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BASICs: Improving Hazardous Materials Compliance 10


4


Conduct Oversight


Management is responsible for oversight. To assure consistency of results in hazardous materials compliance, management must:


• Maintain a hazardous materials security plan for its place of business and train employees in how to report hazardous materials incidents.


• Regularly review a sampling of shipping papers to ensure that information provided by the shipper matches actions taken by the motor carrier.


• Contact the shipper on any missing or inadequate hazardous materials information. • Review all hazardous materials violations and challenge discrepancies through the FMCSA DataQs process as needed.


• Ask whether hazardous materials violations are specific to a vehicle, a person or job function or potentially system-wide.


• Take action appropriate to findings, whether as reminders, enhanced training, improved equipment, or discipline.


• Document all employee training and all corrective actions taken, whether in regard to personnel, the shipper or in response to incidents and violations.


Be assured, FMCSA or state investigators will look for policies and procedures supporting these same management steps – direction, authority, tools and oversight - when investigating hazardous materials issues at a motor carrier.


Documentation as a


Management Responsibility Coordination with hazardous materials shippers


A common motor carrier mistake is assuming that the shipper has all responsibility for hazardous materials identification, labeling, shipping papers and emergency response. Hazardous materials shippers are regulated by the USDOT, as are hazardous materials carriers. But the USDOT lists carrier responsibilities as overlapping with shippers in most significant respects. (A private carrier, who is an arm of the parent shipper company, performs both sets of responsibilities in their entirety.) A motor carrier must document its close coordination with the hazardous materials shipper, particularly on corrective actions taken, to avoid violations and achieve full hazardous materials compliance.


4 Documentation Responsibilities:


1. Shipper coordination of loads


2. USDOT hazmat registration


3. Hazmat CDL endorsements


4. Completion of employee training


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