US DOT PHMSA processed more than 20,000 reports of transportation incidents involving hazardous materials last year. Each incident illustrates how even minuscule mistakes can result in shipping delays, packaging waste, lost product, injuries, and potential penalties for noncompliance with the HMR.
Below, check out three excerpts from real incident reports. As you read them, consider steps you might take to avoid similar errors in your shipping operations.
When Does DOT Require a Hazmat Incident Report?
The 49 CFR Hazardous Materials Regulations (HMR) require the person in physical possession of a hazardous material when a reportable incident occurs to submit a Hazardous Materials Incident Report on DOT Form F 5800.1
within 30 days of discovery of the incident.
DOT requires a written incident report when any of the following occur:
Serious incidents listed at §171.15(b)(1) to (6)—e.g., a person is killed, hospitalized, an evacuation is ordered, a major transportation "artery" is shut down, others.
An unintentional release of a hazardous material or discharge of any quantity of hazardous waste;
Specific structural damage to cargo tanks with a capacity of 1,000 gallons or more that contains any hazardous material (even if no release occurs) - see 49 CFR 171.16(a)(3).
Discovery of an undeclared hazardous material;
A fire, violent rupture, explosion, or dangerous evolution of heat that occurs as a direct result of a battery or battery-powered device.
Lessons from 3 Real Hazmat Incident Reports
As you read these partial incident reports, think about what steps you might have taken to prevent the incident. For each one, we extracted one or two key lessons that all shippers can benefit from.
Incident Report #1
"Shipment taken out of system flow because the external carton is wet. Box contained four 1-gallon plastic bottles of reagent alcohol. One bottle had a loose cap, allowing 0.20 gallons to release."
Shippers must close hazmat packages according to detailed manufacturer’s instructions which are commonly printed or embossed on the package. Closure instructions can be very specific—and may require a particular brand or product number for tools like tape, glue, staples, etc. The closure instructions for some packages even require that a lid or top be tightened to a specific torque specification.
A second lesson we can take is that a release does not have to be major to trigger an F5800.1 report to the DOT. One-fifth of a gallon of alcohol spilled from a loosely fitted bottle cap was enough to take the package out of transportation and delay delivery of part or all of the shipment.
The sorting facility that reported this release followed their procedure for damaged hazardous materials after discovering the small spill, making sure the damaged bottle was contained.
Incident Report #2
"Package loaded improperly, causing some product to leak out the top of a bottle. The caps were all on very tightly, so it is possible that some broke through when the box was loaded upside-down. Some spillage out of the top of the closure on one bottle of product."
Because improper loading of a hazardous materials package can lead to a release in transit, as it did here, employees who load hazardous materials packages are “hazmat employees” and must receive hazmat training.
Hazmat training must include a “function-specific” element that instructs the employee to perform his or her specific hazmat job role(s). For workers who load vehicles, “function-specific training” might cover things like the meaning of orientation arrows and other package markings, separation of incompatible materials on a vehicle, and other information relevant to the employee’s specific job function.
Without required hazmat training, an employee may not know that loading packages with the orientation arrows pointing in a direction other than “up” is illegal and can subject their company to hefty civil penalties.
Incident Report #3
"Package was being loaded onto van when it was dropped by package handler. Side of package was dented/punctured. near the base. Caused gold ink to start leaking out. Package was removed from vehicle, placed in a HazMat tote, and taken to HazMat cage using proper PPE. Excess ink was cleaned up with towel. Towel also placed in tote."
This incident is a reminder that accidents happen
. No matter how much effort and resources we devote to safe, compliant shipping practices—sometimes a box gets dropped.
When an employee drops a box containing hazardous materials, it’s important that they know the hazards of the material so that they can safely clean up a minor spill. The employee should also know who to notify so that the facility can initiate a response effort (if needed) and can file the required Incident Report.
While a spill during loading may slow down the process, hiding the error and loading a damaged package will exacerbate the problem, may expose supply chain workers to hazardous materials, and could even result in criminal penalties for a knowing and purposeful violation of the HMR.
Instructor-led DOT Hazmat Training
Develop in-depth expertise to keep hazmat shipments in full compliance with the latest 49 CFR Hazardous Materials Regulations (HMR), including shippers' responsibilities for incident reporting.
Join an instructor for in-person hazmat training in Houston, Chicago, Cincinnati, San Diego, San Jose, and St. Louis in early 2022. Or join us for comprehensive, instructor-led Hazmat Ground Shipper Certification Webinar on February 7–8
or March 7–8.
Or train at your own pace with Lion's online DOT hazmat training.