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30 Questions Hazmat Investigators Want to Ask

Posted on 6/13/2024 by Lion Technology Inc.

PHMSA recently shared a list of “general investigative questions” that the Office of Hazardous Materials Safety (OHMS) would like to ask hazmat shippers, transporters, and other stakeholders during safety investigations. 

The agency will accept public comments on the list of questions, until August 12, 2024.

Notice and Request for Comments Hazardous Materials: Information Collection Activities.

The list of about 30 questions must be approved by the Office of Management and Budget (OMB). If approved, the “pool” of relevant questions will guide investigators in their fact-finding efforts following hazmat incidents and releases. No new reporting or recordkeeping will be required. 

The list of hazmat-related questions appeared in the Federal Register on June 12, 2024: 

30 Questions Hazmat Investigators Want to Ask

Hazmat Safety Investigation Questions

The list of questions for OHMS personnel to use during hazmat investigations appears below. Click a topic to jump to it.


Introduction Questions

  1. What are your typical operations? Can you provide a general overview?
  2. To the best of your knowledge, was a hazardous material involved in your operations?
  3. If yes, please provide the proper shipping name.

General Hazardous Materials (Hazmat) Information

  1. Can you describe the hazardous materials in transportation you normally see?
    1. How often do you see them?
    2. Are you shipping them?
    3. Are you storing them?
  2. Are there any specific requirements for the condition of the hazardous material that must be followed before the identified material is transported?
  3. Have these conditions been verified? If so, what was the method used?
  4. Are there modal-specific (rail/air/ vessel/highway) requirements for this hazardous material that you follow? If so, what are they?
  5. Do the locations accepting your hazardous material have any concerns/ special accommodations when receiving your hazardous material?
  6. Do shipping agents (e.g., insurance companies, shippers) have specific requirements when accepting your hazardous material?
  7. Which hazard class(es) of hazardous materials in transportation do you routinely see?

Hazardous Material Training

  1. Which employees/departments are trained to be able to handle this hazardous material? Who conducts this training?
  2. When was the last time training was provided?
  3. How do you determine who needs training?

Safety

  1. What have you or your industry done to mitigate risk around this hazardous material?
  2. What solutions have been found to be helpful during hazardous materials incidents?
  3. How would you handle a hazardous material found to be damaged or not properly packaged?
  4. Are there any special requirements in place or instructions when hazardous materials are present?

Emergencies/Incidents

  1. Do you have the means to contain the hazardous material if there is an accident or an incident?
  2. What remediation companies are potentially contracted at this location or by this company?
  3. Are you familiar with security plan requirements?

Industry Process/SOPs

  1. Can you identify other companies involved in the transportation of this hazardous material? Can you share their contact information?
  2. What are the locations of your hazardous materials operations?
  3. Can you share the Standard Operation Procedures (SOP) for the handling of hazardous materials at your company?
  4. Are you familiar with registration requirements? e. Who signs and prepares shipping papers?
  5. Do you transport any hazardous materials in compliance with an approval or special permit?
  6. Do you have any type of validation process for hazardous material shipping?

Carriers/Shippers/Testers/Manufacturers

  1. Do you manufacture any hazardous material packaging?
  2. Are any other entities involved with the preparation, handling, or transportation of hazardous materials?

Packaging

  1. Where do you purchase hazardous materials packaging?
  2. Is the product loaded at any specific temperature/pressure?
  3. What types of packaging do you routinely see/use for hazardous materials transportation? Including bulk, non-bulk, and/or cylinders.
  4. At what interval are you having the package tested? Who performs this function? Are there records?
  5. How are you closing the packages? Which tools or other equipment are used?

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