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COUNTERMEASURE
Objective: To reduce the frequency of hazardous materials loading and unloading incidents through regular inspections of loading and unloading equipment and procedures.
Description: A large majority of hazardous materials incidents occur during loading and unloading operations. Providing adequate supervision of these operations and inspecting material handling equipment regularly may reduce the number of Hazmat incidents at this stage of the transportation process.
Questions for Management:
1. Are all loading/unloading operations supervised or conducted by experienced staff?
2. Are flammable materials and explosives kept away from sources of ignition or heat sources
(including cargo heater and air conditioning units)?
3. Are you complying with DOT regulations regarding the compatibility of hazardous materials per
the Segregation Table for Hazardous Materials?
Tips for Management:
* Be aware that certain chemicals react with air or water and require special loading/unloading equipment.
Tips for Hazmat Employees:
* Contact management if a suspicious shipment is offered.
* Check the compatibility of mixed loads.
* Check the weight distribution of loads.
* Verify that the cargo is properly secured.
* Check the type, number, and stacking arrangement of load.
* Ensure that the load will not swing over the cab during loading/unloading.
* Ensure cylinders are kept positioned correctly and that temperatures are kept within a safe range.
* Verify that tank trucks are grounded prior to loading and unloading.
* Prior to loading bulk loads, inspect the tank for objects which are not bonded.
* Inspect valves, connections, emergency shutoff valves, and pipes before loading.
* Verify that container is safe for filling.
* Verify that all truck electrical systems are off before loading or unloading.
* Conduct a walk-around inspection prior to driving away.
References: 49 CFR Parts: 173.30; 177.834; 177.838; 177.848; 392; 396; 397. C12, C2, C11, C12, G1, G2, G3, G4, G7, B1.
VEHICLE INSPECTION I2
COUNTERMEASURE
Objective: To reduce the frequency of vehicle breakdowns and hazardous materials incidents by thorough and regular inspections of fleet vehicles.
Description: Regular vehicle inspection is an integral part of the maintenance program of fleet vehicles. Inspections by qualified personnel dramatically reduce the number of vehicle breakdowns and malfunctions thereby improving overall vehicle fleet operations efficiency and helping to reduce the number of hazardous materials incidents.
Questions for Management:
1. Are vehicles subject to comprehensive pre-trip and post-trip inspections?
2. Are vehicles and loads systematically inspected at regular intervals during a trip?
3. Are frequent functional tests carried out?
4. Are vehicles appropriate for their hazardous materials cargo?
5. Are flammable solids or oxidizers carried in closed cargo spaces?
6. Do vehicles have tight floors where required?
Tips for Management:
* Thoroughly inspect and test vehicles periodically for safe operation.
* Be sure that vehicle repairs are performed in a timely fashion.
* Keep records of results and dates of vehicle inspections and repairs.
Tips for Drivers:
* Check for loose, worn or leaking parts.
* Check pressure, temperature, liquid levels and gauges before setting out.
* Adjust mirrors.
* Check for hot brakes regularly.
* Do not drive your vehicle unless it is safe to do so.
References: 49 CFR Parts: 177.824; 177.835; 177.838; 396; 397. A7, A8, A9, C1, C2, G1, G2, G3, G8, T3.
PACKAGING INSPECTION I3
COUNTERMEASURE
Objective: To reduce the frequency of accidental leaks of hazardous materials due to incompatible or damaged packages by conducting thorough inspections of packages prior to and during the transportation process.
Description: Use of correct packaging is the single most effective measure in reducing hazardous materials incidents. Inadequate packaging can result in costly and damaging Hazmat incidents. These incidents can often be prevented by conscientiously inspecting all packages and containers.
Questions for Management:
1. Is there a quality control program in effect to ensure the monitoring of package integrity
on a regular basis?
2. Is authorized packaging used for hazardous materials?
3. Are sample packages subject to performance testing such as a drop test?
4. Are cylinder scales frequently calibrated to maintain accuracy?
5. Are Hazmat employees aware that flammable bulk packages must be grounded or bonded?
6. Are material-specific leak detectors used to detect leakage and/or permeation?
Tips for Management:
* Require and encourage Hazmat employees to perform visual inspections of packages as they are
loaded and unloaded.
Tips for Hazmat Employees:
* Be alert for containers which are underfilled or overfilled.
* Properly clean, purge, and inspect containers to ensure there is no residue from previous loads.
* Inspect over-fill protection systems for proper operation.
* Inspect pressure, temperature and liquid-level gauges.
* Ensure valve-protecting caps and collars are in place on cylinders of compressed gases, if required.
* Inspect containers and packages to ensure that they are properly labeled and marked.
* Ensure that containers and packages are secure.
* Inspect the stacking arrangements of all loads, including blocking and bracing.
* Ensure that cargo has the appropriate ventilation.
* Inspect all tank mountings.
References: 49 CFR Parts: 171.2; 171.11; 171.12; 171.400; 173; 173.1; 177.824; 177.834; 177.848; 396. C11, C12, G1, G2, G3, G4, G9, B8.
SAFETY EQUIPMENT INSPECTION I4
COUNTERMEASURE
Objective: To ensure that safety equipment is in good working order through regular and thorough inspections.
Description: Properly functioning safety equipment for vehicles, plant machinery and personnel is essential for reducing the frequency and severity of hazardous materials incidents. Therefore, it is vital that complete inspections of safety equipment be routinely performed by qualified personnel.
Questions for Management:
1. Is all safety equipment inspected on a regular and scheduled basis?
2. Is safety equipment on vehicles including fire extinguishers and personal protection equipment,
inspected before setting out?
3. Should spare parts, such as headlamps and directional bulbs, be carried with each vehicle?
4. Is the personal protective equipment provided to Hazmat employees suitable for the hazardous
materials being handled?
5. Are Hazmat employees trained to inspect chemical respirators since this equipment has a finite life
once exposed to atmosphere or chemicals?
6. Are compressed-gas cylinder safety devices checked regularly?
Tips for Management:
* Provide checklists for all equipment inspections and require their use.
* Keep records of all equipment inspections and review periodically.
Tips for Hazmat Employees:
* Check vehicle maintenance log for last servicing date and findings.
* Inspect emergency/remote shutoff valves at beginning of each shift or as part of pre-trip inspection.
References: 49 CFR Parts: 172.704(a)(3); 173.34; 177.802; 180.407; 392.7; 393; 393.93; 393.95; 396; 396.3; 396.11; 393.13. A7, B12, C1, C2, G1, G2, T1.
LABELING INSPECTION I5
COUNTERMEASURE
Objective: To promote effective communication of hazards associated with shipments by the visual inspection of package labeling.
Description: The purpose of package labels is to communicate the primary hazards of the material being shipped. Hazmat employees handling the package should be familiar with the labels in order to be aware of and to respect the potential dangers of the material. Emergency responders also need this information in order to respond correctly in case of an incident. Regular inspections of package labeling may detect packages which are not in compliance with federal regulations.
Questions for Management:
1. Are all samples which are transported labeled for hazard class?
2. Should a reference table be provided to the drivers for interpreting numerical markings and labels?
3. Are carrying capacities marked on tanks, cylinders, and trucks?
Tips for Management:
* Alert employees to the importance of package labeling.
* Encourage employees to check package labeling.
Tips for Hazmat Employees:
* Inspect labels to ensure that they match shipping papers.
References: 49 CFR Parts: 172.101; 172.400; 172.401; 172.404; 172.407; 172.704; 173.4; 177.815. A11, C2, C11, C12, G9, B8, B9.
SHIPPING PAPERS AND CLASSIFICATION INSPECTION I6
COUNTERMEASURE
Objective: To ensure that the information contained in the shipping papers is complete and corresponds to the hazardous materials being transported.
Description: The shipping papers will quickly identify the hazardous materials involved in a Hazmat incident. For this reason, it is critical that the information contained in the documents be accurate. Emergency responders rely heavily on shipping papers for properly identifying materials as well as for finding sources of technical assistance.
Questions for Management:
1. Are hazardous materials clearly identified on shipping papers?
2. Do you have most recent emergency response information?
3. If Material Safety Data Sheets refer to personal protection equipment such as respirators, is this
equipment available?
Tips for Management:
* Alert employees to the importance and use of shipping papers in both routine and emergency situations.
* Encourage employees to inspect shipping papers for content and format.
Tips for Hazmat Employees:
Be sure that emergency response information is immediately available for use at all times.
Check that shipping papers are legible, complete, and that all listed hazardous materials are easily identifiable.
Check that shipping papers are stored for easy access.
Check to ensure that shipment matches shipping papers, placards, markings and labels.
References: 49 CFR Parts: 171.2; 172.101; 172.200; 172.201; 172.202; 172.203; 172.600; 172.604; 172.700; 177.817; 177.848. A7, A8, A11, C2, G3, G5, G9, G12, B2, B8, B9.
PLACARDING INSPECTION I7
COUNTERMEASURE
Objective: To ensure that proper placards appear on the exterior of a vehicle.
Description: In the event of a hazardous materials incident, placards are often the first source of information used in evaluating the hazards of an unidentified Hazmat shipment. The inspection of vehicle placards prior to departure will ensure that the information displayed is accurate.
Questions for Management:
1. Are vehicle equipped with the proper tools for attaching placards?
2. Are placards being offered by the shipper to the carrier?
3. Is the carrier placing the placards on the vehicle?
4. Are replacement placards available to Hazmat employees?
Tips for Management:
* Train Hazmat employees to properly choose placards.
* Consider the use of separate placards versus the use of flip-type placards.
Tips for Hazmat Employees:
* Inspect placards prior to departure to ensure they are clean and legible.
* Verify that the placards match the shipping papers.
* Clean any dirty placards.
* Replace any damaged or illegible placards.
* Remove or change the placards only when it is appropriate to do so.
References: 49 CFR Parts: 172.500; 172.506; 172.516; 172.704; 177.823. C2, C10, G3, G5, G12, B2, B6, B9 .
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