Cargo Securement for Chemical Distributors

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Cargo Securement for Chemical Distributors

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• 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
• Moderator
• Mike Lang, Vice President, Responsible
  Distribution, National Association of Chemical
  Distributors
• Presenter
• Tom Bray, Sr. Editor - Transport Management, J.
  J. Keller Associates, Inc.

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Mike LangVice President, Responsible
DistributionNational Association of Chemical
Distributors
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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 QA Panelist. Well try to answer them
  during the QA period if they are not covered in
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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.

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Tom Bray Sr. Editor Transport Management J. J.
Keller Associates, Inc.
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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).

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392.9

• All cargo must be properly distributed and
  adequately secured
• Inspect the vehicles 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)

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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

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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

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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

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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

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Intervention Thresholds
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
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CSA Intervention Process
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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

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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)

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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

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Common Hazmat Violations - Roadside
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
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Common Hazmat Violations - Roadside
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
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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/logi
  n.asp
• State Motor Carrier Safety Office
• CVSA Complaint Process

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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)

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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)

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Securement Components

• Tiedowns can be repaired
• Must remain tight while in transit
• Must be adjustable (except steel strapping)
• Cant 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

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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)

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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

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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

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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

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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!

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Question Answer

• Please submit questions to QA
• using the Question tool

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Closing Remarks

• Thank you for attending! Please complete the
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• In 7 days, download the recording and slides
  from todays webcast at http//www.jjkeller.com/c
  bdawebcasts
• Upcoming NACD events
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• April 2-3 Responsible Distribution Workshop
  (Houston)