DOT Items To Consider

Shipping Paper • Clusters/Banks/12 & 6 Packs • CFATS

Shipping Paper
I review shipping papers from members all over the country while doing my DOT on-site audits, and I’m always amazed at the errors I find. People also send me their shipping papers or their handwritten counter tickets so that I can review them for updates prior to reprinting them by the thousands.

One of the common mistakes I find is old shipping names that have been changed by the regulations over the past few years. The most recent was the elimination of six shipping names. For most of our members, it was the elimination of the rare gas entries. Please see the Traffic Bulletins from June 2007 and December 2007 for more details.

Another item that has changed in the past but that I still find not being done correctly is the addition of the subsidiary hazards to the shipping paper hazard class entry. If you find a subsidiary hazard in column six of the hazardous materials table, then you must show them inside parenthesis immediately after the primary hazard class. For example, oxygen now shows 2.2 (5.1) in the hazard class column. Please see the Traffic Bulletin from October 2005.

I know that all these changes cost you money in either updating the cylinder decals, shipping papers, handwritten counter tickets, and even sometimes the forms that you use to print tickets off your computer systems. It is still cheaper than the fines that you could receive from DOT audits or roadside inspections.

If you have not had me review your shipping papers recently, just e-mail me a copy and I’ll be happy to look them over.

Clusters/Banks/12 & 6 Packs
How about something to save you some money for a change? Here is a helpful item for anyone who uses clusters, 12 packs, 6 packs, banks or whatever else you may call them. For all these years, we have had to do the cylinder requalification on a five-year schedule. Wouldn’t you love to be able to do the retest on these cylinders every 10 years?

There is a special permit (SP-14175) that allows certain cylinders of certain flammable and nonflammable gases in bundles up to 24 cylinders to go 10 years on the requalification. To take advantage of this special permit, you will need to apply for and receive back from DOT a grantee letter that has your company name listed and then follow the terms of the special permit. To apply for grantee status, follow the instructions found in 49 CFR 107.107 which are very simple to do. I highly suggest that you use the e-mail instructions they provide. You will get your authorization approval back in a couple of days. Just send an e-mail to specialpermits@dot.gov and identify by number the special permit application or special permit to which the applicant seeks to become a party. State the name, street and mailing addresses, e-mail address (optional) and telephone number of the applicant; if the applicant is not an individual, state the name, street and mailing addresses, e-mail address (optional) and telephone number of an individual designated as the applicant’s agent for all purposes related to the application.

Chemical Facility Anti-Terrorism Standards (CFATS)
If you have not already done so, please check out the Traffic Bulletin dated January 2008 regarding the CFATS program. You need to check Appendix A to see if you have any chemicals on your property that meet or exceed any of the amounts shown in the table. If you do have something, please contact me for help with this program.

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT & Security Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at (573) 785-5111 and at MLDSafety@hotmail.com.