Hazardous Materials Training Course 2016 NFA Expo
The NFA is offering its annual Hazardous Materials Course again this year at our EXPO in Grand Rapids, Michigan. The course will be conducted by Tom Dunaway of Tom Dunaway and Associates, Inc. Tom retired after 34 years with the Federal Motor Carrier Safety Administration and is the architect and past trainer of most of the HM training courses both PHMSA and FMCSA require their enforcement personnel to attend.
The course will include all training requirements contained in The Department of Transportation’s Hazardous Materials Regulations.
Normally the cost of a course of this nature is between $650.00 to $1100.00 per attendee. The cost for attendance at the NFA is $150.00 which will include each attendee receiving a copy of the HM Regulation as well as additional materials. (Bring a thumb drive with you and Tom will gladly give you a copy of all of the slides he uses in his presentation).
This is a very popular course and there is limited number of slots available so act fast in order to secure a space.
You must contact Nancy Blogin soon in order to ensure a slot and to make sure enough training materials are ordered.
Both Nancy and Tom receive numerous calls each year after companies have received a visit from either The Pipeline and Hazardous Materials Safety Administration, The Federal Motor Carrier Safety Administration or in some instances, both of these agencies. By then it is too late to provide any assistance to the company. Below is a reprint of part of a DOT bulletin we published in a past Newsletter as a reminder of the importance of this training.
To: Fireworks shippers, distributors and carriers, and related industry associations
The Pipeline and Hazardous Materials Safety Administration (PHMSA), and The Federal Motor Carrier Safety Administration Agencies of the U.S. Department of Transportation (DOT), actively enforce the Hazardous Materials Regulations on Fireworks companies. They recently completed several investigations involving the transportation and storage of fireworks. These investigations identified widespread problems within the fireworks industry, including a lack of understanding of applicable Federal regulatory requirements covering hazard communication, training, and driver qualifications. Some violations and safety problems noted during these investigations include:
- No PHMSA hazardous materials (hazmat) registration,
- No hazmat placards,
- Limited/no hazmat training,
- No Commercial Drivers License (CDL) with hazmat endorsement (if placarded),
- EX approval numbers do not match devices, products, or product codes,
- Unapproved devices (no EX classification number issued for device),
- Defective package,
- Non-UN standard packaging,
In an effort to educate and increase hazmat safety awareness, this letter summarizes the regulatory requirements that apply to consumer fireworks shipments and provides a point of contact to obtain additional information.
Background Requirements governing the transportation of hazmat in commerce, including fireworks, are contained in the Hazardous Materials Regulations (HMR; 49 Code of Federal Regulations Parts 171-180). The HMR specify appropriate packaging and handling requirements for hazmat, and require a shipper to communicate the material's hazards through use of shipping papers, package marking and labeling, and vehicle placarding. The HMR also require shippers to provide emergency response information applicable to the specific hazard(s) of the material being transported. Finally, the HMR mandates training requirements for persons who prepare hazmat for shipment or who transport hazmat in commerce. The HMR also include operational requirements applicable to each mode of transportation.
Questions and Answers
Q1. What do organizations need to know about the transport of fireworks?
A1. There are a number of Federal regulations that apply to the safe transportation of hazmat. Please see HMR 49 Code of Federal Regulations Parts 171-180 for detailed information on these requirements.
Q2. Are consumer fireworks considered hazmat, and, if so, do they require special handling in transportation?
A2. Yes, DOT identifies consumer fireworks as Division 1.4G explosives, and regulates their safe transportation in commerce.
Q3. What are the regulatory requirements applicable to consumer fireworks shipments?
A3. In addition to the general and highway-specific requirements of the HMR, all shipments of Division 1.4G consumer fireworks by highway transport vehicles, including shipments from sales outlets and retail stands to/from storage areas, must conform to the following:
- Shipments must be accompanied by a shipping paper describing the explosives, including the quantity being transported (see 49 CFR Part 172, Subpart C). The Shipping Paper must include:
◦ UN ID number prescribed for the explosive materials;
◦ Proper shipping name prescribed for the explosive materials;
◦ Hazard class or division;
◦ Packing group;
◦ For Class 1 materials, the quantity must be the net explosive mass;
◦ EX number must be placed on either packaging or shipping paper;
◦ Number and type of packages must be included; and
◦ Telephone number of a contact person who can provide comprehensive emergency response information regarding the fireworks; that number must be monitored at all times the shipment is in transportation (see 49 CFR Part 172, Subpart G).
- Shipments must be accompanied by written emergency response information describing the risks associated with the shipment and immediate precautions to be taken in the event of an accident (see 49 CFR Part 172, Subpart G).
◦ EX approval number (on package or Shipping Paper),
◦ Proper shipping name (general marking),
◦ UN I.D. number,
◦ UN packaging specification marking, and
◦ Proper package labeling (49 CFR 172.411).
- Packages containing fireworks must be properly loaded, blocked, and braced to restrict movement in the vehicle, and be protected against ignition sources (see 49 CFR Part 177, Subpart B).
Q4. Are there additional requirements for transporting large quantities of consumer fireworks?
A4. Yes, for any shipment of Division 1.4G fireworks more than 1,001 lbs., gross weight, on a vehicle, the following additional requirements apply:
- Transporters/carriers must apply and hold a current hazmat registration certificate issued by PHMSA (see 49 CFR Part 107, Subpart G).
Q5. What are the potential Federal consequences for not following requirements for transporting consumer fireworks?
A5. Persons found to be in violation of the HMR may be subject to significant civil penalties, criminal fines, and imprisonment. Maximum penalties depend on several factors, including the nature and circumstances, extent and gravity, and severity of the consequences of the violation, but can range up to $110,000 per violation for a civil penalty, and $500,000 and 10 years imprisonment for a criminal penalty.