Beyond the Rule of Thumb
Survival Tip 33
By Steven De Lisi
Incidents at freight terminals involving hazardous materials can present unique dangers to first responders. Operations at these facilities typically involve the unloading, sorting, and reloading of freight for distribution by highway transportation. Items handled can be anything from a small carton to large pieces of machinery. Totes, drums, and pails containing hazardous materials often move through these terminals, and although the percentage of items handled that are regulated as hazardous materials is relatively low when compared with other commodities,, the potential for a major incident is not. Yet, too many first responders pay little attention to freight terminals and instead focus their attention on more traditional hazardous materials facilities such as industrial plants and storage warehouses. First responders should definitely be concerned about the freight terminals that may be in their community.
Incidents at these facilities are often the results of rough handling of the containers, including those damaged as the result of having shifted during transportation. Remember, not all freight loaded on delivery trailers consists of shrink-wrapped pallets placed neatly on the floor. In reality, freight of all shapes and sizes is often stacked to maximize the volume of a trailer and load the greatest amount of material allowed by state and federal weight limits. Sudden stops and sharp turns during transportation can sometimes dislodge these items, damaging the containers. Usually, this damage and the subsequent release of product are not detected until the trailer doors are opened at the dock and workers are suddenly greeted with a pungent chemical odor.
Forklift blades also frequently damage containers. Punctures to metal and plastic containers usually occur when the containers are behind a pallet and the blades of the forklift used to move the pallet are longer than the pallet. If the blades of the forklift are placed completely through the pallet, the extra blade length will most likely puncture the container. This represents a serious problem for first responders: not only is the breach rectangular in shape, making it difficult to patch, but the breach is also on the lowest point of the container, resulting in the potential loss of the entire contents.
A fire on the loading dock of a freight terminal should be another cause for concern. While parked at the dock, there is typically less than 18 inches between trailers, so that a fire that starts in one trailer can rapidly extend to nearby trailers. Furthermore, many terminals have bay doors around the perimeter of the loading dock. These doors are normally maintained in the open position during hours of operation. In addition, most do not have cushions that seal the back of a trailer against the dock. As a result of these characteristics, first responders can encounter significant crosswinds during windy weather on a loading dock. These winds can increase when trailers are not in place at every door because the entire bay door opening is then exposed. The result is several thousand square feet of space under a metal roof loaded with large amounts of combustible materials and with significant horizontal ventilation in place prior to the arrival of fire suppression crews. The presence of numerous forklifts, each with its own propane cylinder (used as a fuel source), adds to the potential list of hazards for firefighters under these circumstances. Remember, too, that not all loading docks are equipped with automatic fire suppression systems. This fact, coupled with the inability to control air flow during the incipient stage, means that fires that occur on the dock or inside a trailer can intensify rapidly.
When dealing with hazardous materials incidents at freight terminals, since the products handled are in transition, some of the rules learned during hazardous materials awareness training may not apply. For example, although first responders are taught that shipping papers are normally in the possession of a driver or perhaps in a pouch on the driver’s door or on the driver’s seat when the vehicle is unattended, these requirements do not apply to trailers being loaded or unloaded at a dock These documents might be at a check stand next to the truck or trailer where the container is leaking or may be sitting on a forklift or in an office at the terminal. Federal transportation regulations require only that shipping papers be “in a location that is immediately accessible to facility personnel in the event of an incident involving the hazardous material.” 1
Another problem is that although employees who ship or receive chemicals may have some knowledge regarding the hazardous nature of the material, those who handle freight on a loading dock generally have no experience dealing with the product should there be a release. And don’t believe those who say that a material safety data sheet (MSDS) is required to be affixed to shipping papers! That claim is nothing more than a long-standing myth propagated by generations of well-meaning instructors of hazardous materials training programs. Although first responders may occasionally find an MSDS attached to shipping papers, this is rare and represents the exception rather than the rule.
In contrast to an MSDS, an emergency response telephone number is required by federal regulations. This number can be used to contact “a person who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material or has immediate access to a person who possesses such knowledge and information.” 2
Although this telephone number can be an effective means for obtaining emergency response information, remember that, as stated earlier, one of the challenges for first responders arriving at a freight terminal is simply locating the shipping papers. Even if their location is known, an evacuation of the facility may make access to these documents, whether on the dock or in an office, impossible.
Some first responders are well aware that many larger trucking companies will usually enter details from shipping papers into a computer database, thereby making this information readily available at a remote location. However, if the incident occurs at the terminal where the hazardous material involved was originally picked up, that information may not have been entered into the database before the incident occurred. This not only makes it more difficult for first responders because there is no backup documentation available but also because even the original bill of lading at the terminal may have been damaged or destroyed during the incident. If that is the case, then first responders may need to contact the shipper to obtain the original copy of the shipping paper. This could be difficult if the incident occurs outside of the shipper’s normal working hours.
The decision to affix or remove hazardous materials placards for trailers placed at a loading dock and in the terminal yard is yet another problem. This practice all too often depends on internal company policies rather than federal transportation regulations. Some companies may require that dock workers continually change placards as materials are loaded and unloaded. Others allow their personnel to wait until the loading and unloading process has been completed. The latter approach allows final placarding to be based on a combination of hazard classes that may be loaded, many of which allow use of a “DANGEROUS” placard to indicate the presence of a mixture of hazardous materials.
Furthermore, placards may not always be removed immediately following the complete unloading of a trailer, even for those spotted in the yard. As a result of these practices, first responders arriving at the scene of a hazardous materials incident at a freight terminal may be unable to quickly and accurately determine the presence or absence of hazardous materials loaded on trailers at the facility based solely on placarding. Remember that when responding to chemical emergencies at freight terminals, many of the traditional remedies for dealing with highway transportation incidents may not work.
Of course, all of the information presented thus far assumes that first responders are notified of a release. Remember that the Emergency Planning and Community Right-to-Know Act (EPCRA) requires a facility to make an emergency notification of a chemical release only when the amount (as measured in pounds) exceeds an established limit, otherwise known as a “reportable quantity.” However, this normally applies only when the release results in exposure beyond the facility boundaries. Furthermore, reporting guidelines generally require notification to a locality’s Local Emergency Planning Commission (LEPC), not necessarily the fire department.
As with most other industrial facilities, the extent to which first responders receive notification of an accidental chemical release at a freight terminal will depend on the type and quantity of material released, whether the release gets off the terminal site, as well as on how information sent to the LEPC is passed along to first responders. However, there may also be local and state fire codes in your jurisdiction that mandate notifying the fire department if there is a release of a hazardous material. First responders should ensure that employees at freight terminals in their community are aware of these mandated notifications.
Of course, not all chemical releases at freight terminals are catastrophic to the community, and many companies have standing contracts with cleanup contractors to safely handle small spills that may occur. However, in very rare instances, first responders might receive an anonymous call from a disgruntled employee forced to clean up a chemical spill using generic oil absorbent while wearing nothing more than standard work clothing. Although this type of scenario is not the sole purview of the transportation industry, first responders should be prepared; it could be the source of a medical emergency, especially if patient decontamination is required.
Preplanning of freight terminals will provide limited information regarding specifics of hazardous materials handled at these sites, since the nature of commodities shipped and received changes daily. However, there are likely regular customers whose products are handled at the terminal, and employees there should be able to provide some idea of what first responders can expect in terms of the hazard class, type of containers, the average volume, and the frequency of shipments. First responders can also learn about the company’s procedures for managing shipping papers and placarding while loading and unloading trailers at the dock. In addition, they can determine what actions dock personnel and supervisors have been instructed to take in a chemical emergency at the facility.
Freight terminals are an integral part of our nation’s highway transportation system and allow for the efficient movement of products necessary for the quality of life we all enjoy. Yet, despite the benefits, these facilities present first responders with unique challenges when incidents involving the accidental release of hazardous materials or fires occur. Being familiar with these types of occupancies and the people who work there can go a long way to ensure that everyone goes home.
1 49CFR 172.602(c) (2)
2 49CFR 172.604(a) (2)
Click here for more info on Steven De Lisi’s book, Hazardous Materials Incidents: Surviving the Initial Response.
Steven M. De Lisi retired after a fire service career spanning 27 years that included serving as a regional training manager for the Virginia Department of Fire Programs (VDFP) and, most recently, as the deputy chief for the Virginia Air Guard Fire Rescue. De Lisi is a hazardous materials specialist and as an adjunct instructor for VDFP. He continues to conduct hazardous materials awareness and operations-level training programs for fire suppression and EMS personnel. De Lisi began his career in hazardous materials response in 1982 as a member of the hazmat team with the Newport News (VA) Fire Department. Since then, he has also served as a hazardous materials officer for the Virginia Department of Emergency Management; in that capacity, he provided on-scene assistance to first responders involved with hazardous materials incidents in an area that included more than 20 local jurisdictions.
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