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COUNTERMEASURE
Objective: To reduce the frequency of hazardous material incidents by selecting and using the most appropriate travel routes and schedules.
Description: Arbitrary routing and scheduling may cause costly delays and contribute to preventable hazardous materials accidents. By adopting strict routing procedures and realistic, safe schedules, such problems may be avoided.
Questions for Management:
1. Is minimum-risk routing and scheduling employed?
2. Is a realistic amount of time allowed for loading and unloading?
3. Are deliveries scheduled so that shipments are unloaded shortly after arriving at their destinations?
4. Are hazardous materials shipping routes reviewed regularly?
5. Are maintenance facilities, rest areas, and pull-off and turn-around locations marked on route maps?
6. Are environmentally sensitive locations along the scheduled route properly marked?
Tips for Management:
* Use 6-lane highways wherever possible.
* Avoid railway crossings whenever possible.
* Investigate local curfews to minimize delays in delivery schedules.
* Identify potentially unsafe conditions along a route and make adjustments whenever possible.
* Try to avoid tunnels, bridges, winding or steep roads and ferryboat crossings.
* Develop a policy for evaluating weather conditions and deciding when to delay transportation.
Tips for Drivers:
* Preview route and identify potential problem areas.
* Determine if bad weather is forecast along your shipping route.
* Provide feedback to management regarding potential problem spots on routes after
completing deliveries.
References: 49 CFR Parts: 177.810; 177.825; 392.10; 397.9; 397 Subpart D. A11, G3, G4, B2, B6, B7, B8, B9.
TRAINING POLICY P2
COUNTERMEASURE
Objective: To reduce the frequency of hazardous materials incidents by the implementation of a comprehensive training program.
Description: Training programs are essential to ensure high safety standards. Establishing and maintaining high standards will serve to increase the professionalism of the company and reduce the potential for hazardous materials incidents.
Questions for Management:
1. Are there materials and/or facilities available for drivers to demonstrate their skills?
2. Is there a driver safety program in operation?
3. Is there a risk management program in operation?
4. Are employees trained in and aware of the properties of hazardous materials being handled
or carried?
5. Are employees trained in correct tool and equipment usage?
6. Is refresher training available for employees?
Tips for Management:
* Concentrate on effective communication between employees and management.
* Place a strong emphasis on obeying regulations and following correct procedures.
* Review fleet accident records and incident statistics then take appropriate action.
* Identify problem operations and develop safe procedures.
* Encourage cross-training among employees but be sure that procedures are correct.
* Provide all employees with Emergency Response Guidebooks; also be sure that these
guidebooks are placed in vehicles and that employees know how to use them.
References: 49 CFR Parts: 171.1; 171.2; 172 Subpart G; 172 Subpart H; 177 Subpart B. A9, G1, G7, G9, G14, B1, B4, B10, B12.
SUPERVISION POLICY P3
COUNTERMEASURE
Objective: To reduce the frequency of hazardous materials incidents by improving management's supervision policy.
Description: Proper supervision of all personnel involved with the handling and transportation of hazardous materials can significantly reduce the frequency of Hazmat incidents.
Questions for Management:
1. How does management demonstrate its commitment to safety?
2. Is there a safety program in operation?
3. Is there an identifiable supervisor?
4. Is there a policy regarding driver and fleet supervision?
5. Are loading and unloading operations adequately supervised?
6. How does management address comments or complaints from employees, customers and the public?
7. Does management support Hazmat employees who question improperly packaged or labeled cargo?
8. Are Hazmat employees provided with written, load-specific emergency instructions?
9. Are vehicles equipped with Emergency Response Guidebooks and do drivers understand how
to use it?
10. Is the Hazmat at such a level as to require notification of local authorities and contingency
planning?
11. Is notification of shipments required in writing?
12. Is there a process in place for anticipating late deliveries due to circumstances such as
bad weather?
13. How are missed or late deliveries handled?
14. Are duty hours properly recorded?
15. Is there adequate protection from unauthorized entry of facilities?
Tips for Management:
* Require immediate reporting of Hazmat incidents and monitor these reports.
* Establish a procedure for reviewing Hazmat incidents to determine the causes of incidents as well
as how to prevent similar mishaps in the future.
* Identify troublesome operations and work to improve corresponding Hazmat procedures.
* Install procedures which reduce communication errors and put procedures and instructions
in writing.
* Post procedures at work place, where possible.
* Provide vehicles with an accident report package including shipper 24-hour telephone number.
* Be sure that a realistic maximum allowable driving time policy is in place.
* Make sure that delivery schedules are realistic.
* Prevent unauthorized people from entering unattended facilities.
Tips for Hazmat Employees:
* Never leave transfer operation unattended.
* Do not stay in cab during loading or unloading.
References: 49 CFR Parts: 171.1; 171.16; 172 Subpart G; 172.700; 177.817; 177 Subpart B; 395; 397. A7, G1, G2, G4, G6, G11, B1.
EQUIPMENT POLICY P4
COUNTERMEASURE
Objective: To promote the availability and use of appropriate equipment by adopting a comprehensive equipment policy.
Description: Lack of proper equipment or incorrect use of equipment is a major contributor to hazardous material incidents. A strictly enforced policy ensuring the availability and correct use of equipment at all times is a step toward preventing such hazardous materials incidents.
Questions for Management:
1. Is the proper safety equipment provided where and when it is needed?
2. Are Hazmat employees trained in and familiar with the proper use of safety equipment?
3. Are appropriate and adequate tools available for all Hazmat employees?
4. Are sparking tools prohibited in areas where flammable/combustible materials are handled?
5. Is adequate protection provided for all service equipment?
6. Are hazardous materials transported and stored in tanks of suitable material which comply with
all applicable standards and regulations?
7. Is grounding and bonding equipment available where necessary?
8. Is the carrying capacity of each vehicle displayed on the vehicle?
Tips for Management:
* Review the provisions for adequate ventilation where appropriate.
* Post signs showing correct protective clothing at the work location.
* Consider the issue of repacking leaking containers and establish guidelines for doing so.
References: 49 CFR Parts: 171.1; 171.16; 172 Subpart G; 172.700; 177.817; 177 Subpart B; 395: 397. A7, G1, G2, G4, G6, G7, G11, B1.
INSPECTION POLICY P5
COUNTERMEASURE
Objective: To reduce the frequency of hazardous materials incidents by conducting thorough inspections.
Description: Improper or infrequent inspections can result in preventable hazardous materials incidents. By introducing frequent inspections of all vehicles and equipment, the safety record of the company can be greatly improved.
Questions for Management:
1. Are inspections carried out at regular intervals?
2. Are inspectors and Hazmat employees qualified to make inspections?
3. Is immediate reporting of inspection findings required?
4. Are there measurable criteria for maintenance and inspection activity?
Tips for Management:
* Document results of inspections and require signatures on forms.
* Use check lists for all inspections, but require written entries.
Tips for Hazmat Employees:
* Perform pre-trip inspections carefully.
* Be sure that safety equipment is in good working order.
* Review last vehicle inspection report (DVIR).
* Be sure that shipping papers are readily accessible.
* As part of shipping paper inspections, report to your supervisor if documentation is
incomplete, improper, or illegible.
* As part of consignment inspections, report to your supervisor if containers are damaged,
unsuitable or noncompliant.
References: 49 CFR Parts: 177 Subpart B; 180; 392.7; 392.8; 396; 396.7; 396.11; 396.13; 396.19; 396.21; 396.25. C1, C2, G1, G2, G3, G5, G14, B1, B2, B9.
DRIVER SCREENING POLICY P6
COUNTERMEASURE
Objective: To ensure that only qualified and suitable drivers are employed and retained through regular evaluations.
Description: Screening new drivers and regularly evaluating current ones are activities which ensure that fleet drivers are competent, responsible, and possess a valid CDL with a Hazmat endorsement. Many hazardous materials incidents are caused by driver error. Careful monitoring of driver performance may reduce the frequency of such occurrences.
Questions for Management:
1. What kinds of hazardous materials has each driver handled?
2. Are there tests or evaluation methods to determine the qualifications and suitability of drivers?
3. Is there a means for drivers to demonstrate performance?
4. Is there a means for drivers to mentor each other?
5. Is there a means for drivers to critique each other?
6. Are all drivers routinely evaluated?
7. Are all traffic violations, including off-duty ones, recorded?
8. Are drivers given regular medical examinations and are records retained?
Tips for Management:
* Establish standards for knowledge, skill and driving records.
* Interview drivers after any incident and implement corrective measures.
* When necessary, take disciplinary action.
* Reward a safe driving record.
References: 49 CFR Parts: 172 Subpart H; 177.804; 383.93; 391 Subpart B; 391.27; 391.31; 391.45; 391.51; 391 Subpart H. A2, G1.
PARKING AND STORAGE POLICY P7
COUNTERMEASURE
Objective: To promote the protection and security of hazardous materials cargo during parking and storage periods.
Description: The lack of security or improper storage of hazardous materials cargo may lead to leaks, fires, pilferage or vandalism. Hazardous materials are potentially dangerous to individuals and the environment, so particular care must be taken in selecting, providing, and supervising suitable storage areas.
Questions for Management:
1. Are all hazardous materials vehicles supervised when parked?
2. Is there a company policy of not leaving vehicles and trailers unattended?
3. Do storage areas provide adequate protection against physical damage and vandalism?
4. Are storage areas patrolled by security personnel?
5. Are Hazmat employees aware that flammables and explosives must not be garaged?
6. Are storage and parking areas well ventilated and free from debris and sources of ignition?
7. Is there a no-smoking policy for drivers and other personnel attending hazardous materials vehicles?
Tips for Management:
* Keep exits to storage areas clear.
* Ensure that proper access for emergency response equipment and personnel is provided.
* Ensure in-house vehicles will not damage cargo.
* Consider introducing the concept of a "safe haven" where appropriate.
Tips for Drivers:
* When leaving a vehicle in an emergency situation, leave the truck transmission in gear, apply hand brake and use wheel chocks to avoid inadvertent rolling.
References: 49 CFR Parts: 172 Subpart G; 397.5; 397.7; 397.13. B9, G2, G4, B3.
CLASSIFICATION POLICY P8
COUNTERMEASURE
Objective: To reduce the frequency of hazardous materials incidents by improving the accuracy of classification and increasing the dissemination of material characteristics information.
Description: Accurate product characteristic information, including proper classification, is essential to maintaining high safety levels in the hazardous materials transportation process. Hazmat employees who are knowledgeable about the potential hazards of a shipment are likely to perform their duties carefully, anticipating high-risk situations. A policy that actively supports proper classification of hazardous materials and the effective dissemination of product information may reduce the number and/or severity of Hazmat incidents.
Questions for Management:
* Has management committed adequate resources to develop product information literature?
* Have HM employees been adequately trained to understand product information literature?
* How are materials categorized into hazardous materials classes?
* Are hazardous materials being properly classified?
* Is there a policy promoting proper material classification?
* Is this policy accurately communicated to Hazmat employees?
* Is the necessary product characteristic information communicated to Hazmat employees?
Tips for Management:
* Develop a company attitude and philosophy of excellence.
* Educate Hazmat employees about the importance of proper classification of materials including
their responsibility to other Hazmat employees who will handle the material.
* Reduce factors which might promote short cuts and possible non-compliance; for example,
rush jobs may encourage employees to "get it out" prior to proper material classification.
* Encourage Hazmat employees to properly classify hazardous materials by using incentives.
* Establish an internal monitoring system to verify HM employees are properly classifying HM.
Tips for Hazmat Employees:
* Be familiar with hazardous materials classifications and what they mean.
* Make it a regular practice to read product information, including shipping papers, which accompany
a hazardous materials shipment.
* Ask questions when information is unclear or incomplete.
References: 49 CFR Parts: 171.2; 172 Subpart H. A3, G12, G14, B8.
MAINTENANCE POLICY P9
COUNTERMEASURE
Objective: To reduce the frequency of equipment failures or malfunctions, which are potential causes of hazardous materials incidents, by implementing an effective maintenance policy.
Description: Equipment failures and malfunctions can be both dangerous and costly to a company and its employees. The introduction of a maintenance policy can greatly reduce the potential of such occurrences taking place.
Questions for Management:
1. Is a comprehensive preventive maintenance policy in place?
2. Does the maintenance schedule include a regular cleaning and inspection schedule for
vehicles, equipment and plant facilities?
3. Are your mechanics, or any other personnel performing maintenance, properly trained?
Tips for Management:
* Missing or damaged safety equipment should be reported and replaced immediately.
* Brake failure is a common cause of truck accidents; therefore, emphasize proper brake inspection
and adjustment procedures.
References: 49 CFR Parts: 173 Subpart B; 180 Subpart E; 392.8; 396; 396.3; 396.25. C1, G1, G8, B1, B11.
EMERGENCY RESPONSE POLICY P10
COUNTERMEASURE
Objective: To respond to hazardous materials incidents quickly and appropriately by establishing a comprehensive emergency response policy.
Description: The improper handling of hazardous materials incidents can aggravate a situation resulting in higher costs and greater danger to the public and the environment. By pre-planning an emergency response procedure, the consequences of such an incident may be dramatically reduced.
Questions for Management:
1. Is there a comprehensive emergency response policy in place?
2. Are there "stop-gap" or short-term emergency fixes that could be used for certain
pre-defined situations?
Tips for Management:
* Periodically review emergency response policies in light of new technologies and techniques.
* Educate local authorities and local emergency response personnel about proper emergency
response procedures for materials being shipped.
* Establish mutual aid relationships with other companies.
* Be sure management and Hazmat employees are familiar with emergency response policies
and where to quickly find necessary information.
References: 49 CFR Parts: 172 Subpart G; 172 Subpart H. B12, G6, G13, G14, B3, B12.
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