5 minute read
The View from the Porch Swing
FROM THE PORCH SWING
SHOULD 14 BE CONSIDERED THE NEW UNLUCKY NUMBER?
I can’t afford to stay in Manhattan in New York City, but recently a client could. So, I got a couple nights in a hotel with 13 floors, or more accurately, 12 floors and an accessible roof. And on this roof was an open-air bar. I had arrived after a long cross-country flight, and thought a couple of drinks would help me sleep and thus re-set my body clock.
Spurious rationalization or not, I was in the elevator on my way up when it stopped at another floor for more passengers. One of the newbies wondered to the other whether the “14” button was for the top floor of rooms or for the roof, and worried about not getting to the bar before the end of ‘happy hour’. The sign on the side of the elevator behind her back gave the answer, yes, the 14th floor was indeed the roof. But then the devil jumped on my shoulder. “Actually”, I said, “the button marked 14 only takes you to the 13th floor”. As the two guests looked bewildered, I pointed out that the numbers went directly from 12 to 14 without a 13. Both of them looked at me so funny I started to wonder if the two young ladies thought I was trying to pick them up (hit on them). Then one said “that’s odd” and the other said that still wouldn’t tell them whether the 14 button would take them to the rooftop bar.
I handled it in reverse order by reassuring them that, yes, they’d make it to the half prize booze on the 14th floor rooftop bar in time, and that 13 used to be considered such an unlucky number that hotel guests would refuse to sleep on the 13th floor. So hotels learned to just skip that number.
Striving valiantly to look impressed by my nugget of trivia from back in the dark ages, the young ladies nonetheless did ensure they went to the other end of the bar from me. Too old to be perturbed by them thinking I might be a crazy coot with improper intentions, I nursed my still way-overpriced even at happy hour, craft beer, while pondering which number should/would be considered unluckiest if the fear of 13 has worn away.
Then there was class the next day, and the answer beat me over the head.
I had a couple of Europeans, trying to get comfortable with the US DOT’s 49CFR regulations, when what to put on the SDS (mSDS) for DG transport became the topic of the day.
“So”, one said, “if we put ‘Environmentally Hazardous’ on our SDS for our bulk shipments when they are a US Marine Pollutant (note: often different from a global Marine Pollutant), then our non-bulk road and air shipments may be rejected from the carrier as undeclared?” (note: US Marine Pollutants only have to be regulated when in “bulk” or by vessel). “And yet,” the other continued, “if we put non-DG on the SDS, then the carrier may think our bulk shipments are improperly marked and placarded?” Yes, and yes. These were fast learners.
One asked, “if we heat a certain solid hot enough to melt it for easy pouring into a portable tank, then it might or might not be DG as an ‘Elevated Temperature’ material depending upon how long it is between filling and offering to the carrier?” “Yes”, I said, “it depends upon the material’s temperature when the carrier comes to get it.” “Well then”, the other asked, “what are we to put into the SDS?”
“Are you kidding,” was asked that day, “our viscous liquid is PG II in some sizes and PG III in other sizes?” As I was learning to expect, the other chimed in with “and how does that get handled on an SDS?”
“What are you saying,” one asked, “that in an aerosol type container it’s classified as an Aerosol, but in a cylinder it’s merely a Chemical Under Pressure?” And with the follow-up from the other side of the table…, “Do you think our SDS author knows what it’s going to be put in?” This then went back to the first commenter for, “How do we prevent this from being rejected
by the carrier if we use both packagings, and thus both classifications, but only put one on the SDS?”
“Acetone Solution when it’s a raw material, but ID8000 Consumer Commodity when it’s a product?”, followed by the other half of the tag team offering, “Oh, wait, only ID8000 by air, not by boat?”.
“UN1950, Aerosol, outside the USA, but just the PSN (proper shipping name) of the gas when in the USA, because 49CFR doesn’t allow ‘just gas’ aerosols?”, was succeeded by colleague’s, “Wow, so, from Germany to South America one SDS with one classification, but from Germany to the US a different classification and therefore a different SDS?”
Oh my, I could go on. Combustible liquids, self-heating size variations, US Toxic Gas When Wet, life-saving appliances with and/or without lithium batteries, transition options for vehicles, and more. So many variations and permutations that I’ve picked a new unlucky number, Section 14.
Do SDS authors get adequately trained on these transportation quirks? A few do, but many don’t. Do acceptance personnel at carriers get adequate training on classification, in order to be able to use Section 14 properly? I want to say never, but must settle for usually not. In fact, some carriers won’t even listen to an explanation, instead insisting on an SDS that matches every detail of the now held shipment.
Yeah, I think 14 is proving to be a very difficult, if not unlucky number for more and more shippers and their mSDS authoring folks. Tetradekaphobia, anyone?
This is the latest in a series of musings from the porch swing of Gene Sanders, principal of Tampa-based WE Train Consulting; telephone: (+1 813) 855 3855; email gene@wetrainconsulting.com.
