Logistics Safety Issues to Consider When Introducing a New Hazmat
When manufacturers of hazardous materials introduce a new hazmat, they need to consider a number of logistics safety issues to ensure that subsequent shipments are safe, secure and compliant. The Logistics Safety function is ideally suited to lead the logistics safety new hazmat introduction process. (See Blog: 10 Ways the Logistics Safety Function Can Enhance Hazmat Practices.) The new hazmat introduction process can be organized by considering:
- Internal stakeholders and their processes
- External stakeholders and their needs
The issues to consider when introducing a new hazmat can be arranged under the following 9 categories. The specific requirements will vary depending on the hazmat and the supply chain that it will be introduced into. Here is a brief summary of some of the issues to consider.
INTERNAL STAKEHOLDER PROCESSES:
1. Administrative: The administrative procedures set the tone for the new hazmat introduction process. Specifically, is there a process to introduce a new hazmat in the company’s logistics safety management system? A checklist should be used to assign and track the completion of all tasks associated with a new hazmat introduction. Package filling and transport unit loading/unloading checklists are 2 other documents that may also need to be revised because of a new hazmat introduction.
2. Classification: Classification is a critical step because it will determine if the transportation regulations apply to the new chemical. If the regulations do apply, classifying the chemical will determine the proper shipping name, hazard class(es), UN #, packing group, authorized packaging, special provisions, labels, marks, placards and applicable limitations.
3. Packaging: Actions associated with the package include selecting the packaging type(s) to be filled, determining the minimum performance specifications, creating filling procedures, obtaining closure instructions from the manufacturer and selecting appropriate labels, placards and marks. If the package will be used multiple times, procedures must be in place for reuse, repair, reconditioning, etc.
4. Handling: Handling issues can include the need to prepare a new load securement diagram, the requirement for bonding and grounding during loading/unloading (e.g., applicable to flammable/combustible liquids) and the consideration of special provisions that may apply to handling.
5. Logistics Security: A new hazmat introduction can raise several basic security issues:
- Does the existing security plan address vulnerabilities related to the new hazmat?
- Is a security plan now required, or are new procedures needed in an existing plan?
- What security seals are going to be used to protect the package while in transit?
6. Training: A new hazmat will require safety training for those hazmat employees that prepare the hazmat for transportation. Training must include measures to protect employees from the hazards, procedures for avoiding accidents and emergency response training. Additional training could also be required if a new hazard class is introduced to the company or new hazard communication requirements (e.g., new marks) are needed.
EXTERNAL STAKEHOLDER NEEDS
7. Customers: Two important customer considerations are:
- Were customer handling procedures and sustainability goals considered in the selection of the packaging?
- Do customers require training on the handling of the hazmat or package?
8. Logistics Service Providers (LSP): Based on the initial assessment of the LSP and any subsequent training provided due to the new hazmat (e.g., load securement, segregation, storage and handling), the LSP should be formally approved to store or transport the new hazmat.
9. Emergency Responders: The following emergency response information should be developed or obtained for a new hazmat, whether distribution incidents are handled by contractors or employees:
- Immediately available emergency response information or the applicable Emergency Response Guidebook page
- Comprehensive emergency response and incident mitigation information
- Training on new requirements associated with containment, control or waste disposal
The introduction of a new hazmat should follow a deliberate process to manage all the regulatory requirements and company mandated considerations. The decisions and actions from the logistics safety review of a new hazmat introduction should be shared and ideally be part of a company-wide new chemical introduction process.