Article Contributor: Betsy Sibila
In 2015 there were a couple of changes to Department of Transportation (DOT) Regulations that may or may not apply to your organization. To make sure you are keeping up, below is a brief description of these two changes.
The DOT has added new descriptions and Proper Shipping Names for Air Bag Inflators/Modules and Seat-belt Pretensioners. These devices have previously been listed with the following entries:
- “Air bag inflators or Air bag modules or Seat-belt pretensioners” assigned to identification number UN 3268, which is a Class 9 hazardous material, and
- “Air bag inflators or Air bag modules or Seat-belt pretensioners” assigned to identification number UN 0503, which is a Class 1.4G hazardous material. This classification is for similar devices that are explosive articles.
As of January 1, 2016, the Proper Shipping Names – Air Bag Inflators, Air Bag Modules, or Seat-belt Pretensioners will no longer be acceptable for UN3268. The new Proper Shipping Names correspond to a revision to regulation 49 CFR 172.102, special provision 160, for a number of automotive industry life-saving appliances that are actuated by an electric signal of a crash sensor or apply the use of a Class 1 explosive device. The new Proper Shipping Names are:
- “Safety devices, electrically initiated” assigned to identification number UN 3268, and
- “Safety devices, pyrotechnic” assigned to identification number UN 0503
The DOT Hazardous Materials Regulations (HMR) require that all employees shipping hazardous materials complete training once every three years. KPA can assist with your training needs.
Another Shipping Change … Lithium Batteries
In February, 2015, new DOT HMR went into effect for businesses that ship lithium batteries. Shippers must comply with the new regulations or risk potential fines up to $75,000 per day. The changes pertain to nearly every step of the shipping process including classification, marking, labeling, and filling out shipping papers.
Under the new rules, a shipment of even a single small lithium cell is subject to specific package marking and hazard documentation requirements. Many employers will be responsible for compliance with shipping rules for the first time and these shippers may be unfamiliar with HMR that apply to their products and packages. The DOT’s HMR require that all employees shipping hazardous materials, including employees involved in shipping lithium batteries, complete training once every three years.
Shipments containing lithium batteries are now so common that noncompliant shipments have a place on the DOT’s “Frequently Cited Violations” list. Do not become a statistic!
KPA wants to make sure you are keeping up with the changes. Risk Management Consultants can assist in identifying areas where changes in regulations affect your facility. And as for training? KPA can help! For additional information on regulations, training, or other inquiries, please contact a KPA Risk Management Consultant or email [email protected].