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Hazardous Materials Inspection Procedures (Bulk, Non-Bulk and Cargo Tank)

Entry DateSeptember 20, 2019
Issue Number19-037-HAZ
NameSTEVEN PAYNE
AgencyOKLAHOMA HIGHWAY PATROL
Address220 NE 38TH TERRACEOKLAHOMA CITY, OK, 73105United StatesMap It (opens in a new tab)
Phone580-919-8044
Email[email protected]
CommitteeHazardous Materials Committee
StatusClosed
Summary of Issue

NTC has updated General Hazardous Materials Course (GHM) to include only non-bulk packagings for roadside inspection. Materials referencing bulk packages is to be deleted from the course and taught in follow on courses (Cargo Tank, Other Bulk Packages). After receiving this training inspectors may only inspect vehicles transporting non-bulk packages.

Justification or Need

CVSA inspection procedures for North American Standard Hazardous Materials/Dangerous Goods applies to both non-bulk and bulk packages. Inspectors who will be trained to inspect shipping papers, placards, and markings (identification numbers) will not be allowed to inspect vehicles for violations discovered pertaining to general hazardous materials violations and will allow vehicles with Out of Service violations to continue to operated in commerce.

Request for Action

If FMCSA NTC is going to eliminate bulk package training in the General Hazardous Materials class, should references to bulk packages in the CVSA inspection procedures for North American Standard Hazardous Materials/Dangerous Goods continue to include references to bulk packages in items 3 and 4? Or, should CVSA establish inspection procedures which allow inspectors to only inspect shipping papers, placards, and markings (identification numbers only) on bulk packages?