DOT Hazardous Materials Not Under EH&S? 12 Common Missteps Which Can Likely Result

Hazardous materials transportation compliance issues can cast a wide net across an organization and impact many people and departments. It’s not unusual for compliance in this area to be de-centralized and not fall completely under an EH&S department’s or manager’s responsibility.  Compliance goes well beyond the shipping of chemical and biological wastes wherein contracted vendors often provide compliance assistance and perform many of the pre-transport tasks.

12 common mistakes, which more often arise from such de-centralized environments, include:

1. Not understanding the regulatory differences between modes (air, hwy, water, rail)
2. Offering electronics, batteries, and instruments mistakenly as non-hazardous
3. Improperly preparing of packages for return to suppliers
4. Assuming the competency and MSDS/SDS reliability of original suppliers
5. Not controlling access to shipping accounts to only trained employees
6. Inadvertently creating inspection and enforcement triggers
7. Increasing regulatory burden and liability by shipping by air when not necessary
8. Improperly preparing hazardous materials for self-transport or hiring of untrained couriers to move hazardous materials
9. Not obtaining the correct software, pre-approval and/or contract to ship hazmats
10. Not determining “competency” of hazmat employees
11. Not training receivers in issues related to proper identification and emergency response
12. Not having administrative control over the hazardous materials program (security, registration, inspection preparedness, recordkeeping, reporting, etc.)