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For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Cargo Securement for Chemical Distributors This webcast.

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Presentation on theme: "For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Cargo Securement for Chemical Distributors This webcast."— Presentation transcript:

1 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Cargo Securement for Chemical Distributors This webcast will cover... DOT Cargo Securement requirements for bulk and non-bulk hazmat CSA and the Cargo BASIC Roadside inspections and the top cargo violations Accident liability and cargo loss Driver training Moderator Mike Lang, Vice President, Responsible Distribution, National Association of Chemical Distributors Presenter Tom Bray, Sr. Editor - Transport Management, J. J. Keller & Associates, Inc. Attention Attendees: +Thank you for attending! +The presentation will start in a few minutes at 1:00 PM Central. +Please use your computer speakers to listen to the event. If you have audio issues, dial-in info is below. +You will be muted during the event. +Please use the Question feature to text questions to Q & A. Well try to answer them during the Q&A period if they are not covered in the presentation. +The slides and recording will be posted in 7 days at: http://www.jjkeller.com/cbdawebcasts

2 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Mike Lang Vice President, Responsible Distribution National Association of Chemical Distributors

3 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Introductions DOT Cargo Securement requirements for bulk and non-bulk hazmat CSA and the Cargo BASIC Roadside inspections and the top cargo violations Accident liability and cargo loss Driver training Question & Answer Housekeeping issues: You will be muted during the event. Please use the Question feature to text questions to the Q&A Panelist. Well try to answer them during the Q&A period if they are not covered in the presentation. If you lose sound at any point, you can dial-in by phone using the number and Pass Code listed below. If you lose the program window and need to re-login be sure to enter a different e-mail address to avoid being denied access for multiple logins. Mike Lang NACD

4 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Disclaimers The content in this webcast is intended for information purposes only and should not be construed as providing legal advice. If you ask questions based on your unique circumstances, we will attempt to address them from a more general perspective. This is an introductory course and is intended to highlight critical safety and compliance topics. Time constraints limit our ability to go in depth. Mike Lang NACD

5 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Tom Bray Sr. Editor – Transport Management J. J. Keller & Associates, Inc.

6 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Cargo Securement According to 49 CFR §391.13, drivers must understand the vehicle inspection and securement requirements found in Parts 392 and 393 of the Federal Motor Carrier Safety Regulations (FMCSRs). Tom Bray J. J. Keller & Associates, Inc.

7 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 392.9 All cargo must be properly distributed and adequately secured Inspect the vehicles cargo and load securing devices within the first 50 miles Reexamine again after 3 hours, 150 miles, or next change of duty status (whichever comes first) Tom Bray J. J. Keller & Associates, Inc.

8 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 393 Aggregate working load limit Anchor point Blocking Bracing Dunnage Friction mat Shoring bar (or load bar) Tiedown Working load limit (WLL) Header boards Cargo covers (tarps) Sealed container loads Tom Bray J. J. Keller & Associates, Inc.

9 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Compliance Safety Accountability (CSA) Overview CSA is an enforcement system for: Tracking, measuring, and evaluating carrier and driver compliance and safety performance Increasing the carrier contact frequency Rating all carriers (will require rulemaking) CSA tracks: All carriers regulated as an interstate carrier that have a USDOT number, regardless of type (and their drivers) Intrastate carriers that have a DOT number Tom Bray J. J. Keller & Associates, Inc.

10 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 CSA Process Data collection (roadside inspection, interventions, crashes) Safety Measurement System (SMS) Seven BASICs (Behavior Analysis and Safety Improvement Categories) Unsafe Driving (Parts 392, 397, etc.) Fatigued Driving (Parts 392 and 395) Driver Fitness (Parts 383 and 391) Controlled Substances/Alcohol (Part 382 and 392) Vehicle Maintenance (Parts 392, 393, and 396) Cargo Related (Parts 392, 393 Subpart I, and HM regulations) Crash Indicator Comprehensive and progressive interventions Tom Bray J. J. Keller & Associates, Inc.

11 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 SMS Process Measures and compares safety performance using all safety-based violations discovered during roadside inspections and interventions, and DOT-recordable crashes All violations are severity and time weighted Severity Weight - Violations 1-10, Accidents 1-3 Time Weight - 0-6 months = 3, 6-12 = 2, 12-24 = 1 Full value is determined by a formula that multiplies the weights Once per month, scores are totaled, normalized, and used to percentile-order carriers in BASICs versus peers in Safety Event Groups Carriers with percentiles that exceed the BASIC thresholds will be targeted for intervention Tom Bray J. J. Keller & Associates, Inc.

12 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 BASICHazmat Unsafe Driving Fatigued Driving Crash 60% Driver Fitness Drugs/ Alcohol Vehicle Maintenance Cargo-Related 75% Complaints and crashes can lead to investigative interventions as well Intervention Thresholds Tom Bray J. J. Keller & Associates, Inc.

13 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 CSA Intervention Process Tom Bray J. J. Keller & Associates, Inc.

14 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Interventions Early Contact Warning Letter Carrier Access to Safety Data and Measurement Targeted Roadside Inspection Investigation Offsite Investigation Onsite Investigation – Focused Onsite Investigation – Comprehensive Follow-on Cooperative Safety Plan Notice of Violation Notice of Claim Operations Out-of Service Order Tom Bray J. J. Keller & Associates, Inc.

15 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Intervention Scoring Based on violations of serious regulations discovered during audits and investigations Will not improve BASIC Score, but can flip a BASIC Safety Evaluation to Alert (regardless of BASIC Score) Tom Bray J. J. Keller & Associates, Inc.

16 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Cargo Related Violations Violations that effect BASIC Measure and Score : Damaged or loose tiedown Failing to secure vehicle equipment or load HM placard missing, damaged, or obscured HM package not secure Shipping paper errors Discovered during auditing: Security plan problems No shipping paper for HM shipment Accepting and transporting HM not prepared properly Failure to maintain copies of cargo tank certificates Tom Bray J. J. Keller & Associates, Inc.

17 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Common Hazmat Violations - Roadside Tom Bray J. J. Keller & Associates, Inc. VIOLATIONNUMBERSEVERITY Size and weight199,456 -- No or improper load securement13,981 10 Damaged securement system/ tiedowns12,495 7 Failing to secure vehicle equipment10,805 7 Failing to secure load8,719 7 Loose/unfastened tiedown.7,656 8 Leaking/spilling/blowing/falling cargo7,653 10 Insufficient tiedowns7,136 8 Driver load securement5,611 10 Heavy vehicle/machine securement5,418 10 Placard damaged, deteriorated, or obscured3,736 5

18 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Common Hazmat Violations - Roadside Tom Bray J. J. Keller & Associates, Inc. VIOLATIONNUMBERSEVERITY Placard damaged, deteriorated, or obscured3,736 5 Package not secure in vehicle3,147 10 No Copy Of Cert Of Registration Or Registration # On Subject Vehicle3,006 -- Vehicle not placarded as required2,977 5 Failing To Provide Carrier Required Placards2,151 -- Shipping paper accessibility1,784 3 No shipping papers (carrier)1,577 3 Emergency response (ER) information missing1,573 3 ER information not available1,208 3 Offering HM Without Preparing A Shipping Paper1,183 -- Placard damaged, deteriorated, or obscured3,7365

19 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 CSA How to Survive Existing data can be viewed at: CSA SMS http://ai.fmcsa.dot.gov/SMS FMCSA Portal https://portal.fmcsa.dot.gov/ Get wrong data out of the system Learn and be willing to use the appeals processes: Federal DataQs - https://dataqs.fmcsa.dot.gov/login.asphttps://dataqs.fmcsa.dot.gov/login.asp State Motor Carrier Safety Office CVSA Complaint Process Tom Bray J. J. Keller & Associates, Inc.

20 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Common HM Violations Discovered During Auditing Security plan problems (no plan when required, plan not current, plan not trained on, etc.) No shipping paper for HM shipment Accepting and transport HM not prepared properly Failure to maintain copies of cargo tank certificates (original, reman, testing) Tom Bray J. J. Keller & Associates, Inc.

21 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Preventing Cargo Related Problems Train, train, train Make sure drivers: Know what they are doing Know to ask questions Have replacement procedures for defective equipment Provide drivers with hands-on information Handbook Cheat sheets Support numbers (expert and/or mentor) Tom Bray J. J. Keller & Associates, Inc.

22 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Securement Components Tiedowns can be repaired Must remain tight while in transit Must be adjustable (except steel strapping) Cant contain knots Edge protection may be required Straps can go outside the rub rails Lever-type binders are acceptable You can choose the tiedown type Tom Bray J. J. Keller & Associates, Inc.

23 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Driver Training: Loading, Unloading, and Freight Inspections Never leave cargo unattended Never use an unauthorized individual to load/unload the vehicle Check skid/package count before leaving Make sure freight is properly described and in good condition Immediately report discrepancies (if not corrected, note on bill of lading) Be aware of signs of damage Look for signs of tampering (broken seals, damaged tape) Tom Bray J. J. Keller & Associates, Inc.

24 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Driver Training: Maintain Accurate Vehicle and Cargo Information Vehicle identification, license, and serial numbers should be with the driver at all times Cargo information (lot numbers, types of containers used, markings, inventory numbers) should be with the driver at all times Tom Bray J. J. Keller & Associates, Inc.

25 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Driver Training: Stopping Procedures Be aware of areas traveling through Plan stops Avoid unauthorized stops Never stop in the same place at the same time Stop at populated locations Park in well lighted areas Avoid dark, secluded areas Avoid conversations with strangers Tom Bray J. J. Keller & Associates, Inc.

26 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Driver Training: Seals and Locks Cargo seals expose any signs of load tampering, and locks help prevent theft A log of inbound and outbound cargo seal and lock numbers should be kept Date and time Number of trailer Destination of load Name of person applying Name of vehicle driver Record appropriate information if seal/lock is removed/broken Tom Bray J. J. Keller & Associates, Inc.

27 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Driver Training: Handling Vehicle/Cargo Theft Call the police immediately Give as many details as possible License number(s) on equipment Equipment serial number(s) Vehicle description Cargo description Time incident occurred Description of suspicious people near vehicle Notify the company Make sure driver has this information with them whenever they leave the vehicle unattended! Tom Bray J. J. Keller & Associates, Inc.

28 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Question & Answer Please submit questions to Q&A using the Question tool Tom Bray J. J. Keller & Associates, Inc. Mike Lang NACD

29 For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130 Closing Remarks Thank you for attending! Please complete the survey. In 7 days, download the recording and slides from todays webcast at: http://www.jjkeller.com/cbdawebcasts http://www.jjkeller.com/cbdawebcasts Upcoming NACD events: February 28: The Clean Air Act Section 112(r) General Duty Clause - What You Need to Know Webcast March 27: Product Segregation in the Warehouse – EPA Expectations and Resource Guidance Webcast April 2-3: Responsible Distribution Workshop (Houston) Mike Lang NACD


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