Shipping Powder and Hazmat/Dangerous goods

[XTR]

The other topic is locked or I'd post this there.

For the record, I've been a Waste and Hazmat transportation and disposal coordinator/shipper/broker for 25 yrs. I am registered with DOT as hazmat shipper, certified IATA shipper, and teach DOT hazmat training for my company.

The point of all that is that I'm not just a guy who heard something in the gun shop. In this case it is actually my profession.

The average person cannot ship hazmat. Once you have received a delivery of powder or primers they are yours and about the only way you can give them to another person is face to face.

Notwithstanding some specific exemptions, you have to be trained to ship haz. There is a reason carriers won't take a shipment from you, it's the shippers* responsibility to determine that the material is properly classified and packaged IAW the requirements of 49 CFR. W/O training you don't even know where to start looking in the book.

There are some things that have specific exemptions that can get you out of the regs (e.g., primed cases it's Special Provision 50 to the hazmat table in 172.101 but you still need someone to tell you that or you'll never get there) but bulk powder or primers in boxes, there is no way that you can be compliant w/o training. The training is a requirement under 172.704, so w/o it you are not compliant.

* The shipper is the person offering the material for transportation, so you are the shipper, unless you contract someone to do that for you. I bill out at about $150/hr.

 

[searcher]

Out of curiosity, can an "average citizen" who owns no business take this training and then be legal to ship through, for example,
Fedex or U.P.S.? If so, how many hours of training time should it take to attain such status - and is there a test? If so, who administers it?

 

[dickn52]

Ok, are we going around in circles here? If I take hazmat shipment to UPS and they ask the magic question, and they will, don't they become the 'shipper' of record and I pay them the $27.50 fee or whatever the fee is? They will want to know if it is packaged in compliance with the laws, placarding, double wall boxes, box in a box or whatever that commodity calls for in the regulation then they will check it and then they will either accept the shipment or not. The UPS concern is when something does NOT meet the compliance statutes, DOT catches the shipment during a random inspection and fines them into non profit status for that complete TRUCK, not just the one shipment. Theory being your little cache of primers could start something with the other packages in that truck.

 

[spclark]

Out of curiosity, can an "average citizen" who owns no business take this training and then be legal to ship through, for example,
Fedex or U.P.S.? If so, how many hours of training time should it take to attain such status - and is there a test? If so, who administers it?

FedEx used to have an on-line program that would, once passed, allow the taker to ship hazmat by GROUND only. The course to gain certification for shipping by AIR (FedEx Express) was offered only once a year, in select cities & cost about $800. That was in 2006 I think.

Believe the man when he says you do not want to risk getting caught shipping prohibited materials. You don't have enough in the bank to win your case or pay the fines....

 

[fdshuster]

XTR: You are the guy who can clearup some misunderstandings for the rest of us about Hazmat shipping. So, if you will: (1) Who wrote the regulations for Hazmat shipping requirements? (2) If someone is caught violating the regs., who is responsible for prosecution, and under what law or regulation? (3) Who determines what the fee will be? For example, the current $27.50, that was $25, and before that less. (4) Who actually receives the $27.50? (5) Do the regulations apply to inter-state transportation only, and not to in-state? For example, the seller/shipper, trucking company and receiver are all located in the same state. Thanks for any advice you are able to give.

 

[spclark]

Company I used to work for got fined $20,000 (2 instances @ $10,000 each) for shipping less than an ounce of touch-up lacquer.

That was back in 2007.

Here are a few more (scroll down) recent examples:

http://www.hazmat-news.com/

 

[XTR]

49CFR is the regulation that is promulgated to enforce the hazardous material transportation law.

No, UPS cannot just ask you and become the shipper. They are the carrier. You are the shipper unless you contract someone to take the responsibility and do it for you. UPS is not contracting for the hazmat fee. UPS cannot assume that you know how to characterize material, because you don't.

The fee that UPS charges is to offset their costs for handling hazmat in particular the training costs. There is also a whole different level of training that has to be completed in order to ship packages vs handling them in the warehouse or at the desk. The personnel at UPS and FedEx are not trained shippers, they are trained hazmat employees. They have not much better idea than you do as to what is appropriate packaging. They may have a checklist to determine what stickers should be in place, but determining the classification in the first place is way beyond the scope of their training.

The regulations apply to any material transported in commerce on public highways. Rail and air are under the same regs but with specialized requirements, and air carriers won't accept your packages unless you also comply with IATA.

I'm not going to upload my PowerPoint training slides here; however, PHMSA (Pipeline and Hazardous Material Safety Administration) is the branch of DOT that publishes the regulation. The Federal Rail Administration (FRA) handles rail and the FAA handles air shipments. Fines are substantial, and air shipments are a whole 'nuther issue and very high priority since 1998. It was undeclared, improperly shipped hazmat that brought down Valuejet Flight 592 in 1998.

I've had special agents from FRA and FAA contact me auditing shipments that I've done (no citations, no fines, just routine), but the first thing they ask for is my training records and the records of the people involved in the shipment.

The regulations are online here PHMSA

The training requirement is here: 172 Subpart H


Training violations are $250/person/day. I believe that UPS was hit with the largest fine ever handed down by DOT back in the mid 90s for training violations. (think about that $$ with say 5000 employees for a couple of yrs)

Other fine schedules are in the book, but understand, you never get one fine. Someone working for me once made a shipping error shipping radioactive material (most of what I move is) He recorded the wrong dose rate at 1 meter from the package. That reading is required to be recorded on the package and the shipping paper. That's two (2). The reading he got changed the class of label on the drum, changed it from the yellow III it was supposed to be to a Yellow II, wrong label on the package, wrong label listed on the shipping papers, that's two (2) more. Had they actually seen the truck leave there would have been a 5th citation because a Yellow III requires placarding, and a Yellow II does not, oops, and all of this got audited because another package he shipped from the same location was dropped 14 feet from the cargo door of a plane the shielding failed and the dose rates were higher than expected when the package was delivered to the destination.

How would you document that you were properly packaging the powder for shipment? "I shipped it out like it came in" isn't a good answer.

Searcher, yes you can get training if you need it. I give training for our people, and I actually attend one to three classes a yr, no one class covers everything that I have to stay current on, and even though the DOT requirement is training every 3 yrs I have to be trained every yr to maintain certain DOD certifications. Figure $600 to $1200 for a class plus travel.

 

[fredhorace77]

tag...good stuff here

 

[jnyfeler]

Thanks for the eye-opening info, XTR.

Jeff

 

[XTR]

It's a long running joke when I sign the shipping papers that I've become the designated felon.

 

[fdshuster]

XTR: Thank you for all the info. Bottom line seems to be, for all of us not qualified, to keep away from, and do not attempt to get involved in hazmat shipping of primers and powder.

Makes me think back to the for sale ads I've seen here, (and elsewhere) for primers and powder, and it's easy to see that at least some of those ads might involve illegal shipping.

All the more reason face-to-face transactions make sense.

 

[spclark]

Good stuff XTR, thanks for taking time to key all that in.

It should be very clear now there are literally legions of folks out there whose jobs are full-time serious about enforcing the rules in place and uncovering violations over shipping all kinds of stuff we take for granted. It's not just those we use for our shooting pursuits either; the batteries in cell phones & other electronic devices (lithium) are a "hot topic" right now (pun fully intentional).

 

[M-61]

XTR....thanks for the input on the complete picture.....and taking the time to post this.

 

[XTR]

It’s been a few yrs, I’m going to run this one back to the top just as a public service FYI

 

[hogpatrol]

It’s been a few yrs, I’m going to run this one back to the top just as a public service FYI

Your original post needs to be a sticky in the classified ads. What say you boss?

 

[Hend7526]

The other topic is locked or I'd post this there.

For the record, I've been a Waste and Hazmat transportation and disposal coordinator/shipper/broker for 25 yrs. I am registered with DOT as hazmat shipper, certified IATA shipper, and teach DOT hazmat training for my company.

The point of all that is that I'm not just a guy who heard something in the gun shop. In this case it is actually my profession.

The average person cannot ship hazmat. Once you have received a delivery of powder or primers they are yours and about the only way you can give them to another person is face to face.

Notwithstanding some specific exemptions, you have to be trained to ship haz. There is a reason carriers won't take a shipment from you, it's the shippers* responsibility to determine that the material is properly classified and packaged IAW the requirements of 49 CFR. W/O training you don't even know where to start looking in the book.

There are some things that have specific exemptions that can get you out of the regs (e.g., primed cases it's Special Provision 50 to the hazmat table in 172.101 but you still need someone to tell you that or you'll never get there) but bulk powder or primers in boxes, there is no way that you can be compliant w/o training. The training is a requirement under 172.704, so w/o it you are not compliant.

* The shipper is the person offering the material for transportation, so you are the shipper, unless you contract someone to do that for you. I bill out at about $150/hr.

Hi! I just finished my course, but still have questions on proper labels and placarding! Is this something you would be willing to help me with?

thanks!
H

 

[XTR]

Hi! I just finished my course, but still have questions on proper labels and placarding! Is this something you would be willing to help me with?

thanks!
H

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