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Non-Bulk Hazardous Material Inspections - Defining a HM Inspection

Entry DateAugust 16, 2011
Issue Number11-038-HAZ
NameSgt. Susan M. Fries
AgencyMichigan State Police
Address333 S. Grand Ave. PO Box 30634Lansing, MI, 48909United StatesMap It (opens in a new tab)
Phone517-241-0583
Fax(517) 241-0501
Email[email protected]
CommitteeHazardous Materials Committee
StatusClosed
Summary of Issue

This is a request to define General HM (non-bulk) inspections in the CVSA policy. CVSA currently does not have specific criteria for such inspections.

Justification or Need

Not having clearly defined criteria to qualify HM inspections is confusing to inspectors and managers who must review inspections for maintenance of certification. Being left to interpretation by inspectors or their agencies creates inconsistency which is problematic for inspectors, carriers, quality of certification, and data collection. For example, some consider the inspection of materials of trade HM to meet the criteria, while others do not because the materials are excepted from the HMR. Some maintain that the HM must require placards to meet the criteria. In another example, some consider inspections of automobile transporters to be HM inspections while others do not. With the implementation of CSA, defining specific criteria for HM inspections is now even more important since HM carriers are held to a higher performance standard.

Request for Action

This is a request to define specific criteria for General (non-bulk) HM inspections and what is considered a HM inspection.