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Dangerous Goods Industry Survey Identifies Compliance Challenges

Labelmaster (a U.S.-based provider of labels, packaging and technology related to the transport of dangerous goods and hazardous materials), recently announced the results of its annual 2018 Global Dangerous Goods Confidence Outlook. Sponsored by Labelmaster, International Air Transport Association (IATA), and Hazardous Cargo Bulletin, the survey was conducted to gain insight into how organizations around the globe approach dangerous goods shipping and handling, and the challenges they face.

“Shipping dangerous goods is complex and high-risk, and those responsible for compliance have an increasingly critical job,” said Rob Finn, vice president of marketing & product management at Labelmaster. “In an effort to better understand today’s dangerous goods landscape, Labelmaster, IATA and Hazardous Cargo Bulletin partnered to gather insights from dangerous goods professionals across the globe. We found that while many organizations have the necessary infrastructure, training and processes to ensure compliance across their supply chains, a large number do not.”

The survey covered personal profile information, including: respondent location, most common DG hazard class materials handled, contact role, etc.; training and DG enforcement concerns; compliance challenges; use of technology; comparison to the 2017 survey results; and other leading industry concerns.

Here are some of the key results from the survey:

Keeping up with regulations and ensuring compliance is challenging: Regulatory compliance is critical to an organization’s ability to maintain a smooth supply chain. Yet with growing volumes and types of DG, increasingly complex supply chains, and more extensive regulations, many industry professionals find it challenging to do their jobs effectively and efficiently. In fact:

  • 51 percent find it challenging to keep up with the latest regulations.
  • 15 percent were not confident that they can ensure DG regulatory compliance across their entire organization, and 13 percent were unsure.
  • 58 percent feel that even if they follow the regulations perfectly there is a chance their shipments will be stopped.

When asked to rank their greatest challenge to compliance: budget constraints (28 percent); company leadership not aware of risk (21 percent); insufficient or ineffective training (19 percent); lack of technology (17 percent); difficulty in keeping up with changing regulations (15 percent).

Compliance technology and training is often inadequate: Those responsible for DG face an uphill battle – not only in meeting evolving regulations, but also in overcoming inadequate infrastructure and training. Technology is critical to the supply chain, and significantly improves efficiency, speed, accuracy and more. And even with a number of technology resources available, 28 percent of dangerous professionals are still doing everything manually. Furthermore, 15 percent believe their company’s infrastructure ability to quickly adapt to regulatory and supply chain changes is “lagging behind the industry,” 65 percent said it is “current, but need updating” and 21 percent believe it is “advanced – ahead of the industry.”

The need for improvement extends to training as well. One-quarter of respondents feel their company’s training does not adequately prepare people within the organization to comply with dangerous shipping regulations. In many cases, the scope of employees being trained needs to be expanded. In fact, 67 percent of respondents believe dangerous goods training should be extended to other departments across their company.

An organization’s attitude towards compliance impacts its level of investment: An organization’s attitude towards dangerous goods compliance has a direct impact on how much a company invests in compliance resources. Unfortunately, their attitude towards compliance often does not reflect its true value. According to the survey:

  • 16 percent indicated that dangerous goods compliance is not a major priority for their company.
  • 54 percent wish their companies would understand that supply chain and dangerous shipping management could be a differentiator.
  • 27 percent think their company’s investment to support dangerous goods compliance is “not adequate to meet current needs.”
  • 28 percent believe their company complies “only because regulations mandate it, and adhere to minimum requirements,” while 48 percent believe their company “goes beyond requirements,” and 23 percent view compliance as a “competitive advantage.”

    Which Type of Technology Companies Use to Ship Dangerous Goods

Dangerous goods professionals desire additional support: Investment in infrastructure and training is critical to enabling DG professionals to do their jobs effectively and efficiently, and whether their budgets have increased, decreased or stayed the same, DG professionals desire additional support. When asked how they would prioritize financial support from their organization: more effective training (42 percent); technology for better supply chain efficiency and compliance (29 percent); wider access to the latest regulatory resources and manuals (18 percent); additional headcount (12 percent).

Finn added, “The risk associated with shipping and handling dangerous goods is greater than ever and industry professionals responsible for managing it need the proper technology, training and regulatory access to ensure they are moving goods in a secure, safe, compliant and efficient manner. Unfortunately, obtaining the necessary budget and resources likely requires buy-in from executive leadership, which can be an uphill battle. So how do you get that buy-in? It starts with changing the conversation around dangerous goods management.”

Changing the Conversation with Senior Leadership

Changing the conversation means reframing the overall view of dangerous goods management within an organization. This begins with dangerous goods professionals quantitatively demonstrating how their compliance program can reduce costs and increase revenue to make a positive contribution to the company’s bottom line. Simply put, it is defining your company’s “total value of compliance,” which takes into account three factors:

  • The cost of maintaining compliance throughout the supply chain, such as expenses for people, compliance products, software & technology, reporting, training, etc.
  • The cost of non-compliance due to errors and lapses, such as penalties, carrier refusal and delays, fines, remediation, higher insurance costs, etc.
  • The opportunities of higher level compliance-enabling differentiation, revenue growth and faster cash flows, such as faster product deliveries, increased brand equity, the ability to offer a wider range of products, etc.

This Total Value of Compliance (TVC) framework helps dangerous goods  companies make compliance a powerful, revenue-positive aspect of their business. To learn more about the total value of compliance, download a TVC technical brief and schedule a free assessment, visit www.labelmaster.com/tvc.

To read the full report, visit www.labelmaster.com/dg-compliance-outlook.

About Labelmaster

Labelmaster helps companies navigate and comply with the regulations that govern the transport of dangerous goods and hazardous materials. From hazmat labels and UN certified packaging, hazmat placards and regulatory publications, to advanced technology and regulatory training, Labelmaster’s comprehensive offering of i software, products, and services help customers remain compliant with all dangerous goods regulations, mitigate risk and maintain smooth, safe operations.  To learn more, visit www.labelmaster.com.

 

Hazmat University launches Hazardous Material Online Training

The U.S. Department of Transportation requires anyone whose job involves the performance of any task regulated by the U.S. Hazardous Materials Regulations to undergo hazardous materials shipping training. Likewise, all employers must provide their employees with relevant training applicable to their job function. Hazmat University offers online training programs that can be completed on your desktop, laptop, tablet, or smartphone 24/7.

“When transporting hazardous materials/dangerous goods in commerce, compliance is a primary concern. Compliance is achieved through well maintained training programs by the hazmat employer. Training is an essential component of any shipping operation to achieve safety in the transport of hazardous materials,” said Sonia Irusta, Vice President of Bureau of Dangerous Goods, LTD.

Hazmat University recognizes the need for anyone entrusted with the handling of dangerous goods to be trained on the dangerous goods regulations and to be able to perform their job functions when handling dangerous goods.

Hazmat University makes certain their training programs are exemplary and features are excellent and easy to access. Listed below are the four reasons Hazmat University is your one-stop-shop for hazardous material shipping training.

A Variety of Training Options

  • A wide range of classes that suit a variety of needs such as different modes of transportation including ground, air and sea.
  • Classes cover a wide range of regulations including: 49 CFR Hazardous Materials Regulations, the International Air Transport Association Dangerous Goods Regulations, and the International Maritime Dangerous Goods Code.

Regular Updates

  • Hazmat University updates based on “The Hazardous Materials Regulations” multiple times each year which keeps lesson plans and materials for online content up-to-date.
  • Anyone handling hazardous materials is required stay on top of any amendments and regulatory changes made.

Everything is Online

  • All courses are offered online to relieve the stresses of travel, parking and changing schedules.
  • Lessons can be accessed from anywhere at any time whether at home or in the office.

Start Immediately

  • Begin your training from the moment that you finish placing your order.
  • Your enrollment codes come with your order confirmation, so there is no delay in getting started.
  • Certificates are issued instantly upon completion.

Hazmat University provides specialized courses in the transportation of dangerous goods by air, ground, or vessel, and training for specialized needs, such as lithium batteries, general awareness, segregation, and others.

How to Document Weights on Dangerous Goods/HazMat Transport Paperwork

International Air Transport Association (IATA), International Maritime Organization (IMO), Tile 49 of the U.S. Code of Federal Regulations (49 CFR), & Transportation of Dangerous Goods (TDG) Documentation

No one wants to talk about their weight. Ever. In the world of transport though, you have no choice. You are required to list on your transport paperwork some sort of weight, mass, or volume. The trick is to know which regulation requires what. Should be the net weight or gross weight? Is it per package or per packaging? Sadly, depending on the regulation, the answers to those questions may differ.

Before getting started, be sure you understand what all of those terms mean. I tend to default to the IATA regulations when it comes to definitions. These are found in Appendix A. Take note that these terms are also defined in the other regulations, too. In 49 CFR check in §171.9. For IMDG they are in 2 places – Volume 1, Chapter 1.2 and Volume 2, Appendix B. TDG defines them Part 1.4.

Definitions:

Package

The complete product of the packing operation consisting of the packaging and the contents prepared for transport.

Packaging

A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.

Means of containment

The road or railway vehicle, aircraft, vessel, pipeline or any other contrivance that is or may be used to transport persons or goods.

Net quantity (or weight)

The weight or volume of the dangerous goods contained in a package excluding the weight or volume of any packaging material; or the weight of an unpackaged article of dangerous goods (e.g. UN3166).

Gross weight (or gross mass)

The weight of a packaging plus the weight of its contents.

Now that we know or remember those specific terms, let’s see what each regulation has to say in regards to the paperwork. These are known as shipper’s declarations, dangerous goods form, shipping papers, or a transport document.

IATA – Section 8 Documentation:

For this regulation, a shipper needs to review §8.1.6.9.2. In particular, Step 6 paragraph (a) provides the information we need for our shipper’s declaration.  You are required to list the net quantity of dangerous goods in each package (by volume or weight as appropriate) for each item of dangerous goods that has a different UN/ID number, shipping name or packing group along with the appropriate units of measure.  Since this is an international regulation, those units must be in metric.

IATA does one step further. Certain entries of the Dangerous Goods List in the column for the maximum net quantity per package there will be the inclusion of the “G”. For example, look at ID8000 for Consumer Commodity or certain limited quantity listings. This “G” indicates the shipper must give the gross weight of each package. To avoid confusion for the carriers this “G” must also be included after the unit of measure.

IMDG – Chapter 5.4

Under IMDG, the weight description needed is in §5.4.1.5.1.  Here it says, the total quantity of dangerous goods covered by the description (by volume or mass as appropriate) for each item bearing a different proper shipping name, UN number or packing group shall be included. At the end of that section is the notation to specific the unit of measure and that abbreviations for those may be used.   Again, this is an international regulation, so the units must be metric.

Take note, the use of the word “shall” is a mandatory requirement.

49 CFR – §172.200 Subpart C for Shipping Papers:

In 49 CFR, or as most of us call it DOT, a shipper needs to read §172.202 paragraph (a) subparagraph (5) closely. Here you see the total quantity of the hazardous materials must be indicated (by mass or volume) and it must include an indication of the applicable unit of measure on a shipping paper. Interestingly enough, §171.10 says the unit of measure is to be compatible with international standards which is metric.

49 CFR lists the “customary” units in parentheses throughout but they are not the regulatory standard. We all know the US has yet to convert fully to the metric system. However, it is a good idea to make the changeover now when it comes to our hazardous materials’ shipping papers.

TDG – Part 3 Documentation:

Here a consignor (shipper) is in a unique situation.  Section 3.5 (1)(d) simply tells a consignor that for each shipping name, the quantity of dangerous goods and the unit of measure used to express the quantity must be on a shipping document.  It does go on to say the units used must be metric.  There is not a differentiation between net and gross mass for Canadian transport.

Keeping all of these requirements straight as a shipper making shipments via ground, air, ocean and between the US and Canada can be difficult. Notice I’ve included nothing about how explosives should be listed. They have their own set of rules in each regulation. Hopefully, this blog will clarify one part of your role as a shipper. If you ever have questions or find your self in need of training, reach to us today.

 

The article was first published on the Compliance Center website.

About the Author

Paula Reavis has the following degrees: BS in Science Education, BA in Chemistry, MA in School Counseling Certification.  She is also a National Certified Counselor.  Ms. Reavis has a teaching background and several years of experience in Hazard Communications. She is knowledgeable in HazCom2012, WHMIS (old/new), 49 CFR, IATA, IMDG and TDG. She started with the the Compliance Center in 2014, and is currently the Trainer. She is active in several associations including NACD, IHMM and SCHC where she served as chair of the Membership and Awards Committee. She is based in St. Louis, Missouri.