177.801 - Consider adding to Inspection Software as an OOS Violation
| Entry Date | December 8, 2023 |
|---|---|
| Issue Number | 23-061-HAZ |
| Name | SGT Matt Caudill |
| Agency | MT DOT Enforcement Bureau |
| Address | 2701 Prospect AveHelena, MT, 59620United StatesMap It (opens in a new tab) |
| Phone | 4066331426 |
| [email protected] | |
| Committee | Hazardous Materials Committee |
| Status | Closed |
| Summary of Issue | All 3 Hazardous Material inspector training programs include a slide on documenting OOS violations. The slide instructs inspectors to cite specific codes for OOS hazmat violations. Leaking packages are to be cited under 177.801 while referencing 173.24(b). However within safespect there is no violation for leaking packages under 177.801 that can be listed as an OOS. There is a violation "not prepared in accordance" but this cannot be listed as an OOS and encompasses a wide range of possible violations. The other two violations within 177.801 do not accurately reflect a leaking package. |
| Justification or Need | If we are teaching new inspectors to follow the training programs when performing inspections we need to insure that they are able to do so within the safespect program. |
| Request for Action | I request that an additional violation under 177.801 be added. This violation would be specific to leaking packages both bulk and non-bulk, within the text of the violation we would cite 173.24 and then let inspectors document further the circumstances of the violation. This would ALWAYS be considered an OOS violation. |