24 Spray February 2018
Gene Sanders
W.E. Train Consulting
From here to there:
Topics in
Transportation
Take It Personally!
I have trouble with my elevator speech. You know, that pitch
where you tell someone else what you do during the time
it takes for an elevator to reach your floor after you get on.
Somewhere in my explanation I’ll inevitably mention “hazardous
materials,” which is often just enough information for my
conversation partner to think they know what I do. Sometimes, I
get a response to the effect of “Yeah, it’s really important to keep
track of those hazardous wastes”. Well, yeah, but no.
Important hazardous waste (HazWaste) regulations are put out
by the U.S. Environmental Protection Agency (EPA) but they differ
from those issued by the U.S. Dept. of Transportation (DOT) or its
international equivalents, which is what I specialize in.
On other occasions, my speech gets a response such as, “Oh,
those chemicals that have material safety data sheets (MSDS)?”
Well again, yeah, but no. MSDS are now just known as safety
data sheets (SDS), at least around most of the globe, and they too
are important. The chemicals they address are often “Dangerous
Goods” (Hazardous Material or HazMat for transport), but not
always, and Dangerous Goods regulations cover a lot of materials
that aren’t considered “chemicals” by the Occupational Safety &
Health Administration (OSHA) definition.
Oops, the elevator doors open at our floor, and I haven’t even
managed to talk about how some safety regulations regarding
“hazardous” aren’t the same as transport safety regulations
regarding “hazardous.”
However, at least everyone knows what kind of stuff the
transport regulations deal with, right? Think again. Everyone
knows about most materials the Dangerous Goods regulations
cover, but few know that they’re HazMat. There are several reasons
for this. To start with, air travelers get the wrong message from
our modern aviation systems. Upon checking in, almost every
traveler clicks a button on a screen (maybe a cell phone, or maybe
at the airport) declaring that they have no, none, zip, zero HazMat
with them or in their luggage. They then go through security
where their carry-on stuff is peered at via X-ray, and their checked
luggage occasionally has a rectangular notice that it was manually
inspected, and neither type of inspection results in them being
told that they lied about not having any HazMat. Because, make no
mistake, you always have HazMat with you. Whether worn on your
wrist, or in your cell phone, or in your key fob or powering any of
a whole range of other electronics, you’ve got batteries with you,
and all batteries are HazMat (Dangerous Goods). Not to mention
aerosols that are often in checked luggage, as well as the perfumes,
colognes, nail polish or nail polish remover that are all similar
HazMat. Because the Transportation Security Administration
(TSA—who does the peering, X-raying and inspecting) isn’t
interested in enforcing HazMat regulations, airline passengers
inadvertently and mistakenly learn that many Hazardous Materials
aren’t hazardous.
Besides, who would eat, inhale or rub HazMat into or onto
their bodies? Well, anyone who drinks a bit of cough syrup and its
ethanol ingredient, or puffs an asthma inhaler, or uses an alcoholbased
hand sanitizer, would ingest, inhale or smear HazMat.
“Wait a moment,” you may be thinking, “I can get all those
things at my grocery store, so they can’t be HazMat.” The
pharmacist or cashier doesn’t give you shipping papers. The
policeman issuing you a warning for that burned-out brake
light doesn’t give you a further ticket for not HazMat placarding
your car, so how can those spray paints, batteries, medicine and
personal care products be HazMat? Not to mention the matches,
drain cleaners, liquid paints, vanilla extracts and insecticides? Well,
the answer is as simple as two words: “in commerce”.
Last time I took (rather than teaching) a ground HazMat
transport course, I sat next to two people from Wal-Mart. These
individuals reminded me that from the manufacturer to Wal-Mart
(and more importantly to them) from the Wal-Mart distribution
centers to Wal-Mart stores, HazMat regulations apply because