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FMCSA’s Vince Babich, transportation specialist in the Hazardous Materials Division, reported that, in fact, hazardous materials are not a big focus for the Administration. It has only five dedicated staff, working under Paul Bomgardner, and 22 hazmat specialist inspectors across the country. FMCSA initiated a change in policy on
Hazardous Materials Safety Permits in June 2015, which was implemented in August. At the time of the COSTHA event, FMCSA has just issued a new brochure to explain the policy.
industry; this should be done within 18 months so there could be some changes coming soon. Another topic of intense interest to many in the audience at the COSTHA forum is what is happening within PHMSA in relation to special permits and approvals. Ryan Paquet, director of the Approvals and Permits Division in PHMSA’s Office of Hazardous Materials Safety, explained some of the recent changes in light of the reorganisation of PHMSA (as Charles Betts had already explained). For a start, PHMSA now has a bigger budget, some of which is being applied to improving data management. One outcome of that is that the special permits and approvals process will be quicker and more transparent. In addition, it should help the Approvals and Permits Division to work better with other agencies, such as the Federal Aviation Administration (FAA) and US Coast Guard (USCG). On a practical level, all new applications
for special permits will be processed through the new Special Permits Portal, a web-based system that will help applicants get their application right in the first place and then keep them up to date with its progress through the system. For instance, rather than being marked “pending”, each application will show how far it has progressed and average historical processing time will also be indicated.
AROUND THE MODES After PHMSA’s Charles Betts had summarised current and future rulemakings (HCB Monthly
June 2016, page 80), Tom Kenny, manager of FAA’s Office of Hazardous Materials Safety (ADG) reported on more reorganisation, this time at FAA head office. The work of ADG has recently been divided
into three offices: - ADG-100, hazmat rulemaking and enforcement, headed by Angel Collaku
- ADG-200, infrastructure and operations support, headed by Tom Kenny, and
- ADG-300, hazmat safety analysis and evaluations, headed by Rick Bornhorst. ADG-200 is the largest of the three, with a total of ten staff, though most work remotely. It is responsible for safety oversight to support the field operations teams. ADG-200 has started using Principal Hazmat Inspectors (PHIs), who are all dedicated hazardous materials personnel, to work alongside field inspectors and work directly with carriers. They also provide a single point of contact for certificate holders – American, Delta, FedEx, United, UPS, Atlas and DHL have already been assigned PHIs. The aim is to apply consistent and risk-based planning of assessments and inspections. Another expected outcome of the
reorganisation is better timeliness in terms of response and the provision of guidance. There is more work to do, Kenny said. The
approach will be extended to cover smaller and overseas carriers and to non-certificated entities, such as shippers, freight forwarders, repair stations, etc.
FROM THE FIELD FMCSA has also implemented a concentrated inspection programme on energy transport, most particularly in terms of the movement of crude oil by road. This started at the beginning of 2015 and ran to the end of September. FMCSA undertook 43 comprehensive carrier reviews, which led to 21 enforcement cases; another 62 comprehensive reviews were carried out at cargo tank motor vehicle facilities, which resulted in 35 enforcement cases; and 25 shipper reviews produced another 14 enforcement cases. In total, more than $950,000 in penalties was proposed. Easily the most prevalent violations found during this programme related to a failure to include all the required information on the test/inspection report. Other frequently encountered failings related mainly to testing and training. The focus on tank trucks will continue,
Babich said. FMCSA is also looking at the issue of intermediate bulk containers (IBCs); it had put in place a requirement that drivers of vehicles carrying four or more filled IBCs should have a tanker endorsement due to the potential for sloshing of the cargo that mirrors the effect found in tanker vehicles. However, the Batelle Institute has been studying the phenomenon and the results of that study will be published soon. This might lead to a revision of the definition of “tank vehicle”.
THE IMPACT OF HAZCOM 2012 (ABOVE) AND FMCSA’S CHANGING PROCEDURES WERE AMONG TOPICS OF INTEREST TO MANY AT THE COSTHA ANNUAL FORUM THIS YEAR
HCB MONTHLY | SEPTEMBER 2016
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