WTF! Are You Handling Dangerous Goods?

If it looks like a duck, walks like a duck, and quacks like a duck, then it's probably a duck. Sounds simple doesn't it? But can you always rely on your senses when it comes to describing dangerous goods? Sure the exporter of the product must have alot of information and training to properly described, classify, and package dangerous goods, but what about YOU! Who are YOU?

YOU are the party who may be accepting the goods for transport. YOU may be accepting the goods for multiple modes of transport that may include international transportation. Do YOU know how the goods should be properly labeled, placarded, described on a shipping paper? Do YOU know what if any other goods dangerous or not can be loaded on the same transport vehicle or on the same vessel or the proper segregation that must take place on that vessel?

An example of misclassifying hazardous materials involved a shipper who failed to properly describe a class 1 material on drums that contained primary and high explosive materials. Instead they were improperly described on a hazardous waste manifest and not properly marked or labeled. Class 1 materials have specific safety, security, and vehicle routing requirements, none that were followed in this case and had an explosion occurred it could have been in a densely populated area. As it turned out there was an explosion when the drums were taken to an incinerator and they caused significant damage to the incinerator. The shipper agreed to pay a civil penalty for violiating federal hazardous materials transportation law. You can see how this could have been a much more tragic incident and could have cost lives if the drums exploded during transport or handling.

Ignorance is no excuse for accidents when it comes to handling dangerous goods. Someone's life could be in your hands. Don't be ignorant, be smart. Take a haz mat class and learn how to use a 49CFR. Learn how to properly mark, label, placard and describe dangerous goods and how to use a hazardous materials table. Someone somewhere may thank you!

Is Reporting ISF Timely a Myth?

Everyone who is filing ISFs by now knows that they are still not seeing any monetary penalties being issued by customs. While this is a good thing, you have to ask yourself why is it being delayed? It was reported that penalities would be assessed by the fourth quarter of 2010. Is it because everyone filing an ISF is in compliance? According to the progress reports being sent out by customs the answer is no.

So what gives? We have seen numerous reports of untimely filings. The standard is that the ISF should be reported 24 hours prior to vessel loading. Customs has reported that more than 90 percent of shipments comply with this filing deadline while only 2.5 percent are rejected for being inaccurate or incomplete.

We have been told by customs that the reports on timeliness are not perfect and probably won't be. It still takes human intervention to catch errors made on these reports and customs is working to improve the problem with each new release that comes out. Meanwhile the client should be protected from fines or penalties.


Customs has under law a six-year window to find an ISF violation and issue damages. What will this mean to the importer down the road? Once all the "bugs" are worked out, will customs then proceed to go back and fine violators on past proformance? It will be interesting to see how this plays out and how the implementation of ACE will benefit filers to extract their own data for the reporting of ISFs going forward.

Check back next month for more on ACE.

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