DOT explores risk management

By John V Currie -- Logistics Management, 4/1/2000

Late last year, the U.S. Department of Transportation (DOT) held a two-day meeting about risk management in hazardous-materials transportation. Invitations were extended to organizations identified as "key stakeholders" by ICF Consulting, which hosted the gathering under contract with the Research and Special Programs Administration (RSPA). RSPA stated that the goal of the meeting was to determine whether there were "voluntary, best-practice risk-management techniques applicable to various parties in hazardous-materials transportation." The program that was discussed at that meeting, however, appears to be anything but voluntary, as demonstrated by a statement in the invitation that "the study may eventually identify a need for changes to the current regulatory system."

The first day was devoted to explaining a program called Hazard Analysis and Critical Control Points (HACCP), which was developed to control the quality of foods being supplied to the NASA space program. Over the last five years, the U.S. Department of Agriculture and the Food and Drug Administration have implemented HACCP in certain food industry segments.

The following day, participants split into three groups representing carriers, shippers, and emergency responders. Their task was to develop a framework or model for how HACCP could be applied to transportation risk management in their specific industry segments. Instead, each group came up with a series of questions concerning HACCP.

For example, many participants questioned the use of the term "standards," which could become problematic in litigation. Chemical shippers said their existing programs, such as Responsible Care and the Responsible Distribution Code, already adequately controlled risks. Carriers noted that they already underwent safety enforcement audits, and that they often verified their safety compliance at the request of their customers. And emergency responders said that existing regulations of the National Fire Protection Association (NFPA), Occupational Safety and Health Administration (OSHA), and DOT probably were adequate, provided that they were more stringently enforced.

Almost everyone questioned whether applying HACCP to hazmat transportation would become mandatory, requiring additional resources for implementation with little safety benefit. All agreed that compliance with existing regulations was the most effective way to manage risk in transportation.

When pressed to classify HACCP as either a "guidance" or "compliance" program, RSPA suggested that a "seal" of some sort could verify compliance with the program. Some participants then asked whether the lack of such a seal would imply that a company was not qualified to ship or carry hazardous materials or that using that company might increase a customer's liability.

In food production, HACCP verifies adherence to industry standards by measuring such nonregulated activities as cooking and cooling times, temperature monitoring, and microbiological testing. The question is whether those standards should be applied to an industry that already has mandated testing, packaging, hazard communication, loading and unloading limits and procedures, and mandatory training for all employees, not to mention an enforcement and penalty system for noncompliance.

John V. Currie's firm, Currie Associates Inc., provides safety and compliance audits, consulting services, customized training manuals, and public and in-house seminars on hazardous-materials transportation management and regulatory compliance. He may be contacted at 1118 Bay Road, Lake George, NY 12845. Phone: (518) 761-0668. E-mail: mail@currieassociates.com. Web site: www.currieassociates.com.