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:
-
Is
minimum-risk routing and scheduling employed?
-
Is a
realistic amount of time allowed for loading and unloading?
-
Are
deliveries scheduled so that shipments are unloaded shortly after
arriving at their destinations?
-
Are hazardous
materials shipping routes reviewed regularly?
-
Are
maintenance facilities, rest areas, and pull-off and turn-around
locations marked on route maps?
-
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:
-
Are there
materials and/or facilities available for drivers to demonstrate
their skills?
-
Is there a
driver safety program in operation?
-
Is there a
risk management program in operation?
-
Are employees
trained in and aware of the properties of hazardous materials
being handled or carried?
-
Are employees
trained in correct tool and equipment usage?
-
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:
-
How does
management demonstrate its commitment to safety?
-
Is there a
safety program in operation?
-
Is there an
identifiable supervisor?
-
Is there a
policy regarding driver and fleet supervision?
-
Are loading
and unloading operations adequately supervised?
-
How does
management address comments or complaints from employees,
customers and the public?
-
Does
management support Hazmat employees who question improperly
packaged or labeled cargo?
-
Are Hazmat
employees provided with written, load-specific emergency
instructions?
-
Are vehicles
equipped with Emergency Response Guidebooks and do drivers
understand how to use it?
-
Is the Hazmat
at such a level as to require notification of local authorities
and contingency planning?
-
Is
notification of shipments required in writing?
-
Is there a
process in place for anticipating late deliveries due to
circumstances such as bad weather?
-
How are
missed or late deliveries handled?
-
Are duty
hours properly recorded?
-
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:
-
Is the proper
safety equipment provided where and when it is needed?
-
Are Hazmat
employees trained in and familiar with the proper use of safety
equipment?
-
Are
appropriate and adequate tools available for all Hazmat employees?
-
Are sparking
tools prohibited in areas where flammable/combustible materials
are handled?
-
Is adequate
protection provided for all service equipment?
-
Are hazardous
materials transported and stored in tanks of suitable material
which comply with all applicable standards and regulations?
-
Is grounding
and bonding equipment available where necessary?
-
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:
-
Are
inspections carried out at regular intervals?
-
Are
inspectors and Hazmat employees qualified to make inspections?
-
Is immediate
reporting of inspection findings required?
-
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:
-
What kinds of
hazardous materials has each driver handled?
-
Are there
tests or evaluation methods to determine the qualifications and
suitability of drivers?
-
Is there a
means for drivers to demonstrate performance?
-
Is there a
means for drivers to mentor each other?
-
Is there a
means for drivers to critique each other?
-
Are all
drivers routinely evaluated?
-
Are all
traffic violations, including off-duty ones, recorded?
-
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:
-
Are all
hazardous materials vehicles supervised when parked?
-
Is there a
company policy of not leaving vehicles and trailers unattended?
-
Do storage
areas provide adequate protection against physical damage and
vandalism?
-
Are storage
areas patrolled by security personnel?
-
Are Hazmat
employees aware that flammables and explosives must not be
garaged?
-
Are storage
and parking areas well ventilated and free from debris and sources
of ignition?
-
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:
-
Is a
comprehensive preventive maintenance policy in place?
-
Does the
maintenance schedule include a regular cleaning and inspection
schedule for vehicles, equipment and plant facilities?
-
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:
-
Is there a
comprehensive emergency response policy in place?
-
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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