The View from the Porch Swing

at only the US DOT regulations, because the IMDG Code, and others, do the same thing, too. IMO has us add on the words MARINE POLLUTANT to shipping documents and add on a mark to the container when a material is bad for the environment if released. We do these two add-ons whenever the material is already a dangerous good (DG). But, what do we ‘add to’ if the material isn’t otherwise a dangerous good? Well, we make it a DG, throwing it into Class 9, giving it a PSN, PG, and technical name, and then we can add “Marine Pollutant” and the diamondshaped mark.

The USA treats their “hazardous substances” and the letters RQ almost identically. If a hazardous material is also a hazardous substance (which is confusing enough), then the preparer of the shipping papers must add on “RQ” (not just near the basic description, but immediately before or immediately after), and the packer must add on “RQ” near the other required marks and labels. And analogously to the IMDG Codes treatment of Marine Pollutants (MP), the US DOT requires that a hazardous substance that isn’t already a hazardous material be thrown into Class 9 so that the add-ons can be added on.

Long before there were any Proper Shipping Names (PSNs) that began with “Toxic by inhalation…”, the US DOT required that certain ‘inhalation hazards’ have their own add-ons, a practice that continues today. For certain materials that are “toxic by inhalation”, but not for all materials that cause toxicity when inhaled (wow, again, horrendously confusing), we must add on “INHALATION HAZARD” to both the shipping papers and the package marks, and we must add “poison” or “toxic”, and an appropriate HAZARD ZONE to the shipping papers. It’s not enough for a poisonous gas, for example, that it bear a hazard label with a skull-and-crossbones pictogram and a “2” in the bottom corner, those extra words must added on. And, oh yeah, in the US, the hazard label gets a black background added on behind those skullsand-crossed-bones.

Both inside and outside the USA, materials containing extra thermal energy get add-ons, too. Depending upon the physical state at

There’s also a point about consistency in approach that’s both philosophical and practical. Why is an MP sometimes Class 9 and sometimes not? Why can Class 9 be a primary hazard, but not a subsidiary hazard? Why aren’t Hazard Zones treated as the equivalent of “types” (like 5.2 or self-reactive) or “categories” (like 6.2) or “packaging group” (like most DG), and treated as an integral part of the basic classification? Why should Hazard Zone be an add-on, when PG isn’t? Sure, as long as the information gets communicated, we’ve got a decent system, and does it really matter if we’re ‘philosophically consistent’ in how we communicate? Well, how about the practical aspects, not including complicated spreadsheets or databases?

Both individual nations and international modal agencies are grappling with a perception (probably accurate) that DG training isn’t always well understood and applied. Is it possible that a big part of the problem isn’t just the quality of the instruction, the time allotted, and the employer follow-up, but the complexity of the material?

Is it possible that the more simple, the more uniform, the more ‘philosophically consistent’ we are, the more able students in DG courses will be able to understand the system, and more importantly, the better able to consistently apply it they’ll be? Is it possible that if we re-engineered our system a bit to reduce some of the add-ons, it would be more consistent, more understandable, and more consistently applied compliantly?

I don’t like fro yo, but I do really, really like our DG system. It’s the add-ons, though, that give me some pause, whether paying for them on nasty fro yo, or tacking them onto the framework of our basic DG classification and communication system. I can’t do much about the former, but maybe we can all weak the latter, make training simpler, and increase safety by making compliance easier to simply understand.

time of offering, physical state at standard temperature and pressure (STP), flash point, and amount of thermal energy (temperature), the container might get an add-on mark that looks like a thermometer inside a triangle or an add-on mark that says “HOT” inside a diamond outline, and the documents may get verbiage such as “Hot” or “Elevated Temperature” or even “molten” added on. Of course, like the MPs and RQs, if the hot stuff isn’t already a DG, we throw it into a hazard class, usually 9 but possibly 3, and then add on from there.

There are other add-ons, too, such as control and emergency temperatures for certain self-reactives, polymerizing materials, or organic peroxides. There are ‘cryogenic’, ultra-cold warnings for some gases. There are flash point communication requirements when shipping Class 3 by water, and more. And the problem isn’t that these requirements are unreasonable, because they are justified. It is important that people get adequate warnings to protect themselves. It’s important that emergency responders get readily available information to mitigate dangers when something is or might get free of its containment. It’s just that, well, handling them as add-ons doesn’t seem like it’s necessarily the best or most consistent way to communicate all this information.

This may be better understood if you try to construct a simple spreadsheet for transport classifications. ID#, PSN, technical name(s), Primary Class/Division, Subsidiary Hazards, and Degree of Danger (e.g. PG or category or type) seem like obvious choices for columns, and a nearly complete listing. But then, consider the add-ons. Columns need to be added for Hazard Zones, and for flash point, and for Marine Pollutant, and probably for physical state. But what do you do about things that change classification with size, such as RQ (or self-heating for that matter), or that change classification with temperature at time of offering, such as materials melted to get them into a container that may or may not be elevated temperature depending upon how long after filling the transport journey begins? All of a sudden a simple spreadsheet isn’t so simple any longer. 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.