We called it the Case of the Curious Shipment.
Traveling deep into industrial Los Angeles on Thanksgiving Day in 2008 we hooked a 37,000 pound Hazardous Materials (HazMat) load. Paint, in 55-gallon drums, and one carton of paper towels. Yes, just one carton. All the way to Ohio we asked why. Why does someone order a 53 foot trailer load of paint and one carton of paper towels? Did someone throw it in by mistake? No, it’s listed on the Bill of Lading. Was it a bonus? A little shipper-to-receiver humor?
The case was solved during our week long training at FedEx. Since we are on the White Glove team and provide special, customized, cargo handling we received the ultra Hazardous Materials Regulations training. Violating HazMat rules is a bank breaker for a driver. The fines are humongous. Once the driver closes the door and signs the paperwork, the responsibility, and all the fines go to her. We learned some HazMat in Schneider school, they have an excellent flow chart to help with placarding requirements and took a test, which tells the government that we are qualified to handle HazMat. We had a refresher at Forward Air and took another test and were given another HazMat qualification card. But we received much more information at FedEx.
A curious thing about HazMat, while there is a thick book laying out the the rules, it’s not enough to know the rules. “HazMat is all about the exceptions,” our instructor said, bringing us back to the paper towels.
According to the rules, if more than 8,820 pounds of one commodity from one single facility is loaded onto one trailer, the trailer becomes “bulk” packaging, which has different rules than “non-bulk” packaging. Bulk packaging has several conditions but it is generally a tanker, a 53 foot trailer carrying HazMat is generally non-bulk packaging. To get around the rule that turns non-bulk packaging into bulk packaging and make the shipment exempt from bulk packaging requirements — which means it does not need the expensive placards with the commodity’s Identification Number on the placard, saving the shipper money — there must be one other commodity on the trailer, which is marked on the shipper’s bill of lading. If so, the trailer becomes non-bulk packaging and can use the cheaper, generic placards. The cost of a carton of paper towel is a fraction of the expensive labels, times four, because each side of the trailer must be placarded.
In the Case of the Curious Shipment from Los Angeles, had it only been paint on that trailer we would have been governed by bulk packaging rules for the shipment, needing four placards with the commodity’s Identification Number, UN1263. With the addition of the carton of paper towels, we became a “regular” HazMat load using the non-bulk packaging rules and the cheaper, generic Hazard Class 3 Flammable placard, white flame on red placard and a numeral 3.
I say that’s damn fine lobbying. That’s how exemptions and special industry or company specific rules are born. Corporations, representing industry, manufacturers and shippers go to their politicians, paid for handsomely with re-election donations and demand their rewards, exemptions from the Hazardous Materials Regulations or the other big regulation mazes, such as tax regulations.
Hazardous Materials are divided into nine Hazard Classes. Hazardous Materials must be clearly noted on the shipping papers, the packaging on the product and placarding on the truck. There are rules about which Hazard Classes may be shipped together. The trailer (see photo) we spied on I-20 in Texas carried Class 5.1 Oxidizing Material and Class 8 Corrosives. The commodities must be loaded so that they will not co-mingle in the event of leakage.
Hazardous materials go into many everyday items, they are a dirty, unmentionable but entirely necessary part of modern life and we are addicted to our modern life. Unfortunately rules can be avoided by the highest bidder. America has treated itself as a lone planet when it comes to Hazardous Materials — helped by effective lobbying — but we are being dragged kicking and screaming into the global marketplace where a hazardous material has one name and one marking everywhere, Europe, developing countries and the US. These commodities and components are used and transported worldwide. If safety is the goal, uniformity is the answer.
Having seen at least 100 Hazardous Materials Bills of Ladings in the past three years, we worry about the paperwork. Every company does its own shipping papers and many are barely readable.
There should be one, universal, world-wide HazMat Bill of Lading, which can be downloaded by any shipper, anywhere, Baltimore or Shanghai or Istanbul. No ambiguities. Always correct. Simply fill it in. Thanks to the World Wide Web this is easy. No questions, fewer mistakes.
There are specific requirements for HazMat Bills of Lading, so specific, even the order of the commodities description on the bills is set in stone. The US will be with the international marketplace in 2012. The soon-to-be universal order is UN (United Nations) Identification Number, the Commodity name, and if it’s a generic name, then in parentheses it needs the technical, chemical name, followed by the Hazard Class, and in parentheses a secondary class, if applicable and finally the packing group. For example, UN0007, Cartridges for Weapons, 1.2F, II (the Roman number II refers to packing groups and is always in Roman numerals) is the correct, legal description of this Hazardous Material.
Seems pretty clear, but every bill of lading is laid out a little differently, requiring us to whip out our 3-inch thick handbook on hauling Hazardous Materials to ensure everything required is listed, in the right order and that the product packaging and the placarding all match.
Thankfully, our first load was not HazMat, we want to get used to the company systems before adding complications. We deadheaded to Olive Branch, Mississippi, in a false start, to pick up a dry box trailer, it had two flat tires and a padlock on the trailer doors and took us 24 hours to get everything corrected. Waiting for our first load with the dry box, a temperature-controlled trailer came available and we were deadheaded to Louisville, Kentucky to pick it up. It was all set to go.
We’re loaded and on our way. Good thing. The wheels haven’t been turning for almost a month, it’s time to be earning.