The Quick 6

Common Citations

I recently attended a Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) workshop where they revealed some of the most common citations they find and or give out. Without reading ahead, do you think you can name them all?

The first 2 are related to one another…

1. Failure to train a hazmat employee.

This begs the question who is a hazmat employee? Any person who is employed by a hazmat employer and who in the course of employment directly affects hazardous material transportation safety. This could be Shipping personnel, receiving personnel, Hazardous waste workers, truck drivers, lab personnel, department supervisors, and Tank truck and Tank Car (loading/unloading personnel). Basically anyone that is involved with a shipment of hazardous materials needs training.

2. Failure to maintain training records.

This one is two fold. If you don’t do it in the first place, you cannot maintain something you do not have. Another common mistake is not conducting recurrent training. Recurrent training is required once every 3 years, if there is a change in job assignment, or a change in the hazardous materials regulation that relates to a function performed by a hazmat employee.

3. Packages not properly marked or labeled.

I am sure there is a multitude of different examples for this one, but a very common one is putting the wrong label on the package. This could be as simple as the wrong hazard class, the wrong color (if you are printing your own or even buying them), and the wrong size label.

4. Incorrect Shipping Papers

When filling out your shipping paper, there is required information that must be on every shipping paper. This consists of the basic description, the total amount you are shipping, number and type of packages being shipped, a signature of someone who is DOT trained, and an emergency contact phone number for someone or an entity that can be reached 24/7. If you’re missing one, some, or all of it, your shipping paper is and not correct. An easy was to remember what goes into the basic description is the Acronym ISHP which stands for Identification Number (HMT column 4), Proper Shipping Name (HMT column 2), Hazard class (HMT column 2), and Packing Group (HMT column 5).

5. Failure to Register with PHMSA

Although this may seem like a no-brainer, many offers do not realize they must register with PHMSA for one reason or another. Some it may be ignorance (because it is what they have always done) for others they may not realize what they are shipping is in fact considered hazardous materials. For whatever the reason may be, this violation is more common than you might think.

6. Lack of a Security Plan

Just having a “security plan” is not good enough nowadays. There are specific requirements that must be included in each plan. A security plans must address Personnel Security, Unauthorized Access, and En Route Security. It must also be/have:

• In writing
• Address security threats
• Detail security duties for each position or department responsible for implementing the plan
• Be revised and or updated as necessary to reflect changes
• Retained for as long as it remains effective
• Reviewed Annually
• Recent (the most recent version made available to employees)
• A Risk Assessment
• A plan for training hazmat employees in accordance with §172.704(a)(4) and (5);
• Notification for all employees of any revised or updated changes

While you may have noticed different citations being handed out, these examples came straight from the source. To help avoid these common citations and others, don’t forget to  SIGN UP for our newsletter where you will receive regulation updates, industry news, and exclusive special offers. You can also find us on Facebook, LinkedIn, and Twitter. If it’s industry leading training and compliance you want give us a call at (724) 899-4100 or visit us at learnhazmat.com and one of our team members will be waiting to help you achieve all your compliance and safety goals!