Madam, I’m Adam.
Oops, I wrote that backward. It should have read madA m’I ,madaM. Oh, wait, if we ignore the punctuation marks and spaces, it still says the same thing! It’s one of those palindromes, meaning it’s the same in either direction. Sort of like the current state of affairs for Dangerous Goods shipments. No matter which direction the travel, the rules are the same. Not only do I mean that East to West shipments have the same rules as West to East shipments, I am also referring to the directions in a supply chain or logistics chain.
Right now the rules are the same for a supplier shipping to a customer as they are for a customer shipping to a supplier. But, perhaps, it could be that returns, the shipments from a customer back to a supplier – also known by the fancier term ‘reverse logistics’ – may get some regulatory relief. Returns may get a break from some training requirements, or from some packaging requirements, or from some paperwork requirements. Who knows what will actually happen, but I’ve certainly heard a wide variety of opinions and proposals. So I started remembering some returns that I’ve experienced, and pondering what might be learned from them.
There was a hospital that wanted large bottles of concentrated hydrochloric acid for their labs and received large bottles of concentrated sulfuric acid instead. The error wasn’t discovered until the acid had been removed from the packaging, the packaging discarded, and the bottles put away on a shelf. So, the return shipment didn’t get packaged into the sturdy UN-specification packaging it had arrived in, and instead go packaged into a box that happened to be available at the shipping & receiving dock, an empty diaper box. Sorry Huggies, it was a crumpled and torn Pampers box still barely around the bottles of acid when they arrived back to the supplier.
Another customer in a similar situation didn’t have the original packaging available to return the bottles of methanol they didn’t want, so they just used an incoming package of ethyl acetate instead. So the methanol arrived back to us marked ethyl acetate, and with ethyl acetate’s ID# instead of methanol’s ID#. I never did manage to get a copy of the shipping paper used, but it had to have been non-compliant. It either didn’t match the package marks or didn’t describe the actual contents.
There was a return I’m not sure whether to smile about or not. Two employees were arguing about an incoming return in a plain brown box. Neither wanted to open it, one because she thought there was a rattlesnake inside due to the intermittent buzzing that could be heard coming from the box, while the other employee thought she heard more than just buzzing, and believed that there was a squirrel “or some other furry critter” in the package. I smile because, as I cut open the tape across the top of the box, I emitted an abrupt and loud “OH!”, and both the women instantly jumped back several feet. My smile didn’t last long as I removed the quite warm, but to be honest not hot, battery operated equipment that was repeatedly cycling through its auto-calibration program. Of course, it had to be “repeatedly”, because it wasn’t hooked up to any calibration standard. Our outgoing shipment had been with batteries in slots in the rigid foam cushioning of the package, but apparently the customer installed the batteries before deciding to return it.
Not all the returns I ponder are packaging related, however. We sent a fully marked and labeled hazmat in a UN-specification packaging to our customer via UPS. When the customer asked to return it unopened, our customer service rep arranged for the customer to have a UPS “call tag”, which was to ensure that we, not the customer, paid for the return freight charges. All fine, except that UPS doesn’t accept DG from anyone, in any direction, unless the offeror has registered with UPS as a HazMat shipper. Because the customer was a DG receiver, but not a DG shipper, UPS refused to accept the call tag and package. So, the customer, bound and determined to be rid of this unwanted material, simply overpacked the whole package into a plain, brown box, and re-offered it to UPS the next day. With no visible indication the box contained hazmat, UPS accepted and delivered the now intentionally undeclared return! My employer didn’t think it would be good for business to report our customer to the authorities for this criminal, albeit safely packaged, violation of the regulations, so we didn’t.
I could go on, but column space is limited, and my next five returns involved DG that was respectively, leaking, leaking, leaking, leaking, and yes, leaking, at the time the customer re-introduced the goods into the transportation system.
Maybe there could be some regulatory changes that would make these ‘reverse logistics’ shipments safer. About the only thing that comes to mind would be allowing the use of salvage drums for them. Certainly salvage drums are easy to use, have a proven safety record, and are much stronger than a Pampers box. But what other regulatory relief should be offered to re-shippers?
Based upon the many thousands of DG shipments I’ve witnessed, and the hundreds of ‘reverse logistics’ DG I’ve had the opportunity to inspect, I’m not sure that additional exceptions are the answer. Who truly believes that safety will improve by reducing the communication requirements for reverse logistics? Will fewer marks, labels and placards make safer a shipment that is already more likely to be leaking? Who thinks packaging levels will improve or communication regulations will be more frequently complied with if we reduce training requirements. And how should all the safe and compliant shippers feel about the non-compliant, un-safe shippers being the ones to get breaks from the regulatory burden?
The goods don’t know which direction they’re being shipped, and pose the same dangers in both directions, so with the possible exception of making it easier to use stronger packaging on ‘reverse’ shipments, shouldn’t our safety protections remain palindromic? My answer: “is sí”.
Written 8/15/2012 for HCB Magazine