General Hazmat Knowledge - Hazardous Material Transportation

One observation is the statement at the beginning about how most of these fines are based on undeclared shipments, which are known or not known by the consignee and resulted in incident. Another observation is that these fines are on the extreme end of the spectrum, as basic fines start at $493 per incident as a $50,000 minimum means multiple mishaps or mistakes during hazardous material handling. Of the 125 listed incidents, there were a few that were fined multiple times with similar fine amounts, as the fines are relatively small comparable to the incidents. There were multiple packaging issues that were later discovered to be leaking, which the penalty served was high comparable to the materials shipped.

76 of the 125 incidents were found from the material leaking through the container or packaging and discovered by material handlers. 79 of the 125 incidents were discovered by a ground handling employee, also noting that 9 of the 125 incidents were uncovered without the product leaking. Of the 125 incidents, 100 were discovered in the process of distribution. Further, 13 of the shipments were stated to involve undeclared Oxygen Generators, which are strictly prohibited for their byproducts, volatility, and hazards associated with rapid explosion when combined with combustibles.

108 incidents were lumped in the range of $50,000 to $100,00 with others spread sparsely between $100,000 and $1-million US dollars. An approximate fine amount when including all fines spread across $50,000 increments sits the average fine at around $85,000 for each of the 125 incidents, which helps fund hazard awareness and training opportunities to industry employees.

When searching through the company owned material incidents, it seems ignorance over the issue is apparent and lacking through the airline industry. Some of the companies such as FedEx are cautious, or so it seems, to find suspicious packages that could harm handlers or leak in transit. HAZMAT training such as general awareness and familiarization, function specific, label recognition, safety, and training records should be emphasized to train front-line material processors before material entry to the logistics system. Another critical aspect to this problem is packaging, which seems to highlight another issue of material and business integrity over hazardous material shipments. The higher fines associated within the report highlight multiple mishaps, which uncovers various problems areas that could be decreased by employee training and awareness. Specifically, one incident had 19 occasions of transporting hazardous materials on an aircraft, as the pilot was unaware of the materials onboard, which increasingly puts the passengers and crew in danger with each occasion.

The materials regulated as COMAT should only be transported by an airline that has a FAA approved Hazardous Materials/Dangerous Goods program, and without the program the airline must process its COMAT through other carriers for transport. One thing I did not know through reading the weekly material was about some of the examples of hazardous materials that already exist on aircraft such as cabin fire extinguishers, radioactive exit signs, rain repellent, first aid kits, life rafts, life vests, cargo Halon extinguishers and unpurged fuel control units. These items are all safe for transport, but must be declared, properly stowed, handled, marked, and prepped for shipment.

The training aspects of the incidents seem to draw awareness to the increase of fines over repeat findings. Increasing the fines would not correct the issue, as it may only increase the covertness of concealing the hazardous materials. Increasing the Department of Transportation’s no-notice HAZMAT inspections of processing facilities should increase awareness at the management level of logistics. Many of the incidents listed are lumped, which could highlight inspection findings and facility visits. The training material is open-source as businesses are responsible for their own employees training when dealing with potential hazardous materials, at levels equivalent to the employees’ frequency of material handling. With the no-notice inspections, the ability to revoke HAZMAT certification of processing certain types of material can affect businesses more than an imposed fine. Loss of business from decertification may increase strategic awareness through desired need maintain operations and protect corporate investments. Fines in the amount of $50,000 may not directly affect larger businesses such as Spirit Airlines and FedEx, as that $50,000 can go a long way when turned to employee training, but can be considered just the cost of business that is revealed through the mismanagement of logistics and employee training. Inspection criteria and training should spotlight packaging as a method of protection, labeling, and safety.