I was younger then. Years ago…, heck, centuries ago…, wait, actually, due to Y2K, technically a millennium ago, I was young and there were drive-in movie theatres across the land. We were at a double-feature, and after the children’s movie would be the latest and greatest James Bond flick. We children were supposed to be laying down for sleep in the back of the car, but I just had to see what was so, so, so…, well, I didn’t know what it was that parents had to watch sans children. And sneaking a peek over the front seat was supposed to satisfy my curiosity.

Early in the movie some villain tried to kill James Bond by releasing a cobra into Bond’s hotel room. In the morning when Bond swung his legs off the bed and sat up, he was face-to-face, or maybe face-to-hood with the menacing cobra. I was fascinated, in part because I knew they couldn’t kill the hero this early in the plot. So, I knew James Bond would escape, but how? This all happened so long ago that actors were allowed to smoke cigarettes in movies. With reflexes faster than any mere reptile, James Bond grabbed his cigarette lighter and underarm deodorant spray from the bedside table, pressed the aerosol spray valve while striking his lighter, and used the resulting ‘blow torch’ to incinerate the cobra.

Looking back, I understand why I wasn’t supposed to watch the second movie. For I shared the information about the incredible properties of underarm deodorant spray with all my friends in the neighborhood, and of course, wasn’t believed until I reproduced the ‘flame thrower’, in secret, in the woods. Luck was with us that day, for the woods did not burn down, despite all the boys running around and trying it for themselves. Later in life I discovered that there is an astonishing array of aerosols with either flammable contents or flammable propellants, from underarm deodorant to disinfecting air freshener to shaving cream to bicycle chain lubricant to foot fungus spray. Who knew?

Well, actually we’re all supposed to know. When confronted with a leaking package of Consumer Commodity, whether ICAO’s ID8000 or the USA’s ORM-D, we’re all supposed to be able to open the box, see the inner containers, and immediately recognize the type of hazard. I’m not sure most transportation workers know the hazards of a fecal analysis kit, but almost everyone know why toilet cleaner, matches, drain opener, and rubbing alcohol are dangerous goods. Once we know the hazard class, the proper and safe clean-;up can take place, without any inappropriate over-reaction, such as waiting on non-sparking tools before cleaning up a spill of drain cleaner. And the system seems to have been working. I’m only aware of one fatality directly related to inappropriate response to a Consumer Commodity shipment problem. But, because ORM-D shipments are not subject to incident/accident/spill reporting, we don’t have data to prove the system’s been working, and it’s just my impression that it seems to have been working.

But things are changing, especially for road and rail. Now, it’s not just Consumer Commodities that are allowed to ship without an indication of the hazard class, it’s all Limited Quantities. Now, if there’s a spill from a box with a Limited Quantity mark on it, even looking at the inner containers may not be helpful. How many people in the transport chain know whether to use an acid neutralizer or a base neutralizer on a spill of DimethylDeadly? Does anyone know whether a puddle of TetraethylDontDoIt will start a fire if sawdust is spread on it as an absorbent? And who is aware that it might not be a good idea to use a wet mop to clean up the remnants of a spill of solid TrichloroBadStuff because it would cause a small cloud of poison gas? Well, sure, there’s less danger with a quantity that’s “limited”, but are we really willing to accept a limited fire, or a lesser cloud of poison gas, or a ‘not too large’ spattering and splattering from a failed attempt to neutralize a corrosive?

A few years earlier, when we harmonized excepted quantities, smaller amounts than limited quantities, it was decided that an indication of hazard class was necessary. Why now, with larger, albeit limited, quantities, is that type of hazard communication no longer important? Should I just be patient, and hold off on pondering these questions now? Will we have information in a few years that will provide answers to any concerns about these changes? No. No, because we’re not requiring LQ (LTD QTY) problems to be reported. In effect, we’ve already decided that a limited quantity is so safe we don’t need to gather data to prove it. Yet, I got more than a few long and spectacular flames from the limited quantity of underarm deodorant in that aerosol can all those years ago.

Oh yeah, it was the three preceding days of rain that kept the woods from accidentally burning down.

Written 2/26/2012 for HCB Magazine