ACA Attends COHMED Annual Meeting, Presents on Intersection of Transport and HCS 2012/GHS
February 16, 2016 •
Last month, ACA participated in the Cooperative Hazardous Materials Enforcement Development (COHMED) Program held in San Antonio, Texas, and had the opportunity to talk with federal and state highway patrol officers who enforce the Hazardous Materials Regulations (HMR) at roadside and during facility inspections. This annual conference provides a vital conduit for industry to present concerns and perspectives about the enforcement of the regulations. The information-sharing and problem-solving that takes place, coupled with the in-depth education that’s presented, is critical to building cooperation among stakeholders.
ACA’s effort to educate and sensitize those with regulatory and enforcement jurisdiction for hazmat transportation to the unique nature of our industry’s products and the universe of regulations under which they fall, was met with a positive response and created a better understanding of paint and related products in shipping and transportation, that will help to improve hazardous materials safety.
In its presentation, ACA focused on the labeling and packaging issues raised by the intersection of transport regulations and OHSA’s revised Hazard Communication System (2012), which adopts portions of the UN’s Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
The system’s new requirements for classification, package selection (shipping package), marking and labeling packages for shipment, and shipping documents, are focused on hazmat employees and first responders. The OSHA HCS 2012 and UN GHS differ on varied requirements, so ACA endeavored to provide some general rules, and also illustrated some specific examples.
In general, ACA advised the following:
- The container holding the chemical product requires OSHA labeling,
- The shipping package requires DOT marks and labels; and
- If the container holding the chemical product and the shipping package are same (single packaging), both OSHA and DOT labels may be required.
ACA underscored the obvious problem that occurs when a container holding the chemical product and the shipping package are the same (single packaging) as both OSHA and DOT labels may be required. This applies to drums and pails, jerricans, intermediate bulk containers (IBCs), and tanks.
ACA also identified common exceptions for paint in transport, including the Consumer Commodity, Limited Quantity, Combustible Liquids, and Environmentally Hazardous Substances and used these common packaging configurations to demonstrate that the pictograms required by HCS 2012 will be different from the marks and labels required under the transport regulations. ACA showed the enforcement community several examples of Safety Data Sheets where the HCS 2012 hazard classification will not match the hazard classification under the transport regulations, resulting in pictograms that differ from transport marks and labels.
COHMED is an outreach activity of the Commercial Vehicle Safety Alliance. It works to foster coordination, cooperation, and communication between federal, state and local agencies having regulatory and enforcement responsibility for the safe transportation of hazardous materials and the industry that they regulate.
COHMED was initiated jointly in 1986 by the states, the U.S. Department of Transportation, and Research and Special Programs Administration (RSPA), now the Pipeline and Hazardous Materials Safety Administration (PHMSA). COHMED is comprised of Federal, state and local agencies, and industry from the United States and Canada. COHMED is committed to
- improving hazardous materials transportation safety,
- providing technical assistance, training and information for the development of federal, state, and local enforcement programs, and
- fostering national uniformity in regulation and enforcement.
Hazardous materials present unique challenges to enforcement personnel and emergency responders. Effective preparedness and mitigation are fundamental to the reduction of exposure to the population and response forces. To improve preparedness and response capabilities to hazardous materials emergencies, COHMED cooperates with other federal and state agencies, enforcement personnel, emergency planning managers, responders, academic institutions, interest groups, and private industry.
Contact ACA’s Heidi McAuliffe for more information.