A Little Learning Is Not Hazardous
Recently, I read
that eucalyptus oil and grapefruit peel oil were among several hazardous
materials that, because of improper handling, brought action against shipping
companies from the Federal Aviation Agency (FAA).
More specifically,
under Title 49 of the Code of Federal Regulations, the folks shipping the
eucalyptus oil were fined $59,500. I’m sure the corporate managers were
screaming, “You clipped us!”
And the company
shipping the grapefruit peel oil had a bitter taste in its mouth after
swallowing a fine of $57,000.
Another company
shipped four, one-pint plastic containers of rubbing alcohol and the FAA
massaged $60,000 out of its hide, plus $82,500 for two, one-pint plastic
bottles of denatured alcohol. Ouch, that stings.
This information
came to me via Roy Marshall, an expert on shipping hazardous material and
president of HazardousMaterials.com. The point he is trying to make is that
businesses unknowingly ship hazardous material all the time. And you
don’t have to ship large quantities to have fines levied.
I took a look at
the Department of Transportation (DOT) Web site, hazmat.dot.gov. It’s not
surprising to learn that human error is most often responsible for careless
shipping of hazardous material. According to DOT, there are more than 800,000
shipments of hazardous material daily in the U.S. While the DOT cites human
error as the primary cause for hazardous-material-related accidents, it appears
that a lack of training
for employees working with these materials is responsible in about one-third of
the incidents.
Maybe it’s a
matter of semantics, but I think that saying there is a training issue here is
not the right approach. Training is for dogs. Education is for people.
Education appears to be lacking in the handling, labeling and transporting of
hazardous material. The DOT regulations clearly require certified training (its
word) for employees involved with hazardous material. Here’s the tough
part: DOT also requires that employees must “comprehend and be able to
apply the regulations when preparing, handling or transporting hazardous
material.”
In the Proposed
Hazmat Transportation Safety Reauthorization Act of 2001, sent to Congress
October 10, 2001, Transportation Secretary Norman Mineta proposed various enhancements
to hazardous material transportation safety, and called for an increase in
civil penalty fines from $27,500 to $100,000 per violation. All well and good
— but after-the-fact. As I read (or waded through) the law, a
redesignated subsection ([b] [2] of section 5115) would “authorize use of
$200,000 in fiscal year 2002 and such amounts as are necessary in fiscal years
2003 through 2007, from the Emergency Preparedness Fund account,” to
carry out a training curriculum. Again, by my reading, this fund authorizes the
secretary to spend “not more than $21,217,000 for FY 2002 to carry out
federal hazmat law.”
There is also
indicated the use (in 2002) of $5 million for planning grants and another
$7,800,000 for training grants, along with $150,000 for monitoring and
technical assistance. And toss in a half-million bucks to publish the Emergency
Response Guidebook —
assuming anyone will read it.
It seems to me that
education is getting the pointy end of the stick here. Doesn’t it make
more sense (or is that cents?) to spend more of our tax dollars on educating
employees so they can understand the complexities and urgency of dealing with
hazardous material?
Probably no amount
of education could have stopped the mental giant who, in November 2000, mailed
a motorcycle gas tank, loaded with three gallons of gasoline, from a repair
shop in Arizona, to Portland, Oregon. Nor would it have prevented the guy who
last year packed and shipped mercury in a soup can sealed with duct tape.
However, authorizing a few million more of those dollars designated for
clean-up toward education might help in the future.
Save your company
money — whether you ship perfume or fertilizer, both considered hazardous
material — and do some educating. If you want to read scary stories, visit
hazmat.dot.gov. If you want education, visit hazardousmaterials.com.
Clyde E. Witt, executive editor, cwitt@penton.com