Who Needs a HAZMAT Safety and Security Plan
Companies who produce, distribute, sell or recycle hazmat must have strict internal operations and security plans, that ensure safe processing and handling of all chemicals – they must also arrange for safe transportation of their chemical components. This often requires the assistance of a 3rd party transportation provider, who has their own transportation restrictions. When combined with the compliance requirements set forth by the DOT, a detailed hazmat safety and security plan must be in place. This plan must include a facility safety and security plan, and a transportation safety and security plan. Even if you provide your own transportation, you must establish a safe, responsible and compliant plan.
You Are Responsible for Your Products
Hazardous materials are required across multiple industries, well beyond that of oil refining or bio-hazardous materials. Even if produced in small quantities, they are often transported in large quantities that if not packaged, labeled, and in full compliance with both industry and federal rules and regulations – it can at best lead to costly fines, and at worst result in health and safety risks for those transporting your goods, as well as the nearby wildlife and communities who suffer from the hazardous material spill or security breach.
While the transportation provider that you select is responsible to some extent, it is irresponsible to believe that what happens after your materials leave the warehouse is solely up to them. Even if you are responsible for your own transportation, you must be in full compliance.
The DOT is Strict
Rightfully so, the Department of Transportation has strict rules and regulations. These regulations apply to the transportation of hazardous materials in commerce and their offering to:
- Interstate, intrastate and foreign carriers by rail car, aircraft, motor vehicle and vessel
- The representation that a hazardous material is present in a package, container, rail car, aircraft, motor vehicle or vessel
- The manufacture, fabrication, marking, maintenance, reconditioning, repairing or testing of a package or container which is represented, marked, certified or sold for use in the transportation of hazardous materials (49 CFR 171.1(a))
The Regulations Are Always Changing
Regulations are always changing, making it difficult for even the most well-intended business owners to remain current and pass inspection. As a result, costly fines and warnings are incurred, which could be easily avoided if a more proactive approach is established. While employee and public safety is of course the primary concern, these fines can be steep – even detrimental to your business. Even if you can absorb the fines, you may not be able to absorb the costs associated with your soiled public image.
If your hazardous materials are transported by ship, rail, air, or road – you are responsible for compliance with the strict and ever-changing safety and security plans. You are also responsible for:
- Chemical Inventory
- Emergency response training and drills
- Vulnerability studies
- Carrier management systems
- Plant accountability systems
- Proper packaging and labeling
- Document retention
- And more
What is a Safety and Security Plan
A hazmat safety and security plan establishes systems and protocols that are, at a minimum, in full compliance with all industry and government rules and regulations. It must incorporate your transportation security plan, as well as your facility security plan – and a safety plan for each. This includes daily operations, logistics, and distribution. Regulations vary by industry, as well as by the type of hazardous material produced. The goal is to avoid costly mistakes, security breach and potentially life-threatening accidents.
While safety and security plans have common denominators, they must always be fully customized to each company. In fact, you may have multiple hazardous materials or projects that require varying levels of compliance. There must also be a plan in place for auditing, maintaining compliance, and ensuring that all data is correctly filed and retained.
Outsourcing Hazmat Plans
Many companies choose to outsource some or all aspects of their facility and transportation security and safety plans. By working directly with a dedicated agency that specializes in chemical compliance, many times, cost and life-saving protocols are put in place. These agencies do not work from afar, but require direct access to your facility – to test and audit your systems firsthand. They can handle everything from establishing initial operations, ongoing compliance, hazmat training, data management, compliance audits, packaging, labeling, and shipping. They will also keep you apprised of any compliance changes, as well as how your compliance will evolve as your business expands.
Don’t think of your hazmat compliance regulations as a hassle or stressor, but instead as a responsible away for maintaining safety and integrity. Businesses who successfully manage and transport their hazardous materials gain industry respect – which almost always coincides with longevity and success. Remember that as your products or services evolve, your compliance systems will need to do the same. Make sure you stay on top of the latest hazmat compliance regulations and reach out to Transportation Compliance Associates today.