Operational Policy 14 - Documenting Hazardous Materials/Dangerous Goods Violations

Request the Hazardous Materials Committee to add to Operational Policy 14 a section that standardizes hazardous materials/dangerous goods violations and how to properly document a violation.

This is needed as a standardization among enforcement in properly listing the correct number of violations on an HM/DG inspection to provide data uniformity.

I am requesting that the Hazardous Materials Committee look at the current Operational Policy 14 to add a section for HM/DG violations. Currently there is nothing listed in the Policy that guides officers on an HM Inspection on how to list violations when multiple violations of the same section are found together. Currently Operational Policy 14 has a section for vehicle equipment violations and driver hours of service but nothing for HM/DG. I have provided pictures of two recent inspections that I have encountered and provided information for each of those below. The first one was a cylinder truck that had multiple different products on board all labeled and placarded correctly. Several different shipping papers were provided roadside, most were correct but the two that are attached had multiple violations of the same regulation section on the shipping paper. The first one has two incorrect proper shipping names listed for two separate products of different hazard classes. The first incorrect proper shipping name on the shipping paper was for UN1073 listed as “Liquid oxygen refrigerated liquid” and should have been listed as “Oxygen, refrigerated liquid”. The second incorrect proper shipping name on the same paper was for UN1075 listed as “Liquefied Petrole” instead of the correct proper shipping name of “Liquefied Petroleum Gas”. Again, there is nothing in operational policy 14 addressing violations of section 172.200 for shipping paper violations and how to list violations. Should the violation be listed once per Specific product, once per hazard class, or maybe once per shipping paper with notes describing? The second recent example is a freight truck that was stopped hauling multiple bulk and non-bulk Hazmat products in the same van trailer. Placarding and labeling was correct, however inside there were three separate packages all with the incorrect size markings for identification numbers. One is a bulk package that has the improper size identification markings. There were also two other products both in non-bulk drum packages. One was flammable and one corrosive, each with undersized identification markings on the packages. The bulk package is a separate section but should the violations for Marking size under 172.301 non-bulk be listed for each specific product, hazard class, or together as one? During each of these two inspections I listed each individual violation separately on the inspection report but would like clarification for future. This request is to examine sections 172.200- 172.600 and provide some guidance to inspectors through operational policy 14 on the proper way to list multiple violations of the same sections on an inspection report for data quality.