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For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Cargo Securement for Chemical Distributors
This webcast will cover ...• DOT Cargo Securement
requirements for bulk and non-bulk hazmat
• CSA and the Cargo BASIC • Roadside inspections and the top
cargo violations • Accident liability and cargo loss • Driver training
ModeratorMike Lang, Vice President, Responsible
Distribution, National Association of Chemical Distributors
PresenterTom Bray, Sr. Editor - Transport Management, J. J. Keller & Associates, Inc.
Attention Attendees:+ Thank you for attending!+ The presentation will start in a few
minutes at 1:00 PM Central.+ Please use your computer speakers to
listen to the event. If you have audio issues, dial-in info is below.
+ You will be muted during the event.+ Please use the Question feature to text
questions to “Q & A”. We’ll try to answer them during the Q&A period if they are not covered in the presentation.
+ The slides and recording will be posted in 7 days at: http://www.jjkeller.com/cbdawebcasts
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Mike LangVice President, Responsible Distribution
National Association of Chemical Distributors
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Introductions• DOT Cargo Securement requirements for bulk and non-bulk
hazmat• CSA and the Cargo BASIC • Roadside inspections and the top cargo violations • Accident liability and cargo loss • Driver training• Question & Answer• Housekeeping issues:
You will be muted during the event. Please use the Question feature to text questions to the Q&A Panelist. We’ll
try to answer them during the Q&A period if they are not covered in the presentation.
If you lose sound at any point, you can dial-in by phone using the number and Pass Code listed below.
If you lose the program window and need to re-login be sure to enter a different e-mail address to avoid being denied access for multiple logins.
Mike LangNACD
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Disclaimers
• The content in this webcast is intended for information purposes only and should not be construed as providing legal advice.
• If you ask questions based on your unique circumstances, we will attempt to address them from a more general perspective.
• This is an introductory course and is intended to highlight critical safety and compliance topics. Time constraints limit our ability to go in depth.
Mike LangNACD
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Tom Bray
Sr. Editor – Transport Management
J. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Cargo Securement
• According to 49 CFR §391.13, drivers must understand the vehicle inspection and securement requirements found in Parts 392 and 393 of the Federal Motor Carrier Safety Regulations (FMCSRs).
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
392.9• All cargo must be properly distributed and
adequately secured • Inspect the vehicle’s cargo and load securing
devices within the first 50 miles• Reexamine again after 3 hours,
150 miles, or next change of duty status (whichever comes first)
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
393• Aggregate working load limit • Anchor point • Blocking • Bracing • Dunnage • Friction mat • Shoring bar (or load bar)• Tiedown • Working load limit (WLL)• Header boards• Cargo covers (tarps)• Sealed container loads
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Compliance Safety Accountability (CSA) Overview
• CSA is an enforcement system for: Tracking, measuring, and evaluating carrier and driver
compliance and safety performance Increasing the carrier contact frequency “Rating” all carriers (will require rulemaking)
• CSA tracks: All carriers regulated as an interstate carrier that have
a USDOT number, regardless of “type” (and their drivers)
Intrastate carriers that have a DOT number
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
CSA Process• Data collection (roadside inspection, interventions,
crashes)• Safety Measurement System (SMS)• Seven “BASICs” (Behavior Analysis and Safety
Improvement Categories) Unsafe Driving (Parts 392, 397, etc.) Fatigued Driving (Parts 392 and 395) Driver Fitness (Parts 383 and 391) Controlled Substances/Alcohol (Part 382 and 392) Vehicle Maintenance (Parts 392, 393, and 396) Cargo Related (Parts 392, 393 Subpart I, and HM regulations) Crash Indicator
• Comprehensive and progressive interventions
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
SMS Process• Measures and compares safety performance using all
safety-based violations discovered during roadside inspections and interventions, and DOT-recordable crashes
• All violations are severity and time weighted Severity Weight - Violations 1-10, Accidents 1-3 Time Weight - 0-6 months = 3, 6-12 = 2, 12-24 = 1 Full value is determined by a formula that multiplies the weights
• Once per month, scores are totaled, normalized, and used to percentile-order carriers in BASICs versus peers in Safety Event Groups
• Carriers with percentiles that exceed the BASIC thresholds will be targeted for intervention
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
BASIC Hazmat
•Unsafe Driving•Fatigued Driving•Crash
60%
•Driver Fitness•Drugs/ Alcohol•Vehicle Maintenance•Cargo-Related
75%
Complaints and crashes can lead to investigative interventions as well
Intervention Thresholds
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
CSA Intervention Process
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Interventions• Early Contact
Warning Letter Carrier Access to Safety Data and Measurement Targeted Roadside Inspection
• Investigation Offsite Investigation Onsite Investigation – Focused Onsite Investigation – Comprehensive
• Follow-on Cooperative Safety Plan Notice of Violation Notice of Claim Operations Out-of Service Order
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Intervention Scoring
• Based on violations of serious regulations discovered during audits and investigations
• Will not “improve” BASIC Score, but can “flip” a BASIC Safety Evaluation to “Alert” (regardless of “BASIC Score”)
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Cargo Related Violations • Violations that effect BASIC Measure and
Score : Damaged or loose tiedown Failing to secure vehicle equipment or load HM placard missing, damaged, or obscured HM package not secure Shipping paper errors
• Discovered during auditing: Security plan problems No shipping paper for HM shipment Accepting and transporting HM not prepared properly Failure to maintain copies of cargo tank certificates
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Common Hazmat Violations - Roadside
Tom BrayJ. J. Keller & Associates, Inc.
VIOLATION NUMBER SEVERITY
Size and weight 199,456 --
No or improper load securement 13,981 10
Damaged securement system/ tiedowns 12,495 7
Failing to secure vehicle equipment 10,805 7
Failing to secure load 8,719 7
Loose/unfastened tiedown. 7,656 8
Leaking/spilling/blowing/falling cargo 7,653 10
Insufficient tiedowns 7,136 8
Driver load securement 5,611 10
Heavy vehicle/machine securement 5,418 10
Placard damaged, deteriorated, or obscured 3,736
5
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Common Hazmat Violations - Roadside
Tom BrayJ. J. Keller & Associates, Inc.
VIOLATION NUMBER SEVERITY
Placard damaged, deteriorated, or obscured 3,736 5
Package not secure in vehicle 3,147 10
No Copy Of Cert Of Registration Or Registration # On Subject Vehicle 3,006
--
Vehicle not placarded as required 2,977 5
Failing To Provide Carrier Required Placards 2,151 --
Shipping paper accessibility 1,784 3
No shipping papers (carrier) 1,577 3
Emergency response (ER) information missing 1,573
3
ER information not available 1,208 3
Offering HM Without Preparing A Shipping Paper 1,183
--
Placard damaged, deteriorated, or obscured 3,736 5
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
CSA How to Survive
• Existing data can be viewed at: CSA SMS
http://ai.fmcsa.dot.gov/SMS FMCSA Portal
https://portal.fmcsa.dot.gov/
• Get “wrong” data out of the system Learn and be willing to use the appeals processes:
Federal DataQs - https://dataqs.fmcsa.dot.gov/login.aspState Motor Carrier Safety OfficeCVSA Complaint Process
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Common HM Violations Discovered During Auditing
• Security plan problems (no plan when required, plan not current, plan not trained on, etc.)
• No shipping paper for HM shipment• Accepting and transport HM not prepared
properly• Failure to maintain copies of cargo tank certificates
(original, reman, testing)
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Preventing Cargo Related Problems
• Train, train, train• Make sure drivers:
Know what they are doing Know to ask questions
• Have replacement procedures for defective equipment
• Provide drivers with hands-on information Handbook Cheat sheets Support numbers (expert and/or mentor)
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Securement Components
• Tiedowns can be repaired• Must remain tight while in transit• Must be adjustable (except steel strapping)• Can’t contain knots• Edge protection may be required• Straps can go outside the rub rails• Lever-type binders are acceptable• You can choose the tiedown type
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Loading, Unloading, and Freight Inspections
• Never leave cargo unattended• Never use an unauthorized individual to load/unload
the vehicle• Check skid/package count before leaving• Make sure freight is properly described and in good
condition• Immediately report discrepancies (if not corrected, note on bill
of lading)• Be aware of signs of damage• Look for signs of tampering (broken seals, damaged tape)
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Maintain Accurate Vehicle and Cargo Information
• Vehicle identification, license, and serial numbers should be with the driver at all times
• Cargo information (lot numbers, types of containers used, markings, inventory numbers) should be with the driver at all times
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Stopping Procedures
• Be aware of areas traveling through• Plan stops• Avoid unauthorized stops• Never stop in the same place
at the same time • Stop at populated locations• Park in well lighted areas• Avoid dark, secluded areas• Avoid conversations with
strangers
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Seals and Locks
• Cargo seals expose any signs of load tampering, and locks help prevent theft
• A log of inbound and outbound cargo seal and lock numbers should be kept Date and time Number of trailer Destination of load Name of person applying Name of vehicle driver
• Record appropriate information if seal/lock is removed/broken
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Handling Vehicle/Cargo Theft
• Call the police immediately• Give as many details as possible
License number(s) on equipment Equipment serial number(s) Vehicle description Cargo description Time incident occurred Description of suspicious people near vehicle
• Notify the company
Make sure driver has this information with them whenever they leave the vehicle unattended!
Tom BrayJ. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Question & Answer
Please submit questions to “Q&A”
using the Question tool
Tom BrayJ. J. Keller & Associates, Inc.
Mike LangNACD
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Closing Remarks
• Thank you for attending! Please complete the survey.
• In 7 days, download the recording and slides from today’s webcast at: http://www.jjkeller.com/cbdawebcasts
• Upcoming NACD events: February 28: The Clean Air Act Section 112(r) General Duty Clause
- What You Need to Know Webcast March 27: Product Segregation in the Warehouse – EPA
Expectations and Resource Guidance Webcast April 2-3: Responsible Distribution Workshop (Houston)
Mike LangNACD
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