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FAA / DOT Inspections Cornell University

FAA / DOT Inspections Cornell University . Bill Leonard 2013 CUHWC. Bill Leonard. 6 Years US Navy Nuclear Power School 15 Years at Cornell University Manage Radioactive Waste Program Manage DOT Hazardous Materials Program Assist with Chemical W aste Program

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FAA / DOT Inspections Cornell University

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  1. FAA / DOT Inspections Cornell University Bill Leonard 2013 CUHWC

  2. Bill Leonard • 6 Years US Navy • Nuclear Power School • 15 Years at Cornell University • Manage Radioactive Waste Program • Manage DOT Hazardous Materials Program • Assist with ChemicalWaste Program • CDL w/Hazmat, Pesticide Applicator, Hazmat Team, CHMP

  3. Outline • History of FAA Inspections at Cornell • FAA (Federal Aviation Administration) • Recent FAA Inspections • Internal DOT Audits • First Motor Carrier Inspection • New York State DOT • US DOT Number • DOT regulatory changes and updates

  4. DOT Inspection History • 2003 – 2 FAA Agents, 53 citations, $9000 fines • 2007 – 2 FAA Agents, 10 citations, Warning Notice • 2009 – FAA Agent reviews EH&S webpage, notice of update • 2011 – 1 NYS DOT Investigator • 2012 – 1 FAA Agent,8 citations, Warning Notice • 2013 – 1 FAA Investigation

  5. FAA Inspection 2012 • Phone message FAA Agent to arrive at 11 am • Inspection based on records reviewed at FedEx Express facility • Phone call to campus shipper made 2 days earlier

  6. FAA Inspection 2012 • Briefing • Copies of shipping paperwork • 33 Dangerous Goods forms (mostly Cat A) • 1 Airway Bill (dry ice) • Discussed • Paperwork issues • Phone call to shipper • Locations he planned on visiting • Broken DOT flowchart link

  7. FAA Inspection 2012 (EH&S) • Copies of all EH&S shipping papers • Training • List of all campus DOT trained staff • Added certification statement • Course/Class curriculum • General Awareness/Function Specific/Security Awareness • DOT Security Plan

  8. FAA Inspection 2012 (campus) • Animal Health Diagnostic Center • Asked to walk through a shipment • Record review • Training • Dangerous Goods forms • Package Closure Instructions • Regulations • Findings • 18 shipments over passenger limit • 1 chemical return without training • Lab staff classifying materials on shipment form

  9. FAA Inspection 2012 (campus) • Vet Medical Center • Asked to see Category A packaging • 4GU package? • Used package • Asked to walk through shipment • Inner and secondary package closed inside BSL-3 • Record review • Never happened

  10. FAA Inspection 2012 (campus) • Biotechnology Building • Dry Ice shipper • Asked for training records • Findings • Training out of date • Air waybill completed incorrectly

  11. FAA Inspection 2012 (campus) • Biotechnology Shipping/Receiving • Asked for copies of DG form • Findings • First shipment was rejected • Second shipment lost volume? • Undeclared hazmat shipment • Added information to proper shipping name

  12. FAA Inspection 2012 (actions) • Suspended shipper • DOT training • Hired ERC to provide DOT training • Required re-training of all inspected shippers • Sent shipping notice to campus • Informed FAA Agent

  13. FAA Inspection 2012 (final results) • Received Warning Notice • Cited 6 shipments over passenger limit • Cited 2 untrained shippers • Noted in letter “you have taken corrective action, the FAA has decided not to pursue Civil Penalty Action”

  14. FAA Inspection 2013 • Phone call from FAA • UPS reported undeclared dry ice package • Contents potentially infectious? “Human” • Inspection or self disclosure • Findings • Shipment made by lab partner • No DOT training • Samples not infectious

  15. UPS Photos

  16. FAA Inspection 2013 • Actions • Required DOT training • Sent Dry Ice notice to campus • Planned meeting with building safety committee • Results • Warning notice

  17. DOT Audits • FedEx • Quarterly review of DG and air waybills • Form review,24 hour info, PSN, limits • Shipper • Training • Access to Regulations • UN packaging and closure instructions • Demonstrate the steps to complete an shipment • Copies of DG forms • What to do if contacted by a Federal Agency

  18. US DOT number • Do I need one for our farm services truck that is over 10,000 GVWR? • Farm vehicles are exempt, but not our waste trucks • Who manages the US DOT number? • Grounds • Finance office • Facilities Operations (transportation services) • Look up US DOT number • Wilson lab (3 trucks) • Update of US DOT number registration

  19. NYS DOT Motor Carrier Inspection • April 2011 US DOT number renewal and update • 3 trucks to 79 trucks, • Added hazardous materials • December 2011 Motor Carrier Inspection by NYS DOT Investigator • Driver records on operators GVWR >10,000 lbs • CDL’s, medical certificates, driving history, time logs • Vehicle records on all vehicles GVWR >10,000 lbs • Maintenance files, driver inspections

  20. NYS DOT Inspection (hazmat) • Questions via conference call • Do we transport Hazmat? • Do we use a shipping paper? • How do we label our shipments? • Do we use placards? • Where are our shipping paper’s when properly seated and belted? • Do we have a Route Plan?

  21. Route Plan? • Triggered by radioactive placards for LSA • Could not specify the requirement for such plan • Only required for HRC quantities of RAM • Safety Plan • HRC quantity of RAM • > 1 liter PIH zone A • >450 liter PIH zone B • >13,248 liter PIH zone C or D • >13,248 liter liquefied gas with >85% methane

  22. DOT Inspection or Safety Audit? • NYS DOT inspection became safety audit • Treated as a new number • Facilities Operations hired a DOT consultant • Review all transportation functions • Provided guidance and example forms

  23. US DOT number requirements • Applied to any vehicle or driver of a vehicle • GVWR > 10,000 lbs • Truck and trailer with combined GVWR >10,000 • Exceptions • Operation of Fire trucks and Rescue Vehicles • Certain farm vehicles and drivers • Transportation performed by the Fed. Gov’t, a state, or any political subdivision of a state…

  24. US DOT number requirements • Driver’s • Application for employment • Must contain previous driving information • Safety performance history (previous employers) • State driving records previous 3 years • Annual driving record review including violations • Drivers road test (practical)

  25. US DOT number requirements • Vehicle and time logs • Time log (start/finish) • Less than 100 mile radius and returns to headquarters • Less than 12 hour shift separated by 8 hours off • Inspection, Repair and Maintenance Records • Driver’s vehicle inspection report • Specific items listed (including trailers if used) • Drivers signature • Mechanics signature

  26. DOT Regulatory Updates • Closure instructions (recent update 90 days) • FedEx • Dry ice no longer allowed in just styrofoam boxes • Lithium Batteries • UN Number size on packages • 2017 for Domestic • 2014 for Air (IATA currently) • 6 mm / 30L or 30 Kg / 12 mm

  27. DOT Regulatory Updates • Jan 2013 – UN number first and Cargo Only • Jan 2014 – Organic Peroxide placard • Oct 2014 – Class 6.2 and 9 label

  28. DOT Reference Sheet • Packaging • Carry on items • Emergency Response info • Shipping Hazardous Chemicals under OSHA • Definition of Commercial Motor Vehicle (CMV) • CMV Requirements • USDOT Number Exemptions

  29. Questions? Don’t forget your reference sheet Bill Leonard Hazardous Materials Specialist

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