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Proposed Recommended Practices for Bulk Loading and Unloading of Hazardous Materials in Transportation

When the U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) adopted HM-223, it indicated that it did not fully “own” loading and unloading bulk hazardous materials from a jurisdictional perspective. HAZMAT Packager & Shipper has been covering this issue, and reported on the public workshops that PHMSA held. Recently PHMSA published a public notice in the Federal Register requesting public comments on the adoption of bulk loading and unloading practices.

History
In our March/April 2007 issue, Senior Technical Advisor Frits Wybenga’s report titled “Analysis of Hazmat Incident Data Sheds New Light on Loading and Unloading” looked at the data PHMSA had collected over a three year period. He reported that based on its analysis of hazmat loading and unloading incidents, the agency had decided to consider hazmat loading and unloading a priority issue. In the May/June 2007 issue, HAZMAT Packager & Shipper interviewed Bob Chipkevich, who is the director of the Office of Railroad, Pipeline, and Hazardous Materials Investigations for the National Transportation Safety Board. Mr. Chipkevich gave his perspectives on the regulation of bulk loading and unloading operations, and what he hopes will occur in the future regarding the changes in the regulations. Mr. Chipkevich believes that “safety requirements should provide sufficient direction to ensure that personnel involved in safety-critical loading and unloading operations are provided with clear written procedures and that they are properly trained and qualified.”

On June 14, 2007, PHMSA held a public workshop on reducing the risk in the loading and unloading of hazardous materials. Senior Technical Advisor Frits Wybenga covered the workshop in our July/August 2007 issue in a report titled “PHMSA Holds a Workshop on Reducing the Risks of Hazardous Materials Incidents During Loading and Unloading Operations”. The workshop was divided into panels that considered the definition of the problem and identification of a possible solution. It covered industry perspectives, emergency response community perspectives, and the perspectives of the federal government. The workshop was used to give PHMSA a fresh look at the issue. On January 4, 2008, PHSMA announced it was seeking public comments on reducing the risks of hazardous materials incidents during loading and unloading operations. The initial deadline for comments was February 8, 2008, but was later extended to March 14, 2008. Several organizations and a number of companies submitted comments. Some of these are summarized in the following.

National Transportation Safety Board
Many companies support PHMSA setting bulk loading and unloading practices. The National Transportation Safety Board believes that the practices are comprehensive and satisfactorily address safety issues, but is concerned that the proposed practices are only recommended and that implementations would be left up to the shipper, carrier, or consignee of the hazardous material. Under the best of circumstances compliance would be selective and inconsistent, and under the worst circumstances they would not be met at all. Due to these concerns the Safety Board encourages PHMSA to adopt these recommended practices directly or by reference into the Hazardous Materials Regulations.

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