Cargo Securement for Chemical
Distributors
This webcast will cover ...
• DOT Cargo Securement
requirements for bulk and
non-bulk hazmat
• CSA and the Cargo BASIC
• Roadside inspections and the top
cargo violations
• Accident liability and cargo loss
• Driver training
Moderator
Mike Lang, Vice President, Responsible
Distribution, National Association of
Chemical Distributors
Attention Attendees:
+ Thank you for attending!
+ The presentation will start in a few
minutes at 1:00 PM Central.
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+ The slides and recording will be posted
in 7 days at:
http://www.jjkeller.com/cbdawebcasts
Presenter
Tom Bray, Sr. Editor - Transport Management, J. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Mike Lang
Vice President, Responsible Distribution
National Association of Chemical Distributors
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Introductions
• DOT Cargo Securement requirements for bulk and non-bulk
hazmat
• CSA and the Cargo BASIC
• Roadside inspections and the top cargo violations
• Accident liability and cargo loss
• Driver training
• Question & Answer
• Housekeeping issues:
Mike Lang
NACD
 You will be muted during the event.
 Please use the Question feature to text questions to the Q&A Panelist.
We’ll try to answer them during the Q&A period if they are not covered in
the presentation.
 If you lose sound at any point, you can dial-in by phone using the number
and Pass Code listed below.
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For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Disclaimers
• The content in this webcast is intended for
information purposes only and should not be
construed as providing legal advice.
Mike Lang
NACD
• If you ask questions based on your unique
circumstances, we will attempt to address them
from a more general perspective.
• This is an introductory course and is intended to
highlight critical safety and compliance topics. Time
constraints limit our ability to go in depth.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Tom Bray
Sr. Editor – Transport Management
J. J. Keller & Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Cargo Securement
• According to 49 CFR §391.13, drivers must
understand the vehicle inspection and
securement requirements found in
Parts 392 and 393 of the Federal Motor
Carrier Safety Regulations (FMCSRs).
Tom Bray
J. J. Keller &
Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
392.9
• All cargo must be properly distributed and
adequately secured
• Inspect the vehicle’s cargo and load securing
devices within the first 50 miles
• Reexamine again after 3 hours,
150 miles, or next change of duty
status (whichever comes first)
Tom Bray
J. J. Keller &
Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
393
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Aggregate working load limit
Anchor point
Blocking
Bracing
Dunnage
Friction mat
Shoring bar (or load bar)
Tiedown
Working load limit (WLL)
Header boards
Cargo covers (tarps)
Sealed container loads
Tom Bray
J. J. Keller &
Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Compliance Safety Accountability
(CSA) Overview
• CSA is an enforcement system for:
 Tracking, measuring, and evaluating carrier and driver
compliance and safety performance
 Increasing the carrier contact frequency
 “Rating” all carriers (will require rulemaking)
Tom Bray
J. J. Keller &
Associates, Inc.
• CSA tracks:
 All carriers regulated as an interstate carrier that have
a USDOT number, regardless of “type” (and their
drivers)
 Intrastate carriers that have a DOT number
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
CSA Process
• Data collection (roadside inspection, interventions,
crashes)
• Safety Measurement System (SMS)
• Seven “BASICs” (Behavior Analysis and Safety
Improvement Categories)
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Tom Bray
J. J. Keller &
Associates, Inc.
Unsafe Driving (Parts 392, 397, etc.)
Fatigued Driving (Parts 392 and 395)
Driver Fitness (Parts 383 and 391)
Controlled Substances/Alcohol (Part 382 and 392)
Vehicle Maintenance (Parts 392, 393, and 396)
Cargo Related (Parts 392, 393 Subpart I, and HM regulations)
Crash Indicator
• Comprehensive and progressive interventions
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
SMS Process
• Measures and compares safety performance using all
safety-based violations discovered during roadside
inspections and interventions, and DOT-recordable crashes
• All violations are severity and time weighted
 Severity Weight - Violations 1-10, Accidents 1-3
 Time Weight - 0-6 months = 3, 6-12 = 2, 12-24 = 1
 Full value is determined by a formula that multiplies the weights
•
•
Tom Bray
J. J. Keller &
Associates, Inc.
Once per month, scores are totaled, normalized, and used to
percentile-order carriers in BASICs versus peers in Safety Event
Groups
Carriers with percentiles that exceed the BASIC thresholds will
be targeted for intervention
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Intervention Thresholds
BASIC
•Unsafe Driving
•Fatigued Driving
•Crash
•Driver Fitness
•Drugs/ Alcohol
•Vehicle Maintenance
•Cargo-Related
Hazmat
60%
Tom Bray
J. J. Keller &
Associates, Inc.
75%
Complaints and crashes can lead to
investigative interventions as well
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
CSA Intervention Process
Tom Bray
J. J. Keller &
Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Interventions
• Early Contact
 Warning Letter
 Carrier Access to Safety Data and Measurement
 Targeted Roadside Inspection
• Investigation
 Offsite Investigation
 Onsite Investigation – Focused
 Onsite Investigation – Comprehensive
Tom Bray
J. J. Keller &
Associates, Inc.
• Follow-on
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Cooperative Safety Plan
Notice of Violation
Notice of Claim
Operations Out-of Service Order
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Intervention Scoring
• Based on violations of serious regulations
discovered during audits and investigations
• Will not “improve” BASIC Score, but can
“flip” a BASIC Safety Evaluation to “Alert”
(regardless of “BASIC Score”)
Tom Bray
J. J. Keller &
Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Cargo Related Violations
• Violations that effect BASIC Measure and
Score :
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Damaged or loose tiedown
Failing to secure vehicle equipment or load
HM placard missing, damaged, or obscured
HM package not secure
Shipping paper errors
Tom Bray
J. J. Keller &
Associates, Inc.
• Discovered during auditing:
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Security plan problems
No shipping paper for HM shipment
Accepting and transporting HM not prepared properly
Failure to maintain copies of cargo tank certificates
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Common Hazmat Violations Roadside
VIOLATION
NUMBER
SEVERITY
Size and weight
No or improper load securement
Damaged securement system/ tiedowns
Failing to secure vehicle equipment
Failing to secure load
Loose/unfastened tiedown.
Leaking/spilling/blowing/falling cargo
Insufficient tiedowns
Driver load securement
Heavy vehicle/machine securement
Placard damaged, deteriorated, or
obscured
199,456
13,981
12,495
10,805
8,719
7,656
7,653
7,136
5,611
5,418
-10
7
7
7
8
10
8
10
10
5
Tom Bray
J. J. Keller &
Associates, Inc.
3,736
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Common Hazmat Violations Roadside
VIOLATION
Placard damaged, deteriorated, or obscured
Package not secure in vehicle
No Copy Of Cert Of Registration Or
Registration # On Subject Vehicle
Vehicle not placarded as required
Failing To Provide Carrier Required Placards
Shipping paper accessibility
No shipping papers (carrier)
Emergency response (ER) information
missing
ER information not available
Offering HM Without Preparing A Shipping
Paper
Placard damaged, deteriorated, or obscured
NUMBER
3,736
3,147
3,006
2,977
2,151
1,784
1,577
1,573
1,208
1,183
3,736
SEVERITY
5
10
--
5
-3
3
3
Tom Bray
J. J. Keller &
Associates, Inc.
3
-5
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
CSA How to Survive
• Existing data can be viewed at:
 CSA SMS
 http://ai.fmcsa.dot.gov/SMS
 FMCSA Portal
 https://portal.fmcsa.dot.gov/
Tom Bray
J. J. Keller &
Associates, Inc.
• Get “wrong” data out of the system
 Learn and be willing to use the appeals processes:
 Federal DataQs - https://dataqs.fmcsa.dot.gov/login.asp
 State Motor Carrier Safety Office
 CVSA Complaint Process
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Common HM Violations Discovered
During Auditing
• Security plan problems (no plan when
required, plan not current, plan not trained
on, etc.)
Tom Bray
J. J. Keller &
• No shipping paper for HM shipment
Associates, Inc.
• Accepting and transport HM not prepared
properly
• Failure to maintain copies of cargo tank certificates
(original, reman, testing)
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Preventing Cargo Related Problems
• Train, train, train
• Make sure drivers:
 Know what they are doing
 Know to ask questions
• Have replacement procedures for defective
equipment
• Provide drivers with hands-on information
Tom Bray
J. J. Keller &
Associates, Inc.
 Handbook
 Cheat sheets
 Support numbers (expert and/or mentor)
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Securement Components
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Tiedowns can be repaired
Must remain tight while in transit
Must be adjustable (except steel strapping)
Can’t contain knots
Edge protection may be required
Straps can go outside the rub rails
Lever-type binders are acceptable
You can choose the tiedown type
Tom Bray
J. J. Keller &
Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Loading, Unloading,
and Freight Inspections
• Never leave cargo unattended
• Never use an unauthorized individual to load/unload
the vehicle
Tom Bray
• Check skid/package count before leaving
J. J. Keller &
• Make sure freight is properly described and in good Associates, Inc.
condition
• Immediately report discrepancies (if not corrected, note on bill
of lading)
• Be aware of signs of damage
• Look for signs of tampering (broken seals, damaged tape)
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Maintain Accurate
Vehicle and Cargo Information
• Vehicle identification, license, and serial
numbers should be with the driver at all
times
Tom Bray
J. J. Keller &
• Cargo information (lot numbers, types of
Associates, Inc.
containers used, markings, inventory
numbers) should be with the driver at all times
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Stopping Procedures
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Be aware of areas traveling through
Plan stops
Avoid unauthorized stops
Never stop in the same place
at the same time
Stop at populated locations
Park in well lighted areas
Avoid dark, secluded areas
Avoid conversations with
strangers
Tom Bray
J. J. Keller &
Associates, Inc.
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Seals and Locks
• Cargo seals expose any signs of load
tampering, and locks help prevent theft
• A log of inbound and outbound cargo seal
and lock numbers should be kept
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Tom Bray
J. J. Keller &
Associates, Inc.
Date and time
Number of trailer
Destination of load
Name of person applying
Name of vehicle driver
• Record appropriate information if seal/lock is
removed/broken
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Driver Training: Handling
Vehicle/Cargo Theft
• Call the police immediately
• Give as many details as possible
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License number(s) on equipment
Equipment serial number(s)
Vehicle description
Cargo description
Time incident occurred
Description of suspicious people near vehicle
Tom Bray
J. J. Keller &
Associates, Inc.
• Notify the company
Make sure driver has this information with them
whenever they leave the vehicle unattended!
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Question & Answer
Mike Lang
NACD
Tom Bray
J. J. Keller &
Associates, Inc.
Please submit questions to “Q&A”
using the Question tool
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130
Closing Remarks
• Thank you for attending! Please complete
the survey.
• In 7 days, download the recording and
slides from today’s webcast at:
http://www.jjkeller.com/cbdawebcasts
• Upcoming NACD events:
Mike Lang
NACD
 February 28: The Clean Air Act Section 112(r) General Duty Clause
- What You Need to Know Webcast
 March 27: Product Segregation in the Warehouse – EPA
Expectations and Resource Guidance Webcast
 April 2-3: Responsible Distribution Workshop (Houston)
For dial-in: 888.824.5783, Pass Code: 75154299#; Technical issues: 888.259.8414, ID: 347436130