Article Archive
Focus on Hazmat
New cover for an old book
Vol. 27 Winter 2012

Since the beginnings of civilization man has traded with his fellow man. Trade can be defined as the practice of exchanging goods or values that one has for goods that he does not have but wants or needs.  Thus trade by its very nature, involves the transfer of goods and this transfer has an impact on the community.

The transfer of goods always involves a certain amount of risk, especially when a third party, the carrier, becomes involved.  The risks inherent to travel are well known, even today, and when accidents do occur they often result in various materials being scattered around the landscape engendering the need for clean up. In earlier times this effort usually consisted of gathering up the spilled material, salvaging what could be saved, repairing damaged equipment and getting on with business. As technology advanced the potential damage to property and the environment as well as endangerment of innocent bystanders that could result from a transportation mishap increased tremendously.

During the first half of the nineteenth century the introduction of the railroad changed the methodology of commercial transportation for all time. Where once a transportation incident might, at most, involve a single wagon, often the property of the shipper, laden with a small load of a single product, or, no more than, small quantities of two or three, now a train wreck could easily involve a dozen or more freight cars each carrying the equivalent of several wagon-loads of different products; this raised requirements for response and remediation to new levels.

Then, as now, the very first question that was asked by those responding to an incident was “what are we dealing with”? The answer is, of course, pivotal to any effective remediation effort. When goods were transported by horse drawn wagons the driver usually knew what he was hauling; all he had to do was look behind him. With the advent of the railroads all this changed. The train crew had no idea what was in the cars they were pulling. The conductor had a list called the “consist” but this was usually only a list of the cars in the train. The content of the individual shipments were not noted. Thus anyone trying to deal with any sort of transportation incident was very likely to have to rely on a good bit of guess work to determine just what he was up against.

The American Civil War was the first in which rail transportation played an extensive role. It made possible the rapid movement of large numbers of men and the great quantities of supplies, munitions and armaments they required. Several disastrous incidents during the war served to raise awareness of the problems inherent in large scale transportation of hazardous goods by third parties, and individual railroads began to enact and enforce rudimentary safety rules which are the precursors of today’s hazmat regulations. These were not elaborate and most were based on what we would consider common sense; things such as not entering into an area containing gun powder with an open light (an admonition still to be seen on shipments of munitions or explosives). These did have the effect of raising awareness but they lacked uniformity and enforcement was difficult at best.

In 1907, following a growing number of accidents involving explosives, which raised the cost to the railroads of transporting these commodities, the Bureau of Explosives (BOE) was created under the American Railway Association (ARA), predecessor of the Association of American Railroads. The BOE was formed to serve as a self-policing agency to advance the safe transportation of explosives and other dangerous articles, the BOE actually developed the first hazardous materials safety rules, which were later adopted and expanded upon by the Interstate Commerce Commission and later the Department of Transportation (DOT).

In 1908, Congress granted the Interstate Commerce Commission (ICC) power to regulate the transportation of explosives. Even though the ARA Bureau of Explosives’ rules extended to more than explosives, the ICC promptly adopted them and left enforcement to the Bureau. As the Bureau refined these rules, the ICC routinely adopted them. These procedures remained in force until the 1960s, and they sharply reduced accidents despite rapid growth in shipments of hazardous materials. The Bureau’s pioneering developments also extended beyond the railroads, for the ICC later applied its regulations to highway transportation in the 1930s, and the Coast Guard and Civil Aeronautics Board adapted them for marine and air transport.

In an effort to standardize the packaging and identification of materials in transit the Standard Transportation Commodity Code (STCC, often referred to as the “Stick” Number) was introduced. This code addressed the problem of nomenclature so that H2 SO4  was identified by its STCC number whether it was being shipped as “Acid, Sulfuric”, “Oil of Vitriol” , or “Pickling Acid.”  This was indeed a big step forward but the system still exhibited some shortcomings. For Example, the system was only used in the United States. This was not a problem when the STCC was promulgated but as international commerce increased in the aftermath of World War II the need for an international system became more and more obvious.

Another shortcoming was the lack of response information in the STCC. Transportation incidents don’t always happen at the factory gate, in fact they rarely do. They happen at “Plowpoint Junction”  fifty miles east of  West Nowhere and the volunteer Fire Chief has never heard of “trimethyl badstuff” . So, once our mythical Fire Chief knows what he is dealing with his next question is “what should we do about it” and “how can we do it safely”?

The answer is to be found in two publications that should be available to every responder. The first is the venerable Emergency Response Guidebook (the familiar “Yellow Book” ) which will give a responder enough information through the I.D. or UN/NA number  and the various tables of isolation distances,  fire suppression data and sources of additional aid and assistance that he can either deal with the incident or  “hold the fort” until specialized assistance arrives.

The second document is the Material Safety Data Sheet  or MSDS. This sheet identifies the product and/or its ingredients in terms of standard chemical nomenclature. The manufacturer must list the ingredients and the hazards associated with the material in question. The main attribute of the MSDS is that it has been standardized as to content. At its inception the MSDS was intended to be international in scope so that the essential information was made available anywhere; while this aim has not yet been entirely achieved, the MSDS has greatly reduced problems with import shipments. The MSDS system has served well but, like any other similar system, time marches on and change does happen. Therefore, in order to stay abreast of changes in the transportation industry, beginning in 2003 OSHA, began preparations to adopt a format for the familiar MSDS. This format will follow the Globally Harmonized Standard (GHS) initiated by the United Nations. The schedule for adoption has not yet been published, but there will be big changes to our familiar data sheets. The biggest of these, perhaps, are those that deal with “flammable liquids” and “combustible liquids.” This change has been mandated by the United Nations and follows the GHS. The use of a “tox” number on transfer containers appears to be acceptable under this standard. The following is one example of an area where there may be confusion when reading the supplier label in the future.

 DEFINITIONS

Basically, anything with a flash point below 200F is defined as a “Flammable Liquid.”  The new standard eliminates the definition of a “combustible liquid.”  The GHS then breaks flammable liquids down into four (4) categories. In the current NFPA 704 and the HMIS labeling systems used in the paint industry the numerical value of ZERO (0)   indicated no hazard and the numerical value of four (4) indicate the highest degree of hazard.  In the new GHS categorization of “flammable liquids” the numerical value of one (1) indicates the highest degree of hazard and the numerical valve of four (4) indicates the lowest degree of hazard.

 The new titles are called Category and are defined as follows:

• Category 1 has a Flash point < 23°C (73.4°F) and initial boiling point d”35°C (95°F); this was called a Class IA flammable liquid.

• Category 2 has a Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F); this was called a Class IB flammable liquid.  

• Category 3 has a Flash point e•23°C (73.4°F) and < 60°C (140°F); we used to call this this a Class IC flammable liquid, but the old IC class used an upper FP of 100F instead of 140F.

• Category 4 has a Flash point > 60°C (140°F) and less than or equal to 93°C (199.4°F); this is a Class IIIA Combustible Liquid.

  OSHA will also have to revise 1910.106 and 1910.119 to be compatible with the new definitions.

The following has been prepared by OSHA to compare the current MSDS to the future SDS:  http://osha.gov/dsg/hazcom/global.html

A number of files at this site which will provide the reader the entire document (150 pages)  therefore the limitations of publication precludes printing of the entire rule as an appendix.

 
 

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