“Oh, no, I’m not. I’ve got 2 minutes to spare”, responds my teenager. “Not on a week night”, I answer, “you’re nearly two hours late”. “Get a clue, Dad, there’s no school tomorrow. So, I’m on time”. “It’s still a week night, though, and you’re past the week night deadline”, I say, trying not to get too grumpy. My teenager has less restraint, though, and angrily shouts “Mom says the rule is for school nights, not week nights. How are we supposed to follow the rules if you two don’t let us know exactly what the rules are?” Silence. How can I refute that point?
I recently got a ticket. I sometimes drive a tad rapidly, but no, not that kind of ticket. I purchased an airline ticket from one of the biggest passenger airlines in the world, for travel within the United States. As part of the notifications that came along with my ticket was a notice that regulations dictate that “HazMat is forbidden for carriage”. What? Are you kidding me? HazMat isn’t forbidden from surface transport, as many railroads and trucking companies can attest. HazMat isn’t forbidden from air transport, as some parcel carriers could tell you. HazMat isn’t even forbidden from passenger aircraft, as indicated by a couple of the columns in the ICAO Dangerous Goods List. In fact, the airline let me carry on HazMat, and use HazMat in flight. So, why the clearly untrue notice that HazMat is forbidden for carriage?
Many times I begin a DG class by asking if everyone remembered to bring some DG with them. Usually I get blank looks in return. Then I ask the bewildered students, “Surely someone has some HazMat with them that they intend to rub on their skin later today, don’t you?” And almost always it turns out that someone has flammable hand sanitizer with them, yet didn’t think of it as DG. Then we turn to the DG that almost everyone has with them, although you don’t rub these on your skin. In most classes, there has been a student that catches on quickly, who can point out the lithium batteries that power our watches, cell phones, and laptop computers. Even in recurrent classes, it’s usually necessary to remind the students that the definitions of “dangerous goods” and “hazardous materials” include many substances or articles that people don’t generally think of as DG or HazMat.
But it’s not just carriers and untrained students that don’t always have a grasp of what’s regulated, sometimes the regulators themselves don’t know what they don’t know. A little internet searching will show you that some regulators still tell the public that household strength bleach is a DG. Sure, there was a famous airplane incident with concentrated industrial bleach, but that’s different than household bleach. And probably the world’s biggest brand of household bleach used to ship it as if regulated, because they assumed it was regulated. But when they modified their product to make it slightly stronger, they actually tested it. Household strength bleach doesn’t start fires, it doesn’t feed fires, it doesn’t corrode skin, it doesn’t corrode steel fast enough, and it doesn’t corrode aluminum fast enough. So, household bleach is not 5.1 and not 8, and is not regulated as DG or HazMat, despite what some ‘competent authorities’ are communicating to the public.
Unscientific pondering from the swing has led to a determination of the three most common DG misconceptions held by the public.
- HazMat = HazWaste. When I tell anyone what my job is, the most common response is that it is wonderful that someone is willing to deal with hazardous waste, because they themselves would be too frightened to deal with such nasty stuff. Oh, my. I’m sure we “experts” all know that quite a bit of HazMat (DG) isn’t waste, but apparently the general public doesn’t know this.
- If I can buy it in a grocery store, it cannot be DG. Clearly if hand sanitizer and batteries can be bought in many grocery stores, then DG is sold there.
- Only chemicals can be HazMat. Batteries are articles, and not chemicals. Alcohol wipes aren’t bottles or jars of chemicals. Pressurized struts and shock absorbers aren’t chemicals. Fireworks are articles, articles that may contain chemicals, but still articles. Self-inflating life rafts. Fuel cells. Matches. Do I need to go on?
We all want safety. But if one of world’s biggest passenger air carriers e-mails BS to the general public, and if some of the regulators don’t communicate accurately, then how is the public to know what’s DG? If the public doesn’t know what’s DG, how can we expect them to comply with DG rules? And not just carrying DG on planes or HazMat in luggage, but whenever offering a shipment to a courier. I know of an administrative assistant that got a multi-billion euro company in trouble for sending toiletries overnight, undeclared, via parcel carrier to a vice-president whose luggage had been lost. If the public can’t comply with DG regulations, because we can’t explain to them what is DG and what isn’t DG, then how are we going to get the safety we want? My teenager was late (or not) because her parents didn’t make the rules clear and understandable. The consequences though, of HazMat undeclared through ignorance or confusion can be much worse than those of a late-arriving teenager. We, regulators, carriers, consultants, trainers, security folks, and anyone else involved in DG had better get our message clarified and accurate.
Better late than never. Better now than later.
Written 5/01/2012 for HCB Magazine