When Department of Transportation (DOT) roadside inspectors stop your truck, they may no longer be surprised to see leaking hazardous materials (hazmat)—a violation that is pushing toward the top 10 violations of hazardous materials regulations. What’s happening here? Why are hazmats leaking in trucks?
DOT’s Federal Motor Carrier Safety Administration (FMCSA) data show that from fiscal year (FY) 2014 through FY 2017, roadside inspectors are regularly finding released hazmats when stopping trucks for inspections. FY 2018 (which began October 1, 2017) is proving not to be an exception. As a matter of fact, so far in FY 2018, hazmat releases rank 12th in the list of violations uncovered by DOT roadside inspectors. The lowest it has ranked since 2014 is 15th in 2016.
These requirements against hazmat releases apply to:
- Bulk and nonbulk packagings;
- New packagings and packagings that are reused; and
- Specification and nonspecification packagings.
If you are the offeror, i.e., the one offering the hazmat for transportation, it is your responsibility to ensure that packagings are compatible with their contents. This particularly applies to corrosivity, permeability, softening, premature aging, and embrittlement.
As the offeror, you must also ensure that there will be no significant chemical or corrosive reaction between the packaging materials and contents of the package. In addition, it is up to you to make sure that plastic used in packagings and receptacles are compatible with the contents and are not permeable to an extent that a hazardous condition is likely to occur during transportation, handling, or refilling.
Four Steps to Ensure Your Hazmats Are Not Released
DOT hazmat regulations found at 49 CFR 173.24 require that you take certain preventive measures to ensure against leaking hazmats.
Step 1—Design and maintain it. Packages used for the shipment of hazmats must be designed, constructed, maintained, and closed so that there is no identifiable release of hazmats to the environment. The regulation also requires that you limit the contents of a package so that a release does not occur.
Step 2—Make sure it is tough enough. You must also make sure that the package will stand up under various conditions. For instance, such things as impact resistance, strength, and packaging compatibility must be maintained for conditions normally encountered in transportation. These conditions include:
- Minimum and maximum temperatures;
- Changes in humidity and pressure;
- Shocks; and
- Loadings and vibrations.
Step 3—Watch your mixes. Don’t mix gases or vapors in the package that could, through any credible spontaneous increase of heat or pressure, significantly reduce the effectiveness of the packaging.
Step 4—Guard against the yuck factor. Make sure there is no hazmat residue adhering to the outside of the package during transport.
Step 5—Don’t fill liquids to the brim. When filling packagings or receptacles for liquids, make sure to leave sufficient room to ensure that neither leakage nor permanent distortion of the packaging or receptacle will occur as a result of an expansion of the liquid caused by temperatures likely to be encountered during transportation.
- For nonbulk packages, liquids must not completely fill a receptacle at a temperature of 55°C (131°F) or less.
- For bulk packages, the outage must be at least 5% for materials poisonous by inhalation, or at least 1% for all other materials, of the total capacity of a cargo tank, portable tank, tank car (including dome capacity), multiunit tank car tank, or any compartment, at the following reference temperatures:
- 46°C (115°F) for a noninsulated tank;
- 43°C (110°F) for a tank car having a thermal protection system; or
- 41°C (105°F) for an insulated tank.
Is your cargo tank’s remote shutoff device marked correctly? Tune in to tomorrow’s Advisor to see what DOT roadside inspectors are finding.