Safely Shipping Hazardous Commodities

Since the Bureau of Explosives first began regulating shipments of dangerous commodities, it has been important to communicate the presence of risk or danger to those handling these materials during transport.

During the 19th and early 20th centuries, the greatest risk from hazardous materials was the use of lanterns, torches or candles by workmen during loading, unloading and warehousing operations. Hence, the first labels and placards warned against the use of “open lights.” In addition, shippers were required to label packages as to contents. The stenciled words “gunpowder,” “blasting powder” or dynamite would give a dockhand pause to consider just how he was going to handle that particular shipment. But that was only if he knew what the words meant and indeed, in some circumstances, if he could read.

As transportation technology advanced and shipping costs declined, the volume of international shipments increased exponentially. The problem of a stevedore who reads only English being confronted by a label in some other language became very real. The solution has been to rely on colors -- red for flammable, orange for explosive and green for nonflammable gas. We have also made use of icons -- flame, bursting bomb, test tube leaking onto a hand or the skull and crossbones for example. These devices serve reasonably well in marking packages and alerting workers that something bad is around. They are also intelligible to almost anyone, even the illiterate. A worker may not know exactly what has been encountered but he should know that a potentially hazardous condition is present. Proper precautions should be taken and appropriate protective measures implemented. If he does not know, at least he has been warned to seek out competent advice as to what he should do.

The question now becomes what exactly are the “proper” and “appropriate” measures? To answer that, we turn to the shipping papers or perhaps the shipping entity itself. Unfortunately, this party may be half a world away from the site of the incident. Again, there very likely will be language difficulties to overcome. This can include shipping names and chemical nomenclature.

Ethanol or ethyl alcohol (C2 H5 OH) can be shipped under at least six different chemical or generic names, not to include trade names or the names of products in which this compound is a major constituent. For example, the different names for common OTC (over the counter) remedies is staggering. Look at the number of products containing acetaminophen (Tylenol) or ibuprofen (Advil). Then there is acetylsalicylic acid (ASA) or sodium salt, otherwise known as aspirin.

Think of these products in terms of a small bottle in a medicine cabinet but they are manufactured and shipped in astounding quantities. I once taught at a pharmaceutical plant where workmen moved capsules of a common hypertension remedy around with a small front end loader. That medicine sold for $1.00 per capsule. I was looking at a fortune. When these large shipments are involved in an emergency, the unpleasant consequences can be the same as any other chemical. Adequate and appropriate control measures must be implemented.

Once, a large shipment might have meant half a dozen cases sharing a railroad box car with other “general freight.” Today “RO-RO” ( Roll-On, Roll- Off) container ships carry enough intermodial containers to fill several trains. These containers are prepared by the shipper and the contents are unlikely to be checked against the shipping papers. They often contain “mixed freight” in consumer packaging. Because of ORM-D and other similar regulations, disclosure of the specific contents may not be required. This is just a portion of the problem; what about the illegal shipments? Everything imaginable from illicit drugs to illegal immigrants has been slipped aboard ships by means of sealed shipping containers. These are only discovered when something goes wrong and responders open the packaging. Remember, a good offense is the best defense. Workers should be encouraged, indeed rewarded, for being vigilant and, more importantly, responsive. “If you see something, say something.” Many incidents could have been prevented if some alert individual had only reported that something was just not right. It is important that workers know it is okay to report even if it turns out to be a false alarm. This has been amply demonstrated in recent months with a rash of bombs and IEDs (Improvised Explosive Device), both threatened and real. Employees need to know that it is better to investigate ten false alarms than to let one real threat slip through.

Maritime transportation of hazardous materials has its own pitfalls, one of which is size. The advent of containerized freight has, because of “economy of scale,” led to the construction of vessels which would have been impossible only a few years ago. Anyone who has seen one of these behemoths fully burdened with containers stacked like a child’s building blocks knows the true definition of the word “big.” Despite that, these carriers are not equipped for unloading nor is there room for such operations. The usual procedure for handling a container endangering the ship is to simply push it overboard. Unfortunately this can be difficult. What if the container is located in the interior of the stack? Do we jettison the whole load? How do we go about it given the limited space and equipment aboard? All of this could be mitigated by adequate communications among shippers, transporters and consignees. Such a system needs to be simple enough to inform an illiterate stevedore while, at the same time, it needs to be complete enough to give responders the information needed in an emergency. Above all, it needs to tell the truth.

 Older readers may recall the disaster at Texas City, TX. That the ship’s captain spoke little English and had little scientific knowledge about his cargo of ammonium nitrate (NH4 NO3 ) contributed mightily to the escalation of the small shipboard fire into the largest industrial accident in U.S. history. Printed information in the captain’s native tongue or, perhaps, a face-toface interview could have averted the disaster. It is essential that those responsible for cargo in transit know what they are working with, how it will react under various conditions and how to deal with it in an emergency.

Those who respond to rail car incidents are taught to demand the “consist” -- a sequential list of each car’s contents. However, operating crews often rearrange the cars to make it easier to drop successive cars along the way. Thus the “consist” becomes meaningless other than to tell the responder that there may be some “bad stuff” somewhere in the train. More than one responder has counted cars to locate a box car or hopper car that is supposed to contain anhydrous ammonia. Unfortunately the “consist” will not reflect the drop offs and pick-ups along the way unless the conductor has recorded such changes himself. This raises the question of which list is correct – the conductor’s or the dispatcher’s. Obviously the method of counting cars beginning with the engine is questionable to say the least. In a day of instant communication it would not seem unreasonable that “consists” could be kept current.

Information must be complete. Commodities such as nitric acid have different properties at different concentrations. At concentrations of 40 percent or less, this material is, essentially, a strong mineral acid, i.e. a corrosive. At concentrations above 40 percent, it is also an oxidizer, meaning it can ignite in contact with organic materials such as the sawdust commonly used as an absorbent to control small spills. It would not hurt to attach some note about this to the cargo. In other words, follow the KISS principle -- Keep It Simple, Stupid. The story is told about a Gulf Coast plant at which a process unit was periodically flushed with hydrochloric acid to remove accumulated mineral deposits. During a refit and upgrade this unit was replaced. The operating protocol for the new unit specifically cautioned against using hydrochloric acid. Plant engineering posted a neatly lettered sign that read, “The use of hydrochloric acid in this unit is henceforth contraindicated due to the presence of certain components fabricated from ferrous metals thus rendering them susceptible to corrosion.” Despite this, the unit went down within a few days because somebody had flushed it with hydrochloric acid. The unit foreman promised management the error would never be repeated. At the top of the detailed sign he taped the following note – “Don’t use acid in this thing, it eats the pipes.” The foreman communicated with the workers on their own level. Words such as “henceforth,” “contraindicated” and “ferrous metals” held little meaning to them. The workers were happy to comply once they understood.

To be effective, communication must be verifiable and it must be two-way. It is one thing for a shipper or management to publish a list or issue a bulletin; it is quite another to insure that it has been read and the content understood by the addressee. In this litigious age, the fact that communication was attempted can become very important in the courtroom. For this reason it is oftentimes expedient to require that employees sign a statement to verify that they received the material and did, in fact, read it. This protects both employer and employee.

In the United States, emergency response information agencies such as CHEMTREC, CHEM-TEL and the National Response Center (NRC) do an excellent job of providing information to first responders. Outside the US and on the high seas, these agencies are always willing to help if they can be contacted. The real problem often lies with the workers who either do not understand or simply ignore the safety warnings placed on packaging. These warnings include arrows pointing up to indicate “this side up” or labels reading “protect from freezing” or “flammable.” These areplaced on the package for a reason and should not be ignored. I once acquired a full sized tank module from Europe which I used as a training aid. It had been filled with a resin that was maintained in a liquid condition by a catalyst which would be inactivated by high temperatures. A sign explained this in English, French and German. Unfortunately no one paid attention and the module was left in New Mexico’s summer sun for about four hours. It became a tank full of solid plastic and I had to get a new training aid. Nothing is accomplished unless people read the signs and follow the instructions.

It cannot be overemphasized that instructional tags such as “flammable liquid” and “this side up” were put there for a reason. While it is desirable to get as much freight on a trailer as possible, it must not be done at the risk of damage or, worse, causing a hazmat incident which destroys the entire trailer. Safety of the material and personnel must always come first. If that last box will not fit on the trailer or the last gallon of fluid will not fit into the tank car without leaving sufficient head space, it is not worth risking the whole truck, train or airplane to squeeze it aboard.

For employees to do their jobs in an efficient and effective manner they must know what is expected of them. They must also know what they are working with and how it should be handled. To insure that employees know this we must communicate. It must be two-way and include understanding. It is not enough for our stevedore to read a bulletin he must understand what it says and how it relates to him and his job. Otherwise there has been no communication, only the brief examination of a sheet of paper or the drone of some unintelligible oral tirade. Communication needs to be on the recipient’s level of understanding. “If you see something, say something” and be assured that such a report will be taken.

Employees need to be aware that good communication benefits everyone. It protects the employer, the plant, the employee and his job. It is something all parties should strive to perfect.