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For the next 60 seconds, when I start this stopwatch, you may think of anything you want, except Pink Elephants. You may not create mental pictures of pachyderms that are pink instead of grey, you not allowed to think of the alcoholic drink, and you cannot even let the sound or the letters of the words Pink Elephant enter your mind. Ready, go.

Or… Don’t worry about this major academic test, honey. Whatever you do, don’t track your progress or grade yourself or worry about the previous difficult question while you are still taking the test, or you won’t correctly answer the next question either. In other words, I predict that you’ll be too nervous to do well.

We’re probably all familiar with the concept of self-fulfilling prophesies, wherein the act of predicting itself influences the outcome. When I was a camp counselor, I used to use it in a positive fashion. Because I had the second-oldest cabin of boys, we always had to contest the ‘tug-of-war on the lake shore’ against the oldest boys. Older boys, of course, are usually a bit bigger and a bit stronger, making them more likely to win a tug-of-war. So, I would always make a friendly bet with another counselor, being certain to do it in front of my boys, that my guys would win the tug-of-war. Armed with the confidence that comes from knowing people believe in you, my under-sized, scrawny cabin of boys almost always whipped those older boys, often pulling them off their feet. B-6 rules!

But self-fulfilling prophesies usually work in the other, negative, direction, like the Pink Elephants or the big test. Just by itself, the act of predicting often causes negative consequences. So, what does this have to do with Dangerous Goods?

Let’s start in the USA. RSPA, PHMSA’s predecessor agency predicted that consumer products wouldn’t pose significant risks in transport, so they didn’t require placards for full truckloads. But there was an accident with a load of flammable consumer goods, and the responders were not prepared when what started as a small fire suddenly accelerated into a huge, uncontrolled blaze. It burned so quickly and so fiercely, and the responders were so unprepared for the fire’s intensity, that they were unable to finish removing the truck driver from the cab of the tractor, and the driver perished in the flames. But if you attempt to discover how often this kind of problem occurs, you probably won’t be successful, because RSPA had also predicted that there would be no need to keep safety statistics for Consumer Commodities, so such incidents are not required to be reported. Wow, because they predicted a very high level of safety, we now have no way, no data, and no statistics to judge the quality of that decision, nor to evaluate the possibility that maybe the level of safety isn’t quite as high as predicted, and maybe not high enough.

To be fair though, the USA is arguably the best country in the world at requiring DG accident, spill, exposure, and release data to be reported. Most other countries, or even entire continents, do not formally require the reporting of releases or incidents involving dangerous goods. We often don’t require it for ‘fully regulated’ dangerous goods, so of course, we don’t require reporting for ‘partially regulated’ dangerous goods, either, such as limited quantity. Well, of course not, some of us say, we don’t have reporting requirements because we’ve already prevented any incidents, merely by having DG regulations in place. Why should we bother collecting statistics to prove what we’re already sure we know, that the DG regulations work effectively.

The answer is that perhaps we don’t know what we don’t know. Perhaps the long, admittedly anecdotal, lists of spills and fires around the world, that are compiled by non-governmental entities, show that we could be doing better, but that we don’t officially ‘know’ this, because we aren’t systematically collecting this information through government channels. Maybe, in general, our packaging systems work well in most respects, except for closures, which could use some regulatory tweaking. Or maybe it’s possible that there are so many small problems with little shipments that cumulatively we have a big problem. But we don’t know it, can’t know it, and don’t have information to correct it, because of our initial prediction (a.k.a. assumption or presumption) that we wouldn’t have any problems.

Even worse, we’ve been using our lack of data indicating problems to convince ourselves that everything’s fine, and so we’ve been expanding the scope of certain exceptions, allowing even more HazMat to ship with fewer regulatory controls. No, we can’t show that expanding LQ (LTD QTY), for example, will exacerbate existing problems, but we also cannot show that it won’t make things worse, either.

It’s been said that if you can’t measure something, then you can’t control it. Let’s measure, via required reporting, all DG releases and problems, so that we can have the data that will help us control and prevent them. Yes, our DG regulations provide major improvements in safety over not having regulations, but are we where we want to be? Is improved safety, always sufficient safety? It’s too late to ask the driver of that truckload of unplacarded consumer commodities what he thinks about it.

The prediction that regulations without reporting will be sufficient isn’t a pink elephant, but it’s probably a white elephant.

Written 7/09/2012 for HCB Magazine