Oh my, that doesn’t sound too good, does it? I mean, it sounds like I’m a moron overwhelmed at planning a simple, intentional crime. “Well, you big ox, you put the goods in a box, and tell the carrier you’re shipping socks or rocks.” How hard is that?
But I’m not planning an intentional violation of the DG safety regulations, at all. I’m planning an audit. You know, where somebody with a checklist marches through your facility looking to see if everyone is properly trained, and if all the package certifications are current, and if closures are closed properly, and if paperwork is filed properly, and sometimes even checking to see if all of the outgoing products are classified properly. Yeah, I’m planning another typical DG audit, one of my first since leaving big business for tiny business. And something’s bothering me about the checklists I have. The all seem to focus on whether we’re doing properly classified products properly.
Okay, so if I’m on board with the 80/20 rule, or the 95/5 rule, or the 98/2 rule, or whatever numbers you choose, and yes, I’m on board with them, then why would focusing on the areas of greatest exposure bother me? Well, I can think of a couple of reasons. I can even hear one of my mentors, The Badger, thinking right now, “because you anal-retentive, former bank teller, you’re not satisfied until your till balances to the penny, and you’ve crossed every regulatory ‘t’ and dotted every regulatory ‘i’.” Which I suppose would also mean that I’m most happy with the 100/0 rule. But while that may or may not be part of it, I like to think the second reason is the major reason. The consequences of scrambling the sequence of the ‘basic description’ or using a flammable gas placard when a flammable liquid placard is called for, are not normally as serious as the consequences of undeclared DG can be. Surely, proper packaging helps make hazard communication errors moot, and proper hazard communication usually helps rapidly minimize the negative consequences of improperly packaged DG, don’t they? But what of untrained personnel shipping improperly packaged, undeclared DG? I think the potentially higher consequences make looking for even the lower frequency undeclared DG shipments a worthwhile exercise. So, I found myself asking, “how many methods for offering undeclared DG have I discovered in my career thus far?”
Well, let’s strike the ‘big one’ from the list immediately, because dealing with intentionally undeclared DG is a rather large topic in and of itself. Let’s just look at sources of unintentional undeclared DG.
- Returns of product from the customer. It doesn’t matter whether the pickup is by the original shipper, or by a contracted carrier (call tag), if the customer didn’t save the original packaging the return might be undeclared. A hospital once sent back concentrated Hydrochloric Acid re-packed into a Pampers diaper box!
- Returns of incoming raw materials. When the raw material doesn’t pass the quality tests for use in manufacturing a product, and it must be shipped back, there isn’t usually a transport classification in the system (because it isn’t a product), and the incoming packaging has often been disposed of. QC/QA has been known to just drop it in a box and ship it.
- Shipment of samples. When a customer offers to buy several batches of the largest size in the product line, but only if they can prove in advance that it’s high quality, it often turns out that the sample isn’t listed in the product transport classification list (which has different SKUs for different sizes), and the sample often doesn’t follow the channels fully prepared products do. Bench chemists have sent samples out through a mailroom, as if it were a paper copy of their latest scholarly journal article.
- Carriage of customer giveaways. It’s nice to keep the company name in front of potential customers, so sales people often take samples or gifts with them. But I remember when the mercury thermometers (DG) got replaced with toluene/alcohol thermometers (DG), which then got replaced with battery-powered (DG) digital thermometers, and all got taken aboard airplanes hidden in briefcases or suitcases.
- Carriage of R&D materials on a campus. If the monster-sized piece of analytical equipment is in a different building, is a scientist supposed to wait for classification of their new material, then packing and Hazard Communication, and finally pick-up and delivery? Yes, they’re supposed to wait, but they don’t, and sometimes they box it before driving it down the street, and sometimes they don’t.
- Pick-up from the local hardware store. Maintenance folks often believe that if it is okay to buy and transport for personal use, it’s just as okay to buy and transport back to work. Unfortunately, the aerosol can of anti-squeak is subject to the regulations when brought back to a commercial business, such as the maintenance folks workplace.
- Return of non-product related supplies. Quite often, incoming supplies aren’t transport classified, nor trained about, so that when the need to be returned they aren’t recognized as DG. The incoming Lead-Acid battery was unstrapped from the pallet, stored, and when needed, found to be several centimeters too wide for the forklift truck, and thus the battery got sent back undeclared, in exchange for one of the right size.
Well, they may not be the Seven Deadly Sins, but it looks like I’ve found seven important ways to update my DG audit checklists. All from pondering how to do something wrong!
How many ways can you ship undeclared Dangerous Goods?
Written 8/25/2011 for HCB Magazine