself will become ineffective and even dangerous. A routine preventive maintenance program can ensure the proper operation of all safety equipment.
Questions for Management:
1. Is maintenance of safety equipment performed regularly?
2. Is there a team approach where the driver and maintenance crew work together in
identifying problems or do they blame each other for maintenance and repair problems?
3. Is breathing equipment regularly inspected and does it meet applicable standards?
Tips for Management:
* Be sure to include newly acquired equipment into existing preventive maintenance schedules.
* Be sure that preventive maintenance is being performed on schedule.
Tips for Hazmat Employees:
* Check the charges of fire extinguishers and notify management if any need to be recharged.
* Be sure that vehicles have the proper safety equipment.
References: 49 CFR Parts: 172.704(a)(3); 173.34; 177.840; 180.407; 392.7; 393.93; 396.3; 396.11; 396.13. B12, C1, G1, G2, B8.
PACKAGING MAINTENANCE M4
COUNTERMEASURE
Objective: To reduce the frequency of leaks and spills due to poorly maintained packaging through conducting regularly scheduled preventive maintenance.
Description: Leaking or otherwise faulty containers can create potentially threatening situations for Hazmat employees, equipment and the environment. A regular and comprehensive preventive maintenance program will ensure that containers are kept in proper working order.
Questions for Management:
1. Is there a routine preventive maintenance program in operation for packages?
2. Would it be beneficial to monitor hazardous materials packages using a material-specific leak
detector?
3. Is the authorization of packaging for hazardous materials shipped being verified?
4. Is packaging being recycled?
5. Who is responsible for the performance of recycled packaging?
6. How is recycled packaging tested for integrity?
Tips for Management:
* Follow up on the purchasing process to verify that the proper packages are being obtained.
Tips for Hazmat Employees:
* Do not accept a package if it emits an odor, has a wet spot, or shows other signs of damage.
References: 49 CFR Parts: 171.2; 173.3; 173.24; 173.25; 173.28; 173.32; 173.32a; 173.32c; 173.34; 173.40; 177.854(d); 180..404; 172.407; 172.704; 173.4; C4, B2.
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