Opinion: Three Words for Hazmat Safety: Training, Training, Training

By Alan I. Roberts

azardous Materials Advisory Council

When I got involved in the safety of hazardous materials transportation more than 40 years ago, the poor quality of training, or lack of it, was made evident to me at an early stage. I started out as a safety inspector in the Interstate Commerce Commission’s Bureau of Motor Carriers. One early assignment was to investigate the shipping practices of a company located in the suburbs of Philadelphia after one of its shipments had leaked and eaten 18 holes in the belly compartment of an Eastern Airlines passenger aircraft that made an emergency landing in Louisville.

When I visited the company, the packer-shipping clerk informed me that he received his instructions by telephone from New York and that he was to decide how to execute the instructions. He was unaware that the material he was shipping — hydrochloric acid containing a dissolved substance — would attack steel with vigor and was not permitted by the regulations to be shipped in the five-gallon steel pails he used. In fact, he didn’t even know there were regulations. He was not trained.

In 1964, I investigated an incident in Marshall’s Creek, Pa., that resulted in six fatalities, 13 injuries and extensive property damage. The driver of a tractor-trailer removed the placards from the trailer, which contained 30,000 pounds of dynamite and blasting agents, and left the trailer in the parking lot of a tourist attraction. He drove his tractor to a nearby town to call his company to report a flat tire on the trailer. The tire (with tube) ignited and the load detonated just as the local fire department arrived.

Our investigation disclosed that the headquarters “staff” of the large corporation involved in the incident did an excellent job preparing training manuals and instructions — including, “Never leave your vehicle unattended.” The simple, albeit very serious, problem was that the “staff” was just that — staff. They delivered their instructions and guidance to the branch locations, but had no follow-up responsibilities. The line managers were supposedly responsible for the delivery of training.

It was obvious during the investigation that there was little, if any, training given to drivers — and none whatsoever during the six months prior to the explosion.

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Some will say that things are very different now that industry has gotten much smarter and is much more committed to employee training. Well, I suggest we avoid becoming too confident.

More than 30 years after the two incidents described above, I represented the Department of Transportation as a party to the National Transportation Safety Board’s investigation of the fatal ValuJet accident. Again, in my view, lack of training was a key factor leading to that tragedy.

Some will also wonder why I mention two aviation accidents in a publication focused primarily on the trucking industry. The reason is simple and twofold: Almost 100% of the freight transported on airplanes moves first on trucks; and the firms that participate in moving hazmats to airports can play a key role in assuring the hazardous materials are offered in compliance with regulations for transportation by air — assuming their personnel are properly trained.

An evaluation of DOT’s hazmat program was recently completed, and one conclusion suggested the current training regulations are inadequate. While I am certain the topic will be given serious consideration, I doubt there will be many changes, if any.

More than a third of the current enforcement actions include alleged failure to properly train employees. Therefore, it’s apparent the existing training requirements are enforceable. More detailed training requirements from our government may not be the answer, since their implementation would probably be rather cumbersome, considering that several hundred different occupations would have to be addressed. For example, the training of a tank truck driver would be substantially different than the training given a hospital worker preparing medical waste for transportation.

What is needed is a serious commitment on the part of each hazmat employer (a statutory term) to give serious attention to all aspect of its safety training program. Is it sufficient in scope to address all functions subject to the regulation? Has any function been overlooked that has the potential to be a threat to your business, such as contract employees performing duties under the direction of your managers? Are the training personnel upon whom you rely competent and qualified to perform their assigned training responsibilities? If you are relying on vendors to provide your hazmat training, have you checked their qualifications and the extent to which they may certify your employees have been trained as required?

In simple terms, I am recommending you conduct a vulnerability assessment to be satisfied that your training program is the best it can be. This is an important step that is necessary to ensure you are doing your best to protect your company, your employees and your community.

For helpful interpretations concerning the DOT training regulations, I suggest you click on the Training icon at www.hazmat.dot.gov. We have some useful information on our Web site at www.hmac.org.

From 1975 until his retirement at the end of 1999, Alan I. Roberts was responsible for the Department of Transportation’s day-to-day management of hazardous materials. He is now president of the Hazardous Materials Advisory Council, Washington, D.C.