Heck, I wrote it. You may have heard the United Kingdom and the United States referred to as “two countries divided by a common language”. Even if you haven’t heard it, I believe there is some truth to it. I found myself in a DGSA preparation class with some American students and a British instructor. Even though both the students and the teacher supposedly spoke the same language, English, there were some amusing miscommunications. Some words just have different meanings on different sides of the Atlantic Ocean. In the UK, boots and bonnets refer to locations on an automobile, but in the USA, boots and bonnets are items of apparel. In the USA a kit is a baby fox or a collection of disparate items, but in the UK it means equipment or required supplies. Of particular humor to the American students was the ADR requirement to have scotches on certain vehicles. The Americans read the requirement and thought ‘Scotch whiskey’, not wheel chocks, so you can probably understand their amusement. And don’t get me started on the terms “knock you up”, “bloody”, or “rubber”. So, partly for amusement’s sake, but mostly to facilitate communication between trainer and trainees, I created an English to English dictionary.
What I need now, though, is some cultural translation. Sometimes on the porch swing, my mind wanders back to a given topic repeatedly, and I take this as a sign that the particular issue must be particularly important to me. One of these is combustible liquids. Since I don’t deal directly with them any longer, except for the occasional client, I tried to figure out why they were a mental boomerang, and kept returning to my mind. And then, upon my attendance at the DGAC (Dangerous Goods Advisory Council) annual conference in Nashville, USA recently, the answer occurred to me. It seems to me that all of the people and organizations attempting to fix the issue of international shipment of bulk liquids with no hazards other than flash point between 60C and 93C are Americans. I’m sure that “all” is not accurate, but it sure appears to be close to all. And why? That’s what’s bothering me, why aren’t non-Americans doing more?
For shipments completely within the United States, there’s no real problem, and for shipments that don’t start, pass through, or end in the United States, there’s no real problem. But for shipments of these combustible liquids to or from the USA, there are problems at both ends. Shipments into the USA are supposed to be labeled or placarded in the originating country, but the originating country doesn’t recognize that hazard class. And if the shipper doesn’t label or placard, then the shipment is non-compliant before it’s even unloaded from the ship in the USA. Going the other direction, most US shippers apply the labels or placards, but then there’s confusion in the receiving country about these warning labels and placards that look like flammable liquid labels and placards, but aren’t.
Now don’t get me wrong, I’ve heard plenty of complaints from shippers, carriers, and receivers on the northeast side of the Atlantic Ocean about the costs, delays, and just plain irritation that bulk combustible liquids cause. I’m even starting to hear more of the same from the Asia Pacific region. But I’m not seeing action from any of these places. Why haven’t I read a UN paper proposing to make any placards or labels that could be confused with Class 3 non-compliant? Why haven’t non-American safety groups or trade associations made their views known by submitting petitions and comments to PHMSA, the sub-group of the US Department of Transportation that makes the DG rules in the USA? PHMSA is supposed to consider whether their rules and regulations stifle international trade, and if they do, they’re supposed to amend them accordingly. I don’t know why DGAC and DGTA (Dangerous Goods Trainers Association) aren’t hearing their non-American members screaming for action. What am I missing? Are we expecting the UK DfT to speak up on our behalf? Are we inaccurately convinced that PHMSA won’t listen to us if we’re not from the USA?
PHMSA will listen, if international shippers and carriers and freight forwarders speak up about the burden that the US combustible liquid regulations place upon them. They will pay attention to the squeaky wheel, and they’ll be influenced by £, ¥, and € data (although conversion to $ may help). Or is it that hearing complaints has over-inflated my estimation of the extent of the problem? I think not, and I think that we’d love the US to get rid of, or significantly change the combustible liquid regulations. I also think we don’t know how to go about helping that to happen. In the USA, affected companies speak up. Elsewhere…? Not so much.
How can we translate our different approaches into a single set of mutually beneficial regulatory changes? I can translate some words from English to English, but sometimes I need some help with understanding larger, cultural issues.
Written 10/18/2012 for HCB Magazine