At the end of the 2016 fiscal year (FY), unsecured packages remained the top violation of hazardous materials regulations uncovered by U.S. Department of Transportation (DOT) roadside inspections. What other violations made the top ten list? Let’s take a look and help you avoid DOT’s hazmat hit list.
 |
Don’t get caught short by a DOT roadside inspection. In the data for FY 2016, DOT’s Federal Motor Carrier Safety Administration (FMCSA) had performed 192,400 roadside inspections of trucks targeting compliance with hazardous materials transportation regulations. During these inspections, DOT inspectors found 41,175 violations. This is down slightly from the 42,592 hazmat violations uncovered in 191,268 roadside inspections in FY 2015.
The top violation DOT inspectors have found in FY 2016, as in FY 2015, is that packages are not secured in the vehicle. At 3,929 violations, this mistake accounted for almost 10% of the total violations. Following at a close second, inspectors have found 3,139 instances where there was no copy of the DOT hazmat registration number in the vehicle.
Work on Placarding
Three of the top 10 violations have to do with placarding requirements. In some cases the placards were not provided to the carrier, or the vehicle was not properly placarded, or the placards were damaged or obscured.
The DOT provides tons of information concern placarding, but it is often confusing or overly strident. For instance, the DOT deemed one scenario noncompliant when queried about having a white block in the center of a placard.
The shipper in question wanted to know if it is alright to leave a white center block on the placard that is intended for display of identification numbers blank. According to the DOT, A placard with a blank white space (i.e., white center block) is only authorized for display of identification numbers in black on a white background as stated 49 CFR 172.332(c). If a placard is not used for the display of an identification number, it must conform to the design requirements found in 49 CFR 172.519(b), which does not provide for a blank white space in the center of a placard.
Top Ten Hazmat Violations
Here’s look at the top 10 hazmat transportation violations by trucks uncovered by DOT inspectors for 2016 FY.
| Regulation | Violation Description | # of inspections | # of violations | % of total violations | |
| 1 | 49 CFR 177.834 | Package not secure in vehicle | 3,721 | 3,929 | 9.54% |
| 2 | 49 CFR 107.620 | No copy of U.S. DOT Hazardous Materials Registration number | 3,139 | 3,139 | 7.62% |
| 3 | 49 CFR 177.817 | Shipping paper accessibility | 2,174 | 2,180 | 5.29% |
| 4 | 49 CFR 172.516 | Placard damaged, deteriorated, or obscured | 2,023 | 2,164 | 5.26% |
| 5 | 49 CFR 172.504 | Vehicle not placarded as required | 2,015 | 2,078 | 5.05% |
| 6 | 49 CFR 177.817 | No shipping papers (carrier) | 2,025 | 2,070 | 5.03% |
| 7 | 49 CFR 172.502 | Failure to provide carrier required placards | 1,560 | 1,583 | 3.84% |
| 8 | 49 CFR 172.600 | Emergency response information not available | 1,109 | 1,115 | 2.71% |
| 9 | 49 CFR 172.202 | Failure to enter basic description of hazardous materials in proper sequence | 1,076 | 1,101 | 2.67% |
| 10 | 49 CFR 172.602 | Maintenance/accessibility of emergency response information | 1,090 | 1,092 | 2.65% |
Data Source: FMCSA Motor Carrier Management Information System
Double-Check Your Emergency Response Information
As mentioned, the top violation in both FY 2016 and FY 2015 was unsecured packages in vehicles. Interestingly, the violation that held the second spot in 2015 was the lack of a copy of the hazardous materials registration number.
As a matter of fact, eight of the top ten hazmat violations in FY 2015 have shown up as part of the top ten in FY 2016. However, violations related to emergency response information are creeping up there. Two that that broke into the top ten for FY 2016 have to do with emergency response information. At the end of FY 2015, emergency response information not being available ranked 11th at the as a violation, and that emergency response information was either not maintained correctly or was not accessible to the inspector ranked 18th. In FY 2016, they rank 8th and 10th, respectively. The good news is that when the emergency response information is available, it seems to be complete more often. That violation—missing emergency response information—dropped out of the top ten to 13th in 2016, where it ranked 7th in FY 2015.
Check tomorrow’s Advisor for scenarios when DOT thinks your emergency response information may not be up to snuff—an emerging concern in FY 2016.