Stopping dangerous imports from the start

By John V. Currie -- Logistics Management, 9/1/1999

The U.S. Coast Guard recently implemented container-inspection procedures that are designed to improve safety in the domestic transportation of dangerous goods. The new procedures let the agency take an initial look at inbound dangerous cargoes before they are offered for domestic intermodal transportation. The procedures include instructions for targeting inbound ships on a random basis through a review of various information sources. Although the guidelines encourage the use of random selection, they still permit the use of selective enforcement in certain circumstances.

To reduce the impact of inspections on the flow of imported goods, inspectors will obtain the dangerous-cargo and general-cargo manifests for a vessel prior to its arrival. The guidelines establish a scoring scheme for selecting containers with the most dangerous cargoes. The numerical values are based on reports of incidents, injuries, deaths, evacuations, environmental damage, and the cost of incident mitigation or response for the industry as a whole. The points assigned vary for each hazard class. Additional points are assessed against shippers or hazard combinations that have not been inspected during the previous six months. Coast Guard inspectors will select containers with the highest point total for inspection.

Inspectors will use another formula to randomly select a much smaller number of containers from the general-cargo manifest for inspection. The purpose of those inspections is to find undeclared dangerous-goods shipments.

Here's how the inspection system is supposed to work. The inspectors should be ready to go when the ship arrives. They will arrange for the preselected containers to be moved to a staging area; there, inspectors will check the declared weight and authorized capacity of each container, and will remove security seals to inspect the cargo inside. When deficiencies are discovered, the Coast Guard will hold those containers for corrective action. If no violations are found, the containers will be resealed and released for delivery.

It is estimated that it will take approximately two hours to inspect each container. Shippers and carriers should take note, though, that if a container has been preselected for inspection, they probably should not schedule drayage for the day of arrival.

The program is expected to generate several benefits. First of all, the agency believes that the preselection of cargoes will ensure the increased discovery of violations representing the highest levels of risk to health, safety, and environment. If those inspections result in a heightened level of awareness by both foreign shippers and U.S. importers, the entire international transportation system may reap the program's benefits. Importers of dangerous goods, however, should recognize that the new program does not relieve them of their responsibility to ensure compliance with regulations governing domestic transportation under 49 CFR, 171.12(a).

The Coast Guard hopes the new system will prevent shippers and carriers from suffering economic hardships--such as when a previously scheduled drayman must wait for a container that has been detained for inspection. The scheme also is intended to reduce unnecessary inspections, such as inspections of multiple containers offered by the same shipper and carrying the same materials as those previously inspected and found to be satisfactory.

John V. Currie has taught hundreds of college courses, industry training programs, and public seminars on hazardous-materials transportation management and regulatory compliance. His firm, Currie Associates Inc., provides safety and compliance audits, consulting services, customized training manuals, and public and in-house seminars. 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.