Sometimes I train students in non-bulk packaging, which eventually gets around to boxes. In a parcel handling environment that involves conveyor belts and/or automated sorting, a box could end up with any surface downward, even if only temporarily. So if an inner container were to leak inside that box, gravity would pull the contents, often liquid, downward, and downward could be toward any surface, depending upon where the box was in the sort process. So, how many sides of a box need cushioning, and maybe absorbent, inside them? All? Well, yes, all, but I want the number. A square has 4 corners and a cube has twice that, 8 corners. So, if a square has 4 sides, then a cubical box must have…, what, 8 sides? No, actually, even though it has 8 corners, cushioning is only needed on 6 sides of a box; top & bottom, left & right, front & back!

So, it took me a while to understand what he meant when one of my mentors would exhort me to think outside the box, think outside the 9 dots. I know about a box and 8 corners and 6 sides, but what’s that got to do with 9 dots? It turns out they are only related in concept, and they have no direct connection. There’s an old puzzle that has a grid of 9 dots, arranged 3 x 3 (three in each row and three in each column). You are asked to put your pencil on one of the corner dots, and without lifting the pencil, draw 4 straight lines, and only 4 straight lines, that cover all 9 dots. It can be done, but most people can’t figure it out, because the solution requires some of the lines go outside the perimeter of the dots. In other words, people mentally restrict themselves to staying inside the little 3 x 3 grid, when the rules don’t require that be done, and when a solution exists outside it! Oh. So, thinking “outside the 9 dots” is just another way to say “don’t box in your thinking unnecessarily”. Now, I get it.

Which brings us away from non-bulk, and to a previously thorny bulk issue.

The USA is concerned about large amounts of liquids that aren’t especially easy to set on fire, but which will burn. When, on the rare occasions that some does get set on fire, the sheer quantity of the fuel makes the situation worse, and if the packaging isn’t fire-proof, then such a large quantity of liquid can spread the fire over great distances. The US Department of Transportation (DOT) calls these Combustible Liquids, and to ensure that US carriers, forwarders, fire-fighters, longshoremen, emergency responders, cargo handlers, and port personnel are all informed about the potential hazard, the DOT requires that Combustible Liquid placards be affixed to bulk packagings containing them. At first glance, this seems to make sense, using an established system of hazard communication for this related hazard. But, for whatever reasons, perhaps because of the subtle difference between flammable liquids (easy to light, plus, problems when aflame) and combustible liquids (problems when aflame, but unlikely to end up aflame), the rest of the world has chosen to leave combustible liquids out of the various sets of Dangerous Goods regulations.

The USA can regulate what it wants to regulate, as can each other State (country) in the world, and as long as transport is just domestic in each country, there aren’t significant problems. But, placarded bulk containers of Combustible Liquid leaving the USA cause problems for every country receiving those containers. And unplacarded bulk containers of Combustible Liquid entering the USA can cause problems. These problems aren’t new, and many different parties have asked the US DOT to try to solve them. To this point in time, at least so far as I can determine, fixing the problem within the existing system isn’t working. Changing the US hazard definitions to exclude Combustible Liquids from the HazMat regulations is unacceptable, because the USA wants hazard warnings. And removing the placarding requirements is unacceptable, again because the USA wants the hazard communicated. So, it’s time to think outside the box, to think outside the 9 dots.

As I ponder this from my porch swing, I wonder why we have to use only the existing hazard communication system for DG, and exactly as we’ve been using it? Couldn’t there be some alternate form of warning that would be recognized in the USA, yet would not cause problems outside the USA? It’s not like this hasn’t been done before. When the USA regulated ‘toxic by inhalation’ before the rest of the world did, the USA required large font text on these materials, so instead of “INHALATION HAZARD” couldn’t we use large text saying “COMBUSTIBLE LIQUID”? When ICAO wanted a ‘UN’ identification number for consumer commodities they had to create ID8000, so why couldn’t we have, and mark, in large font, ID1993 or some other appropriate ID numbers? When the world wanted warning for marine pollutants, we started with a triangular mark, so why couldn’t DOT adopt a star-shaped, or triangular, or flame-shaped, large mark for Combustible Liquids? Surely, creative minds can find a way to communicate the combustible hazard in a way that won’t be confused with a Flammable Liquid placard. Maybe there even need to be different domestic and international hazard communication options, much like the current 49CFR HazMat Table column 1 entries of “D” and “I”. But surely we can get this item off the regulatory agenda if we try to disregard the artificial limitations on our thinking.

Yes, let’s make a box with 9 dots.


Written 12/26/2011 for HCB Magazine