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Would you Rather?

“Would You Rather?” is a popular game that kids (and adults) play for fun and entertainment. In this game, participants are presented with two hypothetical scenarios or choices and have to choose one of them. The choices can be funny, silly, challenging, or thought-provoking, and it often leads to interesting discussions and laughter.

Let’s play the Hazmat version.

Would you rather train your hazmat employees according to 49CFR 172.700 or receive a penalty of $1500.00 (more than 10 hazmat employees) for each area (general awareness, function specific, safety and security awareness training)?

The answer is simple. TRAIN YOUR EMPLOYEES. Why?

Safety. Hazardous materials can pose a significant risk to human health, the environment and property.

Cost savings. Properly trained employees are less likely to make mistakes or cause accidents, reducing the potential cost of damages, fines, or legal liabilities.

Would you rather provide a shipping paper with all of the correct information or receive a penalty ranging from $1000.00 up to $7500.00?

The answer is simple. Complete it correctly.

Ensure you provide a shipping paper for any hazardous materials offered. Ensure the information on the shipping paper is in accordance with 49 CFR 172.202-172.204.

Ensure that you include Emergency response information according to 49 CFR 172.604

Remember, mistakes on a shipping paper can be avoided by first being trained in the requirements, and secondly, taking your time and paying attention to the fine details.

Would you rather correctly maintain your shipping papers per 49 CFR 172.201 (e) or receive a penalty of $1200.00?

The answer is simple. Retain the shipping documents for a period of 2 years.

This will be a guaranteed ask by the inspector. Ensure that the documents are organized, easy to locate, and only keep the 2-years required. If your company has a policy to maintain documents for a longer period of time, keep them in a separate location.

Documents may be maintained in a binder, in a file cabinet or electronically.

Note: Penalties referenced are baseline assessments and can be found in 49 CFR Part 107, Appendix A. PHMSA (Pipeline and Hazardous Materials Administration) updates these fines on an annual basis.

Hope you enjoyed playing “Would you Rather -Hazmat Edition.” Remember, ICC Compliance Center can provide guidance to ensure you are handling and shipping your hazardous materials correctly. Contact our team of Regulatory Experts, they can help you complete the process safely and efficiently.

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Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.

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