Page 30 - Occupational Health & Safety, March 2018

IH/HAZMAT
yet most of us never think about the work they do. Thanks to their dedication and in- depth expertise, we mostly don’t have to.
For the uninitiated, dangerous goods professionals are involved in securing, shipping, transporting, or managing dan- gerous goods, called hazardous materi- als or hazmat by the U.S. Department of Transportation (DOT). In the simplest terms, these materials come in nine hazard classes: Explosives (1), Compressed Gases (2) Flammables (3 and 4), Oxidizers and organic peroxides (5), Toxic and Infection Substances (6), Radioactives (7), Corro- sives (8), and “Miscellaneous” hazards, in- cluding lithium batteries (9).
In other words, it’s mostly stuff you can’t send through the mail. Except when you can, that is, as with limited amounts of some materials from nearly every class. Ev- ery rule has its exception; you learn this fast in the world of dangerous goods.
Some of these exceptions, such as spe- cial rules for limited quantities of hazmat and “consumer commodities,” are crucial in delivering everyday goods such as medi- cines, antifreeze, nail polish, cologne, aero- sol cans, charcoal, lighters, and much more, reliably and at a cost we can afford.
Dangerous goods management is a vo- cation in which the meaning of words mat- ters. In an era in which reality itself often seems up for debate and concrete truths are hard to come by, this is no small thing.
The day-to-day job of managing haz- ardous materials also requires and rewards an excruciating attention to detail. Hazmat exceptions and exclusions are just one ex- ample. From the required order of elements on the shipping paper to closure instruc- tions for packaging to hazard labels with strict design standards, leaving out details is something hazmat professionals will not abide. They can’t afford to.
Depending on the situation, missing a detail could lead to injured workers, a re- jected shipment, a package leaking in tran- sit, highway closures, emergency landings, response costs, future liability, civil penal- ties from U.S. DOT and other agencies, or worse. With DOT penalties for hazmat mistakes now above $78,000 per day, per violation, even small mistakes can be costly.
What’s It Take to Be
a Hazmat Professional?
First, no worker—manager or not—may
perform any function related to hazmat transport without the proper hazmat train- ing. Under U.S. DOT regulations at 49 CFR 172, Subpart H, hazmat shipping profes- sionals must complete a rigorous training program that addresses critical elements laid out by regulators. In addition, profes- sionals must complete a full review of that training at least once every three years.
Managing hazmat shipping takes the emotional muscle and managerial skills to keep warehouse shipping employees mo- tivated, on task, and working safely. DG professionals are primarily responsible for protecting the employees under their su- pervision—providing guidance and train- ing, onboarding new hires, and overseeing hazmat packaging and handling on site.
Dangerous goods professionals also have a more bookish, scholarly side. They must file timely and accurate reports to DOT and other regulatory agencies, review obtuse rulemaking documents to prepare for changes that may impact their ship- ments, and ensure that every step of the hazmat pre-transport process is done in compliance with the regulations.
That last step can entail classifying and naming the material, selecting authorized packaging, choosing the right marks and labels, preparing or certifying documenta- tion, and seeing to it that employees prop- erly carry out their responsibilities.
Last, hazmat pros need an endless re- serve of patience—the rules are complex, and even the vocabulary isn’t always reliable. “Hazardous materials” is DOT’s term. EPA’s hazardous waste program uses “hazardous waste,” other EPA programs use “hazardous substance,” and OSHA goes with “hazard- ous chemical.” All of these terms may apply to the contents of a container, sometimes all at once. And that’s to say nothing of the international requirements that global ship- pers must reckon with.
That patience is tested often. The hazmat rules are constantly under con- struction, with a new requirement or re- striction always on the horizon. Following the rulemakings through the maze of self- referential, byzantine legislative and ad- ministrative processes is a major challenge.
Where Are Tomorrow’s
Dangerous Goods Pros?
All dangerous goods professionals have one last thing in common—they’re not
getting any younger. As shipping pro- cesses and decision-making become more automated, as we look toward a future of automated vehicles and “smart” industrial equipment, we must question who, if any- one, will step up to replace today’s danger- ous goods professionals.
Many of the pros now counting down to retirement are understandably anxious about handing off the responsibility for hazmat safety—especially given the skill set and dedication needed to do the job right. When hazmat transport is not done right, the consequences can be lethal, so it’s cru- cial that organizations start recruiting and grooming the dangerous goods profession- als of the future today.
Even if businesses foresee increased re- liance on technology as a solution, teaching a software program to ship hazmat would mean not only developing a logic capable of navigating and applying the rules, but training it to bend or re-evaluate that logic when needed to solve problems the way hazmat professionals do every day. And any program or application we create to solve our problems is only as smart as those who program it.
Today’s hazmat professionals have a wealth of knowledge and expertise to im- part, but they need someone to impart it to. In recent years, hazmat industry groups have started initiatives to develop partner- ships and create new resources for those interested in entering the profession.
Moving forward, two things are cer- tain—humans will continue to need haz- ardous materials for energy, for health, for transportation, and more, and the world will need a new crop of dedicated dan- gerous goods professionals to ensure that hazmat reaches its destination, safely and on time.
Roger Marks is a researcher and writer at Lion Technology Inc., a leading provider of 49 CFR, IATA DGR, and IMDG Code dan- gerous goods training in the United States. Now in his seventh year at Lion, he creates content to inform and empower EHS profes- sionals and closely monitors developing regu- latory actions that impact hazmat shipping, hazardous waste management, environmen- tal compliance, and OSHA workplace safety. Find nationwide public workshops, 24/7 on- line training solutions, and live webinars at www.Lion.com.
24 Occupational Health & Safety | MARCH 2018
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