AFAA-Dangerous Goods - Are you fully compliant or just barely meeting the intent?
August 26, 2010
By Mike Alston, CHMM- Owner Transportation Compliance Associates Inc

Do you know, unequivocally, that the personnel in your company that have responsibility to ship your dangerous goods (DG) by air have been trained properly and are fully compliant with the regulations? If not, you need to take heed now! The FAA issued a press release on August 6, 2010 naming 11 companies that received stiff fines for not properly shipping dangerous good by air. Read the entire press release at: http://www.faa.gov/news/press_releases/news_story.cfm?newsId=11678. As members of senior and middle management, you must STOP and fully understand the ramifications of not being compliant, especially when shipping DG by aircraft. Your company, you and the employees that actually ship the dangerous goods could and will be held liable for infractions of the regulations. These penalties range from $275-$55,000 for a civil penalty or unintentional mistake to a fine of $275,000-$550,000 plus it carries a five year jail term for any one knowingly and willfully violating the regulations. Folks, the Justice Department are serious and they should be! I was told by an FAA Special Agent that prior to 911 they spent 93% of their time in air terminals checking hazmat shipments and now since 911 they spend 87% of their time in the shipper’s office. Whether the figures are accurate or not, it shows the dramatic change in enforcement philosophy.

Since the attacks on the USA that occurred on 911, the scrutiny of DG shipments by air has increased significantly. Every company today is faced with poor sales figures and low or non-existent profit margins and preserving capital is a concern of every manager. However, this is not the place to cut costs. For many employers today, the loss of talent or the shuffling of talent due to the economic downturn has resulted in the elimination or displacement of large numbers of trained and capable individuals. Firms have tried to bandage the severely wound patient by placing minimally trained personnel in positions of tremendous responsibility. Others have taken shortcuts by asking untrained shipping personnel to take online dangerous goods training courses to satisfy the intent of the regulations. This may or may not meet the intent of the regulations to complete initial training followed by recurrent training every 24 months and it certainly will not make that person fully compliant and capable of shipping dangerous goods by air. In my opinion, online training should be used only by well seasoned, experienced shippers that need recurrent training and this would not be for the person’s first or second recurrent training either.

Manager must protect their company from potential liability by realizing the potential serious nature of this shipping process and tremendous responsibility that they place with their shipping personnel. This author strongly urges every manager to insure that their personnel are fully trained through a reputable classroom course initially and then every 24 months.

About the author:

Mike Alston served over 30 years as Corporate Hazardous Materials Manager for several major firms and now owns and operated Transportation Compliance Associates Inc (www.LearnHazmat.com).