I admit it. I am a hazmat nerd. I’m not sure exactly when I realized it. Maybe it was the first time I recited a section of 49CFR from memory during a class. Maybe it was when I decided to keep a copy of the ERG in my car so I could identify the UN numbers on placarded trucks. Regardless of when it happened, I now embrace my hazmat nerdiness… even my Facebook profile lists my occupation as “Hazmat Nerd”. Obviously, this is a great benefit when I’m on the job. I have a knack for remembering obscure requirements and knowing where to find them in the appropriate regulation. I enjoy hunting down the answer to tough questions or unusual situations. I like having customers who think of me as their go-to source for their questions.
One aspect of being a hazmat nerd is that I am always noticing things that relate to my job, even when I’m not at work (hence the ERG in my glove compartment). There was the time that I was doing some geocaching (my obsession…I mean hobby) in Buffalo. I had parked the car and jumped out to go find a cache. On my way, I had to dodge some large puddles due to a recent downpour. As I approached one of the puddles, I noticed something odd. There was a Flammable Liquid placard floating in it! Most people would have just walked past it. Not the hazmat nerd! I took a closer look…mainly to see if it was one of our placards. Then I took a picture, because who wouldn’t want to see a picture of a placard in a puddle? I continued on my way, trying to figure out what circumstances would result in a placard floating in a puddle in the middle of a sidewalk. I still wonder about that…
Another time, I pulled up to a gas station and saw 2 IBC’s of paint sitting alongside the building. Once again, they would have gone unnoticed by most people. I however, took a picture!
On one of my many road trips, I made a stop for some fuel for both myself and my car at a truck stop. While walking around to stretch my legs, I came across something I had not seen before…a stop for leaking hazmat vehicles. It made sense that there would be such a thing and I’m wondering why I don’t see them more often in my travels. It’s good to know that drivers do have designated areas where they can go if there is leaking hazmat. Of course I had to take a picture… what kind of hazmat nerd would I be if I didn’t?
I always notice placards on trucks when I’m driving. I even notice empty placard holders on trucks, especially when there is a more than just one or two. Imagine my delight when I was driving behind a truck with eleven placard holders on the back of it! I couldn’t wait until we got to a red light so I could take a picture (not surprising by now, I’m sure). By the way, eleven is my current record for number of placard holders on a single side of a vehicle.
I could go on with my work related, off-the-job hazmat spotting, but I’ll stop here. I will continue to notice these things and have my camera at the ready to document them. And I am proud to say that I am a hazmat nerd!
I always cringe when someone asks me what I do for work. Not because I dislike my job (in fact, I’m one of the few people I know who truly enjoys their work) but because it’s so complicated to explain what I do! Sure, I could simply say I’m a Regulatory Specialist and let them stare at me blankly and try to figure out what that means, but they usually expect more of an explanation.
After going through the explanation for a new acquaintance yesterday, I got to thinking that many of our customers may not know exactly what ICC’s Regulatory Specialists do either. Some of my “regular” customers only deal with one aspect of my expertise, and are often surprised when they learn how many hats I really wear on a regular basis. After 8 years on the job, I have collected many responsibilities to keep me on my toes.
Training – One of the main duties of the Regulatory Specialist (RS) at ICC is to deliver training classes to our customers. For me, this includes the US 49CFR Hazmat regulations, the IATA Dangerous Goods Regulations and the IMDG Code. These classes can take place at our training centers, the customer’s facility, a hotel, or even via an online webinar. Not only do we conduct the training, but we also develop the presentations and quizzes that are used. We have to ensure that all of the information is accurate, up to date and gives the attendees enough information so that they can follow along and learn how to use the applicable regulations.
MSDS – Lately, my main focus has been related to our MSDS services. We provide expertise on MSDS reviews, reformatting and authoring for many areas of the world. Currently, I am able to complete work for the US and Canada but will hopefully be able to add the European Union to my knowledge base soon. With the impending OSHA Hazcom standard update to the Globally Harmonized System (GHS), I have been preparing myself for the changes that are going to take place. Writing an MSDS is no simple task, there is research involved, as well as interpretation of the information once it is found. There isn’t a simple “formula” that can be applied to spit out a finished MSDS. Sometimes it’s difficult to explain why a 6 page document can take several weeks to complete.
Help Desk – We pride ourselves on our customer service at ICC. One of the things that sets us apart from the competition is our regulatory help desk. If our customers have questions related to the regulations and how they apply to their products, they can call and speak to a regulatory specialist to set them straight. I have reviewed shipping documents, assisted in packaging selection, clarified requirements, spoken to carriers and provided help in countless other ways. Many customers that I have built relationships through the years love having the “phone a friend” option to fall back on when they get stuck, confused or completely lost with the regulations.
Internal Education – Just as our customers rely on our expertise, our coworkers come to us when they have questions. Whether it’s a customer relations associate who wants to know about a new label that we offer, our packaging specialist needing advice on a new design, or a business development manager who needs a unique solution for a customer, we get ideas and problems bounced off of us on a regular basis.
Product Development and Review – As regulations change, so do the products that we offer. The regulatory specialists are involved in ensuring that all new products meet the applicable regulations. In addition, when an existing product has to be reprinted or remanufactured, we perform a review to make sure that there are no regulatory changes necessary. We also review our existing products as the regulations change.
All of these tasks keep me busy and make every day at the office different. I have learned a lot since my first days at ICC, and there is still more to add. Even this list is not complete; there are always those miscellaneous requests and tasks that come across my desk. All in a day’s work for this regulatory specialist!
In January 2011, OSHA proposed that in August of this year, they would publish the final rule to align the current Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The more recent DOL Spring semi-annual regulatory agenda released in June revisits the scheduling of the release of the HCS revision to an unspecified date in September of this year. September has now come and gone, and we are still without a final rule from OSHA.
This leads to the question of “If not now, then when?”. It is probably a safe assumption that OSHA’s lack of implementation of GHS to date will be a major topic of discussion at the October 1st – 5th Society for Chemical Hazard Communication (SCHC) fall conference in Washington, DC. Many health and safety professionals, myself included, will be impatiently waiting for word of a revised deadline.
On September 13, 2011, PHMSA published the current 180-day special permit application list in the Federal Register. Under 49 U.S.C. 5117(c), PHMSA is required to give notice to the public of Special Permit applications which have been under review for issuance or renewal for longer than 180 days. The list includes initial Special Permit applications as well as modification, renewal, and party status requests. The reason(s) for delay and the expected completion date for action on each application is provided in association with each identified application. The full notice can be viewed at: http://www.gpo.gov/fdsys/pkg/FR-2011-09-13/pdf/2011-22942.pdf
PHMSA also published HM-244D, a corrections document in the September 13, 2011 Federal Register. PHMSA annually reviews the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180) to identify typographical errors, outdated addresses or other contact information, and similar errors. In the final rule, PHMSA is correcting typographical errors, incorrect CFR references and citations, inconsistent use of terminology, misstatements of certain regulatory requirements, inadvertent omissions of information and outdated transition dates. The full Final Rule can be viewed at: http://www.gpo.gov/fdsys/pkg/FR-2011-09-13/pdf/2011-23167.pdf
by Emily Walter on August 3, 2011 at 3:42 pm · in Emily's Blog
Poison Ivy
As I sat at my desk trying to ignore the itchy poison ivy blisters on my legs and feet, I started to think about what other “hazardous materials” I may encounter out in the wilderness. I decided to do a little research and found that there are a number of safety hazards that Mother Nature has provided.
I started with the cause of my current itching…urushiol. Urushiol is a highly irritating oil found in poison ivy, poison oak and poison sumac. The oil is present in all parts of the plants, including the leaves, stems, flowers, berries, and roots. Despite the common names of the plants, urushiol is not a poison but an allergen, and because of this it will not affect certain people. Because urushiol is inside the plant, brushing against an intact plant will not cause a reaction. But undamaged plants are rare because poison oak, ivy and sumac are very fragile plants. Stems or leaves broken by the wind, animals, and even tiny holes made by insects can release urushiol. The first symptom of reaction is a severe itching of the skin. Later, a red inflammation and a blistering of the skin occurs. In more severe cases, oozing sores develop. Indirect contact with urushiol can also cause the rash. This may happen when you touch clothing, pet fur, sporting gear, gardening tools, or other objects that have come in contact with one of the plants.
Giant hogweed has been in the news quite a bit recently. According to the NY State DEC, giant hogweed is a biennial or perennial herb in the carrot family (Apiaceae) which can grow to 12 feet or more. Its hollow, ridged stems grow 2-4 inches in diameter and have dark reddish-purple blotches. Its large compound leaves can grow up to 5 feet wide. Its white flower heads can grow up to 2 1/2 feet in diameter. When giant hogweed sap, which contains photosensitizing furanocoumarins, contacts human skin in conjunction with sunlight, it can cause phytophotodermatitis – a serious skin inflammation. In brief, the sap prevents your skin from protecting itself from sunlight which leads to a very bad sunburn. Heat and moisture (sweat or dew) can worsen the skin reaction. The phototoxic reaction can begin as soon as 15 minutes after contact, with sensitivity peak between 30 minutes and two hours after contact. If the sap gets into the eye, permanent blindness can occur. Sap can be located in all parts of the plant but higher concentrations are found in the lower part of the hollow stems and petioles; the hollow hairs on the plant; the foliage, stem, flower, or fruit (seed).
Atropa belladonna, also known as deadly nightshade, is a plant I had only read about in fiction. In my research, I found the website for Belladonna Killz, which had a ton of interesting information about this ancient plant. Belladonna is known for its toxicity. It is one of the most poisonous plant species found in the Western hemisphere. All parts of the belladonna plant are toxic. In fact, belladonna berries are greatest danger to children as it looks very attractive and somewhat taste sweet. All parts of the plant are poisonous containing tropane alkaloids. The active agents in belladonna, atropine, hyoscine and hyoscyamine have anticholinergic properties. Consumption of two to five berries by children and ten to twenty berries by adult can be fatal. Even the ingestion of a leaf can be lethal to an adult. The information on toxicity of atropa belladonna also reveals that the most toxic part of the belladonna is the root of the plant, though this can vary from one specimen to another. The symptoms of belladonna poisoning include fever, hallucination, dilation of pupils, headache, flushed skin, nausea, loss of balance, dry throat, urinary detention, convulsions, and delirium. Other symptoms can be complete dryness of skin. However, fatal cases have a rapid pulse that turns feeble. The antidote is physostigmine or pilocarpine, the same as for atropine. Information on belladonna toxicity further reveals that the deadly symptoms of belladonna are caused by atropine’s effect and disruption of the parasympathetic nervous system’s ability to regulate non-volitional/subconscious activities such as sweating, breathing, and heart rate. Toxicity of belladonna plant information also reveals that this plant is also toxic to many domestic animals and livestock. Belladonna poisoning can caused narcosis and paralysis to animals. However, cattle and rabbits eat the plant seemingly without suffering harmful effects.
Stinging nettle is another natural hazard that I have had the unfortunate opportunity to become acquainted with. While not as dangerous as the previous examples, it is not something that I would choose to come in contact with a second time. The leaves and stems of the stinging nettle plant are very hairy with both non-stinging hairs and many stinging hairs (trichomes), whose tips come off when touched. This transforms the hair into a needle that will inject several chemicals, such as acetylcholine, histamine, 5-HT or serotonin, and possibly formic acid. This mixture of chemical compounds cause a painful sting or paresthesia from which the species derives its common name, as well as the colloquial names burn nettle, burn weed, burn hazel. Despite the hazard, stinging nettle is still commonly used as a source of food as well as for medicinal purposes.
The best way to avoid exposure to any of these plants is through education. If you are going to be spending time outdoors, especially in unfamiliar areas, make sure you are aware of what hazardous plants are found in that area. Make sure that you know how to identify and avoid them, as well as what to do if you are exposed.
