Regulating The Transportation Of Hazardous Materials

We learn about the placarding system used for identifying hazardous materials beginning with our first hazmat awareness class. Recognizing hazmat placards is a key element of emergency response. These placards have proven their value on innumerable occasions when responders have been confronted with actual or potential releases.

This identification system is just one of many benefits we gain from the Federal Hazardous Materials Regulations. These regulations are issued by the U.S. Department of Transportation (DOT) to govern hazardous materials transportation in each mode of transport - highway, rail, air, marine and pipeline. These regulations are one part of the complex federal laws and rules that control the storage, use and transportation of hazardous materials.

Over the past two decades, Congress has enacted a series of laws designed to provide adequate protection against the risks inherent in their use. Often, these have been enacted in response to disasters such as the Bhopal, India, chemical plant leak or the Exxon Valdez oil spill. The regulations issued by the DOT and other agencies implement these laws.

This inherent danger has led to tight regulation over every aspect of hazardous materials use. This includes industrial/ workplace usage, transportation, hazardous waste disposal sites and emergency response. The laws create programs that assist the fire service and other public safety agencies in dealing with hazmat releases. They determine what materials are considered hazardous. They establish requirements for safe packaging, clear identification and labeling, and operational rules, such as routing restrictions for trucks carrying hazardous materials. Further, there are federal training requirements, for both emergency services personnel and industrial workers who use hazardous materials.

Last June, a truck carrying explosive black powder overturned at the Springfield interchange of I-495, the Capitol Beltway, in Fairfax, VA. Fairfax County firefighters and others faced an extremely dangerous situation. It was 18 hours before the busy commuter highway was reopened. But the incident's safe resolution came about in part because of the many regulatory requirements in place at the time.

It is important to know what the rules require so that we can know what to expect when on the scene of an incident involving hazardous materials. The DOT rules apply to each person who performs any function related to the transportation of hazardous materials. In general, they prescribe requirements for five major areas: training, classification and identification, packaging, hazard communication and incident reporting.

Training. Each employee working with hazardous materials must be provided initial training and retrained periodically. The training must include: general awareness/familiarization; training that relates to the employee's specific responsibilities; and safety training concerning emergency responses and how to avoid accidents.

Effective training reduces the potential for incidents and accidents and is essential for the protection of people (employees, passengers, emergency response personnel and the public), property, and the environment. A well-trained truck driver can be one of our most valuable resources at the scene of an accident. This part of the rules has had a great effect on the fire service. It has led to the hazmat awareness training that is now (or should be) a part of all firefighters' initial and recurrent training.

Classification and identification of hazardous materials. The rules set out criteria for determining the hazard class and shipping name for each hazardous material. There is a list of several thousand commonly transported hazardous materials that serves as a guide to regulatory requirements and a basis for determining the proper emergency response.

Tens of thousands of other materials that pose similar hazards are addressed by generic descriptions like "flammable liquids, n.o.s." ("n.o.s." means not otherwise specified). This may seem irrelevant, but it is quite important to the fire service. Classification and identification decisions serve as the basis for determining how we handle a particular material.

Protective packaging. The packaging required for hazardous materials is the first line of defense in assuring that they are not released. There are various performance levels for packaging, based on the type of hazards posed by the specific material. All packaging must be designed to ensure that under normal conditions there will be no release of the contents.

Hazard communication. This is the source of the placarding system. Essential hazard warning information must be communicated through shipping documents, package markings, labels and placards on vehicles. These markings are critical for the fire service in identifying and addressing the hazards it confronts at incidents. Emergency response information and an emergency response telephone number must be provided. Package markings and labels convey additional information, such as the proper shipping name, identification number and hazard class of a material. This information readily identifies a package that contains a hazardous material. Also, the information provided by package markings and hazard warning labels can be used by emergency responders when shipping papers are not immediately available.

Hazmat markings must be durable, in English, and not obscured by other information appearing on the package. Labels must conform to size and color specifications, be placed on the package near the marked proper shipping name and be clearly visible.

Incident reporting. Carriers must report to the Research and Special Programs Administration (part of the DOT) all incidents involving hazardous materials. These reports are maintained in a data base (the Hazardous Materials Information System) that is used to identify problems related to the transportation of hazardous materials. This data base should be of value to the emergency response community in its pre-planning activities.

The DOT regulations are only a part of the federal hazmat rules. The Environmen-tal Protection Administration (EPA) and the Occupational Health and Safety Administration (OSHA) have adopted similar regulations that apply to industrial facilities, hazardous waste sites and other circumstances. These rules both improve local emergency response capabilities and provide the public with information about the hazardous and toxic chemicals in their communities.

Steve Blackistone, a Firehouse® contributing editor, is an attorney and a member of the Bethesda-Chevy Chase Rescue Squad in Montgomery County, MD.