Top 3 hazmat violations in 2021
Posted July 23, 2021
According to the Federal Motor Carrier Safety Administration’s (FMCSA’s) Analysis & Information (A&I) online data, the top three hazardous materials regulations violations so far this year are as follows:
- Package not secure in vehicle (177.834(a))
- No copy of US DOT Hazardous Materials Registration Number (107.620(b))
- Shipping paper accessibility (177.817(e))
“Package not secure in vehicle” has been at the top of the list for the past four years (that’s as far as the data goes back).
Drivers are on the road and responsible for the hazmat load at the time of inspection. The top three violation areas — package securement, USDOT hazmat registration, and shipping papers — are all areas where drivers may need to be reminded of their responsibilities:
Package securement. While on the road, packages containing hazmat and not permanently attached to the vehicle must be secured. This means the packages must be braced and secured to minimize shifting within the vehicle during normal transportation conditions. Additionally, drivers need to be aware of segregation requirements. Certain hazmat cannot be transported with other types of hazmat and this information is laid out in the segregation table in 177.848. Be sure your drivers know about the segregation requirements, where to find the table, and how to use the information.
No copy of USDOT Hazardous Materials Registration Number. Each year, if you’re required to obtain the hazardous material registration, you’re required to keep copies of the registration statement and the certificate of registration at your principal place of business. There’s an additional requirement for motor carriers, however. Drivers must carry a copy of your current certificate of registration, or another document bearing your current year’s registration number identified as the “U.S. DOT Hazmat Reg. No.” Every vehicle you use for the transportation of a hazardous material that meets the registration criteria must have this proof of registration on board. It could be that drivers have this documentation on board, but just aren’t aware of it. Or, it could be that the documentation truly isn’t on board the vehicle. Since certificates for 2021-2022 were just issued, be sure to place a new copy of the documentation in your vehicles and let drivers know what to provide to enforcement when asked.
Shipping papers. While transporting hazmat by highway, shipping papers have very specific requirements because they need to be accessible to authorities in the event of an incident or accident. Be sure to remind drivers that:
- If the hazmat shipping paper is carried with any other papers, it is clearly distinguished either with a tab or by appearing first.
- When at the controls, the shipping papers must be within the immediate reach of the driver when restrained by the seat belt.
- The shipping papers must be readily visible to anyone entering the driver’s compartment, or in a pouch or holder mounted on the inside of the driver’s side door.
- If the driver is not in the vehicle, the shipping paper must be either in the door pouch, the door holder, or the driver’s seat.
Additionally, shipping papers must have emergency response information on or in association with the shipping paper.
This article was written by Heather Ness of J. J. Keller & Associates, Inc.