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ABF | Haz mat problems

ABFer said:
For some reason I always thought that the responsibility for changing of the placards laid on those who load/unload the hazardous freight and that it is the driver's job to confirm that they are correct based on the paperwork that they are given.
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You are correct.
 
ABFer said:
I once was handed a HAZ-MAT load with no placards and when I asked about it I was told, "It hasn't been billed yet", and that is why it wasn't placarded. That excuse might work for them but it's a no go for me as the one who has to pull it down the road.
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How simple would it be to write some code so billing never enter in to the picture? Can you see the lawyer for ABF telling a Jury we don't placard until we bill it. 5 million for the Plaintiff you Honor. Stupid is as stupid does. von.
 
vongrimmenstein said:
DOT says the minute the trailer reaches the amount of weight needed to generate placards they must be applied...
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I respectfully disagree. The DOT has no skin in the game till it is on a public street. A trailer being loaded is an extension of the dock as per OSHA. What you are saying is that one minute the dockman would have put a Dangerous flag on it, the next add a Flammable. This game could change several times.

I sort of surprised, well not really, that the hazmat placarding is such a problem at the major LTL's. We constantly had that problem at Oak Harbor till someone decided to take a nap before the truck stopped and he had un-manifested hazmat on. That and several spills on the dock, one with injuries, couple of leakers in the yard that were not placarded, some big fines and court fees (because they always knew the law, LOL) did they get a halfway grip on the problem.
 
Regardless of what company policy is, ultimately it is the drivers responsibility to be sure that the truck is safe to drive and is placarded properly. Shippers responsibility to provide the paperwork . Meaning having a decent working knowledge of the regs. Just having the Emergency Response Guide Book is worthless if one does not know how to use it
 
Who Cares said:
I respectfully disagree. The DOT has no skin in the game till it is on a public street. A trailer being loaded is an extension of the dock as per OSHA. What you are saying is that one minute the dockman would have put a Dangerous flag on it, the next add a Flammable. This game could change several times.

I sort of surprised, well not really, that the hazmat placarding is such a problem at the major LTL's. We constantly had that problem at Oak Harbor till someone decided to take a nap before the truck stopped and he had un-manifested hazmat on. That and several spills on the dock, one with injuries, couple of leakers in the yard that were not placarded, some big fines and court fees (because they always knew the law, LOL) did they get a halfway grip on the problem.
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You are correct; OSHA is the Agency on enforcement. I disagree about on the street statement. ABC company that fills containers big & small of hazardous gases & chemicals loads them on to their delivery trailer, stages them in the yard, for future delivery I have seen placards on them when parked. If OSHA is the Agency enforcing the reg’s on the private property, I am willing to bet that the placards for a trailer must be applied or removed as required by the reg’s as the weight of the Hazardous Materials change in the yard or @ the dock. I don’t know the regs on this subject any more than the next person, but was told by ABF Safety years ago this was required when loading or unloading as needed. Example, we would load a trap 53’ trailer for XP fill it, & drag it out on to a public street for about 30 yards then put it in the dock across the fence line for the XP run that night. At no time did that trailer with different shipments of Haz Mat exceeding 2000 lbs ever have placards. Now I will be the first to say that is nit picking, but there was a DOT violation. As to OSHA you would be hard pressed to convince me that OSHA would state you could have a trailer sitting in the yard with Dangerous or Radioactive material on board a trailer & no placards are required. If they are required, then being an extension of the dock has no bearing. If it is in the trailer with Haz Mat 2000 lb or more then it must have the proper placards, regardless where it sits. And yes I know we don’t haul Radioactive Materials. Von.
 
I agree with what you guys are saying, but some Hazmat Mat. require placards no matter the weight even in small amounts. Yes if the trailer is at the dock it is an extension of the dock but once moved it has to be placarded if required by weight or class on some certain materials.

Placard Requirements:There are nine classes of Hazardous Materials. Vehicles transporting any quantity of explosives (1.1, 1.2, 1.3), Poison Gas, Dangerous When Wet, Organic Peroxide, Poison Inhalation Hazard or Radioactive Materials require placarding for even trace amounts. Vehicles transporting Other Explosives, Flamable Gas, Non-flammable Gas, Combustible, Flammable Solid, Spontaneously Combustible, Oxidizer, Organic Peroxide, Poison, Keep Away from Food or Corrosives require placards when transporting over 1,000 lbs. of the substance.

http://www.ai.fmcsa.dot.gov/DataQuality/CrashCollectionTraining/lesson5/requirements.html
 
vongrimmenstein said:
You are correct; OSHA is the Agency on enforcement. I disagree about on the street statement. ABC company that fills containers big & small of hazardous gases & chemicals loads them on to their delivery trailer, stages them in the yard, for future delivery I have seen placards on them when parked. If OSHA is the Agency enforcing the reg’s on the private property, I am willing to bet that the placards for a trailer must be applied or removed as required by the reg’s as the weight of the Hazardous Materials change in the yard or @ the dock. I don’t know the regs on this subject any more than the next person, but was told by ABF Safety years ago this was required when loading or unloading as needed. Example, we would load a trap 53’ trailer for XP fill it, & drag it out on to a public street for about 30 yards then put it in the dock across the fence line for the XP run that night. At no time did that trailer with different shipments of Haz Mat exceeding 2000 lbs ever have placards. Now I will be the first to say that is nit picking, but there was a DOT violation. As to OSHA you would be hard pressed to convince me that OSHA would state you could have a trailer sitting in the yard with Dangerous or Radioactive material on board a trailer & no placards are required. If they are required, then being an extension of the dock has no bearing. If it is in the trailer with Haz Mat 2000 lb or more then it must have the proper placards, regardless where it sits. And yes I know we don’t haul Radioactive Materials. Von.
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Another reason Von as to placarding the trailer while in the dock loading is to warn the fire dept or emergency personnel. Say there is a fire in a trailer that has no hazmat on board but is loading in the dock next to one that has oxidizers loaded on it and the firemen get there and are trying to put out that fire, and it causes the unplacarded trailer to start burning or explodes. (Oxidizers intensifies fires) the placards would have warned the responders to that possibility also, so they know which way to try to extinguish the fire. You can bet if an unplacarded trailer were to explode and injure a firefighter, it will hit the fan then!
 
Can't say for sure. But I believe the terminal is considerd a Safe Haven. Dont believe the correct placards are required in the yards. Smart to have them, sure. Required, dont think so. And using the trailer as an extension of the dock, why is the building not placarded then?
 
A lot of good comments. I will try this week & talk with the OSHA & DOT offices here in Indy & see if they can show me just what the regs are about placarding @ the Terminal. Even thought I am retired maybe I can get an answer from someone in Safety @ the fort. But to me, I think applying placards @ the dock would be a smart company decision. In a serious fire having trailers @ the dock telling the first responders what kind of Haz Mat they contain could save money & lives. In a true emergency the spotters would know what to drag away from the flames to protect lives & property. If you have loaded trailers with Haz Mat material on board how would know which trailer to pull? Think of a load of propane tanks like we use on the forklifts in a trailer about to be engulfed in fire. Smart thinking says ID the trailer. von.
 
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I recall reading somewhere that placards go on when the trailer is loaded and off when it is unloaded, never seen it in practice though and that includes me.
 
From the Department Of Labor OSHA Administration. The below is still the law today.

SUPPLEMENTARY INFORMATION: Public Law 101-615, the Hazardous Materials Transportation Uniform Safety Act of 1990 (HMTUSA), 104 Stat. 3244, was enacted by Congress on November 17, 1990. Section 29 of HMTUSA reads as follows:

Not later than 18 months after the date of enactment of this Act, the Secretary of Labor, in consultation with the Secretary of Transportation and the Secretary of the Treasury, shall issue under section 6(b) of the Occupational Safety and Health Act of 1970 (29 U.S.C. 655(b)) standards requiring any employer who receives a package, container, motor vehicle, rail freight car, aircraft, or vessel which contains a hazardous material and which is required to be marked, placarded, or labeled in accordance with regulations issued under the Hazardous Materials Transportation Act to retain the markings, placards, and labels, and any other information as may be required by such regulations on the package, container, motor vehicle, rail freight car, aircraft, or vessel, until the hazardous materials have been removed therefrom.

The Congressional rationale for this requirement was provided in Senate Report No. 101-449, (p. 16), as follows:

In November 1988, six Kansas City firemen were killed when the arson-caused fire they were fighting caused the violent explosion of an unmarked truck-trailer parked at a highway construction site. Because the trailer's hazardous materials placards had been removed, the firemen were unaware of the danger it posed. The Secretaries of Labor, Transportation and the Treasury should cooperate in order to ensure that placards and labels required on hazardous materials and explosives, both in transportation and at stationary facilities, be retained until such materials have been removed to the extent that they no longer pose a safety risk.

The sentence that says 'that placards and labels required on hazardous materials and explosives, both in transportation and at stationary facilities, be retained until such materials have been removed to the extent that they no longer pose a safety risk' to me means the placards must be applied or removed @ the dock as the Hazardous Material is added or removed from the trailer.

No doubt a pain in the but. Anyone know of any terminal in the system that follows this regulation? von.
 
ABFer said:
I recall reading somewhere that placards go on when the trailer is loaded and off when it is unloaded, never seen it in practice though and that includes me.
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I never did switch them when I should have. Mentioned it several times to the boss, but gave up, nobody cared.
 
We placard at ours when the trailer is pulled away from the dock, or when the set is hooked in the yard. If the placards are the removal type they are taken off of the empty and put on the loaded trailer. Sometimes there are some who slip past. Placards are supposed to be removed from empties at the dock, but does not happen all the time.
 
truxforever said:
We placard at ours when the trailer is pulled away from the dock, or when the set is hooked in the yard. If the placards are the removal type they are taken off of the empty and put on the loaded trailer. Sometimes there are some who slip past. Placards are supposed to be removed from empties at the dock, but does not happen all the time.
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Pretty much what happens @ 050.
 
truxforever said:
We placard at ours when the trailer is pulled away from the dock, or when the set is hooked in the yard. If the placards are the removal type they are taken off of the empty and put on the loaded trailer. Sometimes there are some who slip past. Placards are supposed to be removed from empties at the dock, but does not happen all the time.
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Scraping placards off a rental trailer in the cold dead of winter is like sunbathing on the beach, can't get enough of it. von.
 
vongrimmenstein said:
Scraping placards off a rental trailer in the cold dead of winter is like sunbathing on the beach, can't get enough of it. von.
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Didn't anyone ever teach you the trick to that? If you spray the placard with ether (not a whole lot) and light it, it burns off fast and the placards peel off like a fresh new roll of electrical tape.
 
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