Yeah, I admit it. They’re not so bad after all. As long as we’re not discussing an action against one of my clients, I’ve even enjoyed talking with a variety of different transportation Enforcement officers. Occasionally, I learn something new, and often, we find that having the same overall purpose, improving HazMat (DG) transportation safety, is enough common ground to keep us chatting for hours. Okay, okay, the fact that many times the conversations have been accompanied by some elbow bending may have contributed to my willingness to ‘fraternize with the enemy’. Seriously, though, I think I’m a better trainer and better consultant for having spent time socializing with the Enforcement division.
One particular thorn in the side of some Enforcement personnel is all the undeclared DG shipments made by those who sell on eBay and similar websites. Unlike a flea market, from which a customer may themselves transport home their purchases over roads and under personal use exemptions, most eBay sales of DG are shipped in commerce by the seller, quite frequently via airplane, and almost always, at least as far as we can measure, undeclared. And most of the attempts at enforcement seem to have a limited deterrent effect.
I’m not sure the solution, though, is really enforcement. Not that enforcement isn’t crucial, but in my opinion, the root of the problem needs to be addressed through Outreach rather than through Enforcement. In my opinion, the general public has no clue they may be shipping undeclared DG, because the general public believes that if you can buy it in a store it can’t be HazMat. Any distinction between personal use and “in commerce” is lost when it comes to the general public and their life-long habits of transporting Dangerous Goods as ‘just stuff’.
Air travel warnings to passengers just reinforce the misconceptions about what is regulated as DG. One of my all-time least favorites is a poster from PHMSA in the US that has great big letters proclaiming “FEDERAL LAW FORBIDS … HAZARDOUS MATERIALS aboard aircraft”. While they do have the obligatory small print, legal disclaimer buried within the poster that addresses the toilet articles exception, everyone gets the idea that HazMat isn’t allowed on airplanes. What PHMSA doesn’t seem to get though, is that the general public knows that their aerosols and their perfumes and their matches and their batteries and their other batteries have been screened and x-rayed and checked, and they were ALL permitted. Obviously, if those items were permitted, then they can’t possibly be HazMat, cuz HazMat is forbidden.
Lest I be picking on PHMSA though, let me say that postal service and parcel carrier posters and warnings aren’t much better. Carriers and postmen are slightly more likely to identify aerosols and perfumes as DG, but often overlook batteries and battery powered equipment. And all of the poster creators commonly mis-identify common, household strength bleach as HazMat, (it is neither corrosive nor oxidizing, and isn’t acutely toxic enough to be 6.1), which reinforces another common misconception, that only ‘chemicals’ can be DG.
How can we all reasonably expect the general public to declare eBay DG shipments as DG, if our institutional warnings all reinforce, instead of dispelling, the myths that if I can buy it in a grocery or hardware store it can’t be DG, and only ‘chemicals’ can be DG? We can’t. We need to ensure our institutional warnings and posters are misunderstood by the target audience. Maybe we need to have drafts reviewed by the general public instead of by lawyers, sort of like pre-screening any other sort of advertisement. But, from the perspective of my porch swing, the root of the eBay, undeclared DG problem is a vast misunderstanding of what DG really is.
Communicating with Enforcement personnel, at the right time, about the right topics, can be productive, educational, and even downright enjoyable. Now, if we can just get their colleagues in Outreach, and our parcel-carrying colleagues to communicate to the general public as effectively, we could all enjoy a reduction in undeclared DG.