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John Hamilton ~ Pinnacle International Freight, Inc.

SuperPort: The Interconnection of International Commerce

The global inventory of Airports, Seaports and Dryports in total constitute tens of thousands of acres of sea and land dedicated to serve as the capillaries of commerce for the life’s blood of the modern economy.  Year by year, the growing wants and needs of millions more people now gaining significant purchasing power press upon the global supply chain with instant access to global markets to buy and sell on-line and on-demand.  But those products bought with the tap of a fingertip have a rough and rugged journey ahead with giant containerships stuck at sea for days waiting to be unloaded, rail yards and highways at capacity, and the air cargo market looking at traffic jams in the sky.

To meet the growing demand Ports around the world are now being rebuilt and expanded into multimodal SuperPorts handling bulk wet, dry and containerized cargo in greater volumes than ever before.  With this demand for infrastructure investment at an all-time high the Interstate Traveler Company’s Hydrogen Super Highway (HSH) offers a practical solution to increased capacity and security while providing a fit instrument to enable Ports secure access for expansion into new inland customs processing facilities.  Not only does the HSH provide secure cargo movement, it also provides secure pipeline services with greater volume than older pipelines already in need of replacement.

The inception of the Interstate Traveler has been the functional upgrade to the Interstate Highway as a public transportation and utility infrastructure network with our focus on the interconnection of our airports, seaports and rail yards to provide fully secured point to point transportation services for people, products and ideas, along with multiple secure pipelines for conducting the hydrocarbon of your choice and direct access to bulk Hydrogen and raw electrical power.  With the integrated system of systems approach the HSH provides a valuable service for all entities co-dependent on port efficiency, safety, reliability and resilience against the hard hits that come from the sea in cyclones and tidal surges.

 Here in America our infrastructure is fantastic, yet the World Bank has developed and maintained an overall performance model to rank the countries of the world published in the bi-annual report called the “Logistics Performance Index.”  The United States ranks 14th overall, yet holds a respectable 7th place in infrastructure.  When the benefits of the HSH are factored in the USA will race to the top of the charts in just a few years after fabrication and installation begins.

In the last 20 years the global infrastructure market has seen a revolution in transportation systems in both the reconstruction of old systems and the rapid fabrication of the new.  The thousands of miles of new high speed rail installed in China and the reconstruction of the Panama Canal are just two highlights.  The Port of Montreal is another; handling their one millionth container in 1977 with a port history dating back to the 1600s, it is now after three expansions handling nearly 1.5 million TEUs per year. Now looking at the several hundred FTZs serving America linked by our highways and railroads; could America be ready to leap ahead of the world with a newer, better, faster, safer and more secure multimodal infrastructure system?  For the investors of the Interstate Traveler Company, the answer to that question is always yes. 

With the HSH, America has the opportunity to take local, regional and international logistics to an entirely new level giving greater access to greater markets at greater distances increasing business for all the existing logistics companies to enjoy greater growth in the years to come.   For more information on how the HSH could help increase your revenues and lower your costs visit our website and send us a letter via U.S. Mail.

 Interstate Traveler Co. LLC

Wixom – Michigan – USA

www.interstatetraveler.us

https://twitter.com/HSHElevatedRail

https://www.youtube.com/user/InterstateTravelerCo

 

Significant Changes to the 61st Edition IATA Dangerous Goods Regulations

By Sonia Irusta
Bureau of Dangerous Goods

It is that time of the year again. IATA has released a list of significant changes and amendments to the Dangerous Goods Regulations (DGR), which will now see its 61st edition. Hazmat employees involved in the transport of dangerous goods by air must review these changes and incorporate them into their routines if applicable. Time is of the essence, as the updated regulations will take effect on January 1, 2020.

What’s Gone

Updates to the dangerous goods regulations do not always impose tighter restrictions. Sometimes, new research shows that current regulations are harsher than they need to be.

The IATA “pointing hand” symbol appears next to DGR regulations when they are more restrictive than their counterparts in the ICAO Technical Instructions (TI). IATA removed this symbol from entries on the Dangerous Goods List for UN 3449 (Bromobenzyl cyanides, solid) and UN 2389 (Furan). The latter is no longer forbidden from transport by air, while the former is now allowed on passenger aircraft, up to a certain quantity. On that note, UN 2216 (Fish meal, stabilized) did not have this symbol, but its status has similarly been changed from forbidden to permitted on all aircraft.

What’s New

Of course, a few regulations are completely new. The DGR’s list of dangerous goods now has four additional UN numbers: UN 0511, 0512, 0513 (all types of explosives) and UN 3549 (Category A Medical Waste). The glossary now contains a new entry for “aggregate lithium content” and a new definition for “lithium batteries installed in cargo transport unit.” (For good measure, we should note as well that there was a “revision to the definition of fissile material to become ‘fissile nuclides.’”) Finally, the regulations also contain new special provisions as part of Appendix I – more on this later.

What’s Different

When people see the term “significant changes,” they may assume wholesale deletions or brand-new additions. However, quite a few of this year’s changes serve simply to clarify existing rules. For example, tear gas candles have now been assigned special provision A802 “to reinforce that packagings must meet PG II performance standards.” In Section 5.0.2.11, subparagraphs (c) and (h) were both edited to clarify packing protocols.

Major revisions have been made to the single packagings tables, found under the section called “Packing Instructions.” Previously, the catch-all phrase “Composites – Plastic – All” would appear anytime hazmat employees could use composite packagings. IATA must have determined this designation too vague to be effective, so these parts of the table now specify the permitted packagings. Clarity is vital in cases like this because if the wrong packaging is used due to misinterpretation, the dangerous goods contained could be compromised.

Appendix I

A new appendix has been added to this edition of the DGR to provide the detail of the changes that will come into effect as of 1 January 2021 based on the adoption of the changes arising from the 21st revised edition of the UN Model Regulations as well as the changes that have been agreed to date by the ICAO Dangerous Goods Panel for inclusion into the 2021–2022 edition of the Technical Instructions.

Learn the Latest Dangerous Goods Regulations Today

The DGR may require hazmat employees to undergo training at least once every 24 months, but the DGR still updates more frequently than that. If you would like to stay current with the latest changes in dangerous goods regulations, training will help by educating interested parties in the intricacies of how to navigate such regulations. Training is not an option if your role meets the definition of a hazmat employee.

Sonia Irusta is a highly accomplished business and technical professional instrumental in domestic and international transportation solutions for shippers, freight forwarders and carriers. She can be reached at Bureau of Dangerous Goods (609) 860.0300 Ext. 327 or via E-mail 

Go jump in a lake, an ocean or a kayak

By Tom Buysse

 Are you having a black-and-white work week? Nothing wrong with that: you’re current on your email replies, your boss hasn’t given you “the look” yet and maybe you even made a customer laugh.

But last week I went to Newfoundland with my wife for our 25th Anniversary, and it was a 4-color week.

Many of the contiguous row houses there are painted in primary colors: a red house with a yellow door connected to a blue house with an orange door connected to a green house with a purple door. But it’s not just the paint colors that made it a 4-color week.

At risk of sounding like I work for the Newfoundland Board of Tourism, try to find the time and money to go someplace different from where you live.

A “town” in Newfoundland is really just a few homes along a beautiful cove or bay overlooking the ocean, with anywhere from a couple commercial fishing boats to a couple dozen tucked into the harbor. Throw in a church, a cemetery and a Royal Canadian Legion Hall and you’ve got a Newfoundland town.

Hike a trail with breathtaking views but don’t get too close to the edge of the cliff because Newfoundland should be called Newrockland. Take a sea kayak tour and figure out how to steer through the crevices of an island filled with nesting puffins. Slow down your stroke rate so you don’t lose sight of a family of eagles resting atop the highest pine trees (it’s not too easy to twist your body and do a double-take in a sea kayak).

Feel the salt air breeze in a rubber raft racing to the open ocean and try following a humpback whale as he searches for food. Count the puffins while your guide is trying to move in the right direction at the right speed in an effort to guess where the whale will surface next.

There is no Motel 6 or Holiday Inn in Newfoundland. Nothing but B & Bs. Wake up to a delicious breakfast at a table with an ocean view and enjoy the company of fellow travelers while sharing stories and ideas on what to do next.

History? Most towns were founded in the 1600s. The first transatlantic cable terminated in a small Newfoundland town, allowing communication between North America and Europe for the first time. Visit a wooden fishing boat museum and help hold boards while the master boat builder carefully constructs a 16-foot punt.

The seafood, as you would expect, is fresh and mouthwatering. You haven’t tasted mussels or codfish like this before. They’re long on fresh seafood but short on vegetables (except Irish potatoes) in this land with a short growing season. That’s OK. You can catch up on your Vitamin C next week.

Many “Newfies” are struggling since the codfish stocks collapsed 30 years ago, severely curtailing the commercial fishing industry which was the backbone of the economy. They need the tourism dollars but are too nice to be greedy. Nobody gouges you. Nobody tries to sell you trinkets. In fact, nobody really tries to sell you anything. You have to look hard to find open restaurants. You have to go to the big city of St. Johns to find souvenirs. The people are genuinely nice. They treat you well and welcome you into their world.

So go find YOUR 4-color place. Maybe it’s in your country or even your state; or maybe it’s on another continent. But it’s out there. Take a week off and find it. Come home smiling. Then promise yourself that you’ll do it again soon.

“Tag, you’re it!” Who has best access to importer’s true intentions?

By Carl Soller

Soller Law Intl

Through the years, United States Customs (hereinafter Customs) and its successor agency United States Customs and Border Protection (Customs) have issued numerous proposed Regulations amending 19 CFR 111, regulations pertaining to Customs broker responsibilities. From former commissioner William von Raab to the current commissioner, proposals suggesting “doing away with Customs brokers” to the current proposal imposing stringent requirements on Customs brokers with regards to obtaining importer of record/owner identification prior to designating a client as “importer of record.” Subsequent to each of the proposed Regulations previously promulgated, the industry has responded with practical reasons as to why the proposals did not resolve issues relating to securing our population or protection of the US revenue. Unfortunately, in conjunction with many of these proposals, the livelihood of the “Customs broker” has been ignored or would have complicated the process to the extent that information required would be impossible to timely acquire.

Its sister agency, Transportation Security Administration (TSA), has in the past few years gone through similar reviews relating to identifying exporters to ensure the security of our air export freight. The “known shipper program” initially required the forwarder, exporter, or carrier to verify the legitimacy of the exporting entity as well as certifying all businesses taking the freight from the exporter to the air carrier. After many months of discussions, it was recognized that the forwarder usually has no way to verify the efficacy of the individual exporter. As a result, the TSA along with other government agencies were tasked with the responsibility of ensuring that the export “entities” were legitimate companies or related entities. Once the shipper was properly designated, the carrier could safely accept freight after ensuring its inspection or examination.

The proposed Regulations with regards to “Customs broker verification of importers’ identity” does not resolve security issues. Any changes in an attempt to identify fraudulent imports must begin with the required “informed compliance” as required by the current US Code Title 19 and attendant regulations. Customs’ reliance on private industry to certify the legitimacy of importers is beyond the capability of most Customs brokers. The entities which can more properly identify those false or fraudulent imports are Customs and other government agencies which have access to confidential tax and corporate filings, as well as individual or partnership tax returns and IRS information. It is thus unlikely that a Customs broker  exercising due diligence is equipped to  identify an import that is false or fraudulent except by reviewing the historical  background of that importing company. For new entities or new clients without certification by Customs, the legitimacy of that entity is open to question, and is not available in most circumstances to either the Customs broker or the freight forwarder. The solution to this problem lies within Customs existing regulatory scheme. As has been argued many times in the past, control of the “importer of record definition” lies with Customs. In the 1980s, the JFK Airport Customs Brokers and Forwarders Association brought an action in the Court of International Trade to require a limited definition of “consignee.” However, the Court decided that the consignee could be the entity named in an air waybill/transportation document; it did not require any additional ownership interest in the imported cargo. The “Customs Regulations” amended subsequent to that opinion created rules which continue until today. It provided that a non-owner consignee could not be importer of record but can appoint an entity which is a Customs broker to submit an entry in the name of that Customs broker. That created a circumstance where “express consignment entities” often designate its Customs broker corporate sister as the importer of record and the entity authorized to act as the broker. In those circumstances, Customs rarely looks to the actual owner until after import review.

The two entities most likely able to properly identify legitimate importers are Customs and the surety companies which write the bonds ensuring that Customs is paid the required duties and/or liquidated damages should the “importer of record” fail to pay.

It is difficult to dispute that certain of the “minimum information” identified in the proposal, that a Customs Broker is required to collect, is often either difficult or impossible to obtain; it is often corporate information that in the course of business the Customs broker has no need to collect.  Copies of credit reports or similar financial information is either too expensive to gather or nonexistent; state regulations regarding corporate governance differ from state to state: for example New York does not require reporting of the names of corporate officers or officials to the state of New York.

Other issues that need to be reviewed are for example in section A 5 on page 40305 of the previously cited Federal Register notice such as the circumstance where the client has multiple physical locations and sometimes only the corporate headquarters and locations where merchandise is not located but drop shipped after import. To insist upon the Customs broker to physically visit its clients is impractical and often impossible. This is particularly so as most Customs brokers operate under “national permits” and are not local, making it inconvenient to visit the clients’ locations. Also, under corporate state or local governance, the proposed rules may be contrary to what is required by those state statute or corporate regulations.

There are many other reasons why the Aug. 14 proposed rules may be inappropriate or too onerous. The likelihood of requiring a broker to obtain information which is more easily obtained by either the Department of Homeland Security, Customs, or surety is questionable. We would expect those importers and Customs brokers impacted by these proposed regulations to file comments before the expiration date of Oct. 15, 2019. Should you wish to discuss the issues or any other related support to include in your comments, please do not hesitate to contact us.

Carl R. Soller, Customs, International Cargo and Regulatory Compliance Attorney is counsel to companies engaged in all elements of the import/export supply chain and a recognized expert in his practice areas.  He and his firm concentrate their International, Regulatory and Cargo Practice in all business and regulatory matters on a nationwide basis.  He offers advice on supply chain security and its related Government Regulations to the Cargo Community as well as advice and a vast range of assistance to importers and exporters of all kinds of consumer goods.  He can be reached at (516) 812-6650 or (212) 643-6650 or

How Important are Hazardous Materials to the Semiconductor Industry?

By Stephanie Congiusta
Lead Sales and Marketing Administrator
Bureau of Dangerous Goods, Ltd.

How lucky are we to be living in a world full of modern technology?  While some of us may not be as thankful for technology as others, we can’t overlook the fact that our world has become reliant on various technologies.  Many modern day technologies require the use of raw hazardous materials to create and power them.  Just how important are hazardous materials to the technology industry?

Recently, Japan and South Korea have been featured in international news regarding a trade dispute of sorts over the export and import of hazardous materials.  South Korea has historically relied on Japan for the import of fluorinated polyimide (UN1250), hydrogen fluoride (UN1052), and resist (UN3077).  It’s been reported that Japan produces around 90% of the world’s supply of fluorinated polyimide and about 70% of the world’s hydrogen fluoride.*  These hazardous materials are essential to the semiconductor industry.  South Korean companies such as Samsung, SK Hynix, and other manufacturers of memory chips, microprocessors, and integrated circuits rely on the import of these raw materials from Japan to sustain.  While South Korea was once able to obtain these materials as needed from Japan, recently the Japanese government has put measures in place that have restricted and delayed the export of the three chemicals to South Korea.  

So what does this mean for South Korea’s semiconductor industry?  As you can imagine the industry is slotted to be disrupted by these delays and restrictions.  Being that Japan is the majority producer of these chemicals, it will likely be difficult for South Korea to seek out an alternative provider of these materials.  Major players in the semiconductor industry such as Samsung and SK Hynix have been reported to account for 61% of the global supply of memory chips.* Their customers include high-profile tech companies such as Apple and Huawei.  

With all of this being said, it’s safe to say that hazardous materials play a major role in our modern world.  We hope that South Korea and Japan will soon be able to remedy their import and export situation in order to minimize the impact on the industry.

*Statistic cited from IHS Markit.

*Statistic cited from CNBC.

Written by Stephanie Congiusta, Lead Sales and Marketing Admin at BDG

Roundup of Developments at the CBP Trade Symposium

By Lara A. Austrins

Benjamin L. England Customs and Trade Team

Here’s a roundup of developments of interest to the transportation and customs broker communities which were announced at the Trade Symposium recently hosted by U.S. Customs and Border Protection (CBP) in Chicago July 23 – 24, 2019:

  1. Risk-Based Increases in Importer Bond Amounts

CBP officials emphasized several times at the Symposium that it has been issuing insufficiency notices on bonds to better reflect importers’ increased liability for Section 301 and Section 232 tariffs.  While the increase in premiums for higher value bonds in most cases is not terribly significant, as the face value of the bond increases, so does the sureties’ liability.  Increased liability has had a significant impact on the cash collateral that sureties are demanding in connection with ADD/CVD entries, and we wonder if similar cash collateral requirements will make their way into bonds securing entries subject to Section 301 and Section 232 duties as well.

  1. Potential for Increased Enforcement Actions

Knowledgeable CBP officials stated at the Symposium that “trade remedy enforcement” is “one of the major priorities” of the Centers of Excellence and Expertise (CEE).  Our experience is that the CEEs are bringing meaningful sophistication to trade agreement and trade remedy enforcement, with their greater expertise, product knowledge, sharing of information, and improved targeting models. 

Symposium participants told us that given the large duty increases imposed under Section 301 and Section 232 and the easy accessibility of unlawful transshipment and other methods for evading the tariffs, they expect a wave of CBP enforcement actions to hit starting approximately six months from now.  Indeed, CBP officials told reporters (but not attendees) at the Symposium that they would like Congress to amend the Enforce and Protect Act (EAPA) to expand the CBP’s current ability to investigate and punish antidumping and countervailing duty evasion to all duty evasion (including evasion of Section 301 and Section 232 tariffs).

Given these developments, now would be a good time for importers to increase their due diligence in assuring themselves of the actual origin of their goods.  If importers have not already done so, we believe that it would behoove them to conduct factory visits, verify the presence and good working order of production equipment, confirm factory purchases of raw materials sufficient to produce the goods they are importing, verify that an adequate, trained workforce is in place at the factory to produce their imported goods, etc.

  1. Changes to Broker Regulations

The customs brokerage community has long been waiting for the issuance of the proposed broker regulations, which would include changes to powers of attorney and cybersecurity requirements.  One major change anticipated in the proposed broker regulations will be the replacement of the district permit and national permit with one single permit that operates at the national level within the Customs territory of the United States.  Additional guidance will most likely be issued at some point addressing the factors customs brokers of varying sizes must satisfy to ensure that they are exercising responsible supervision and control over their customs business.  Knowledgeable CBP officials tell us that the proposed regulations are undergoing review, and we are hopeful that they will be published within the next year or sooner.

  1. Enhancements in Cargo Inspection on the Southwestern Border

CBP has received significant funding to put new, non-intrusive inspection systems in place on the Southwestern Border, which should significantly speed the flow of truck traffic.  Due to the strength of energy emissions from CBP’s current truck-scanning equipment at the border, drivers of trucks seeking to cross the border from Mexico are required to exit the cab before the truck is scanned.  However, CBP officials stated at the Symposium that new equipment will be put in place which will allow truck drivers to remain in the truck while the truck is scanned, thereby significantly speeding the pace of inspection (truck drivers will retain the option to exit the truck during scanning if they wish).

  1. Ways to Manage Risk Presented by Rapid Growth in e-commerce

Finally, the rapid growth in the e-commerce environment and how to manage the increased risks that come along with such growth were central discussions at the Trade Symposium.

This increase in e-commerce is further fueled by the fact that  the value of goods that can be imported by one person in one day free of duty and taxes, the so called de minimis value, under Section 321 of the Tariff Act of 1930, as amended, was increased in 2016 from $200 to $800 (“321 shipments”).  This increase in de minimis value along with the growing popularity of e-commerce has contributed to the exponential growth of low value shipments (321 shipments) crossing our borders over the past few years.

According to CBP 1.8 million 321 shipments are entering the United States daily.  The ease of online shopping clearly has changed consumer purchasing habits resulting in the growth of e-commerce, and the growth shows no sign of decreasing or leveling off.  At the Symposium, both CBP and FDA officials highlighted the greatly increased risk of entry of counterfeit goods (including counterfeit pharmaceuticals and health and beauty products) and other illicit goods via de minimis e-commerce shipments.

As per officials at the Symposium, CBP has taken the following actions to address these risks:

  1. Electronic Advance Manifest Submission for 321 Shipments by Truck

Advance electronic manifest submissions for all 321 shipments by truck must be filed in ACE in accordance with the guidelines specified in the Trade Act of 2002.  This requirement is in full effect and failure to include 321 shipments on ACE manifests could result in monetary penalties issued by CBP.

Prior to this year, 321 shipments were exempt from advance electronic manifest filing requirements.  However, the significant increase of 321 shipments by truck resulted in slower processing times and longer wait times at the borders, as CBP was unable to conduct risk assessments or perform advance targeting on 321 shipments.   As a result, CBP changed its policy at the beginning of this year to require electronic advance manifest filing submissions in ACE for all 321 shipments by truck.  While the current cargo manifest implementation guide states the maximum number of shipments is 9,999, the 9,999 shipments can be submitted multiple times against a single manifest using instructions which are provided for via a web link in CSMS #19-000156, which can be found at https://csms.cbp.gov/viewmssg.asp?Recid=24141&page=&srch_argv=19-000156&srchtype=Seq_Msg_Num&btype=&sortby=&sby=

As the advance electronic manifest submission in ACE of 321 shipments entering by truck is in full effect, the failure to include 321 shipments on ACE manifests may result in monetary penalties issued by CBP at $5,000 for the first offense.

  1. CBP Conducting Section 321 Data Pilot Program to Consider Advance Data Submission Requirements for Low Value Shipments

On July 22, 2019, CBP published Federal Register notice of its intention to begin a voluntary test to collect certain advance data for low-value entries that may be eligible for Section 321 exemptions. 

According to the notice, “CBP is conducting this test to determine the feasibility of requiring advance data from different types of parties and requiring additional data that is generally not required under current regulations in order to effectively identify and target high-risk shipments in the ecommerce environment.” See 84 FR 35408. 

CBP realizes that currently, it is not receiving sufficient advance information to determine the risk presented by 321 shipments. The purpose of the pilot is to allow CBP to use the advance information to improve its ability to effectively and efficiently identify and target high-risk shipments, including for narcotics, counter-proliferation, and health and safety risks.

Eligible participants that can join the pilot include carriers, customs brokers, freight forwarders, and online marketplaces of any size, location or commodity type, regardless of whether they offer delivery logistic services. 

The pilot applies to each Section 321 shipment destined for the United States, arriving by air, truck, or rail and will operate in all ports of entry utilized by the participants for Section 321 shipments.  It will not apply to any mail shipments, shipments arriving by ocean or shipments destined for a Foreign Trade Zone.

The benefits of participation may vary. One benefit is that CBP may expedite clearances for low-risk Section 321 shipments when enough test data has been received prior to the shipment’s arrival.

The pilot will begin Aug. 22, 2019 and operate for a one-year period.  Once the pilot program is completed, CBP will evaluate the results to determine whether to extend and/or expand the pilot to include additional participants.  It will also decide whether additional advance reporting requirements are necessary in the e-commerce environment.

  1. CBP Entry Type 86 Pilot

In addition to the test pilot for advanced data collection on Section 321 entries, CBP officials announced the creation of  a new entry type (Entry Type 86), which will allow customs brokers and importers to send Partner Government Agency (PGA) data in conjunction with the basic data elements for 321 shipments.  Use of this new entry type may alleviate the concerns raised by FDA and other PGAs regarding the potential for unlawful goods evading review through use of the 321 process.  CBP stated that it will be issuing a Federal Register notice in the near future regarding the pilot program to test the new Entry Type 86, and that it intends to roll out the new Entry Type 86 on Sept. 28, 2019.

Please contact me if you would like to get additional information regarding these or any other Customs and trade matters.

Lara A. Austrins is a member of Benjamin L. England & Associates’ Customs and Trade Team and concentrates on issues arising from the movement of goods between countries.  She regularly deals with U.S. Customs and Border Protection, Department of Commerce, and other agencies that regulate U.S. imports and exports. She can be reached by email at or at (410) 220-2800.

Summer Sizzles, But Transporting Hazardous Materials Should Not

By Sonia Irusta
Vice President
Bureau of Dangerous Goods, Ltd.

Summer officially begins on June 21. Keeping an eye on the calendar is important when it comes to transporting hazardous materials. The manufacturing and distribution of products defined as hazmat increases as the temperature increases. Products for personal care and/or household goods as well as industrial chemicals are transported daily by ground, air, and sea. So why is this time of year any different from any other? The answer is simple: warmer weather conditions can impact hazardous materials/dangerous goods.

Hazmat and Heat

Nearly all chemicals are affected by high heat and humidity. The potential for chemicals to react and undergo changes increases as the temperature of the material rises. In addition, materials with greater volatility may produce higher levels of dangerous vapors at elevated temperatures.

When dealing with liquids, those with high vapor pressure and low boiling points should be of particular concern. When shippers prepare packages of hazmat for safe transportation, they must take into consideration the normal conditions of transport. That means factoring environmental changes which may be encountered, such as temperature extremes.

Chemicals and Pressures

Depending on the volatility of a chemical, increasing the temperature to which a container is exposed can increase the internal pressure exerted on it. Inner and single packagings intended to transport liquids and receptacles for gases must be successfully tested to sustain certain internal and external pressures. Despite this, the external temperature may increase the internal pressure beyond that for which the container is tested, consequently rupturing the receptacle and releasing the contents.

Depending on the quantity and nature of the material, the safety of personnel and the public could be seriously jeopardized. Some containers exposed to high heat may noticeably bulge, and those made of metal may exhibit a metallic “pinging” sound as internal pressure increases. This increase in pressure could also cause caps and lids to pop off.

The sound of escaping vapors indicates not only high internal pressure, but also that the material likely has a high vapor pressure and that, under the current atmospheric conditions, will produce a large quantity of vapors. If these vapors are flammable or toxic, the potential for dangerous exposure for anyone nearby will increase. Aerosols stored at extremely high temperatures can violently rupture and rocket, endangering personnel and property.

No one should transport any package containing hazmat that’s compromised due to heat. Transportation will only increase the risk of release.

Regulations for Transporting Hazardous Materials in the Heat

The IATA dangerous goods regulations address this risk specifically for self-reactive substances of Division 4.1 and organic peroxides of Division 5.2 being transported by air. They require the “Keep Away from Heat” label to be shown, along with a statement on the Shipping Declaration requiring the material to be protected from direct sunlight and sources of heat, in an adequately ventilated area. These are sensible storage practices to employ for all dangerous goods being stored or transported when temperatures are elevated.

To reduce risk, move containers from an area of direct sunlight into one that is shaded or cooler and well-ventilated. (These safeguards also apply to the transport vehicle the material is being transported in.) Pay attention to warehouse storage areas where materials may receive direct sunlight, such as near loading dock doors, and adjust storage accordingly.

Undergoing Hazmat Training Is Crucial

Proper training in accordance with Federal and International regulations can provide all the up-to-date information you need for preventing incidents related to improper packaging use as well as providing segregation requirements to prevent shipping incompatible dangerous goods.

Sonia Irusta is a highly accomplished business and technical professional instrumental in domestic and international transportation solutions for shippers, freight forwarders and carriers. She can be reached at Bureau of Dangerous Goods (609) 860.0300 Ext. 327 or via E-mail 

Detroit/Wayne County Port Authority Maps its Strategy and Presents its Plans

Detroit/Wayne County Port Authority

130 E.Atwater Street Detroit,Michigan 48226

313-259-5091

June 18, 2019 – The Detroit/Wayne County Port Authority has listened to its stakeholders and mapped the route to success. The plan was presented to a group of public and private sector representatives on Monday, June 10, and received with overwhelming support.

“With a strategy in hand, we’re eager to start living our mission in a more visible way,” said Kyle Burleson, DWCPA Executive Director. “We’re dedicated to bringing the Port of Detroit into the 21st century and setting it up to scale with the continued growth of our region. Timing to tackle this couldn’t be better with Federal funding being specifically designated for ports. To do all of this right, we will be bringing down old silos working on collective impact.”

Since the kick-off of the Port Forward initiative in March, three work groups were formed and used as a platform to collect input on infrastructure, business development, and government relations. Supporting research on best practices and expert interviews rounded out the situational analysis and allowed for strategic planning to commence. An emphasis on re-building relationship was set as a priority.

DWCPA Board President, Shannon Price, emphasized the work on relationships. “We realize the importance of communicating with other organizations to build -and keep- our reputation as an agency to support and partner with others for the good of our business community,” he said. “Our actions in the last few months have already yielded results with cooperative projects underway.”

To summarize the course of action over the next 18 months, the DWCPA presented its objectives. “First we want to develop a strategic relationship with Customs and Border Protection that enables growth of international cargo business for Michigan manufacturers,” said Burleson. Simultaneously, DWCPA will be prioritizing dock and security projects that will improve service in the current state of the port. Relationships continue to be critical and thus communications will be increased to address challenges and promote the port’s capabilities.

Looking to the mid-term, DWCPA will partner with stakeholders to delineate a recognizable “Port District” that caters to multi-modal industrial developments including warehousing, assembly, manufacturing, distribution, and storage. DWCPA would like to develop the Port District as site ready and market the property as the most unique industrial property in Michigan with port, rail, and freeway services. Simultaneously, strategic relationships with communities and economic development agencies from Wayne County, the City of Detroit, and throughout Downriver to embed a port culture for jobs, investment, and recreation will continue to grow. “Ultimately,” said Burleson, “we wish to establish the Port of Detroit as a statewide maritime thought leader. Through this objective, we will be at our best to assist port-related agencies and projects, as is our mission.”

Next steps for the DWCPA are to refine projects under review with partners, send a delegation to Washington D.C. to educate government officials on the Port of Detroit and lobby for Federal grant support and submit a grant application for the BUILD grant program in July.

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Conferences, Conferences and Bugs…educate yourself and your team and spread good will, not invasive species

By Debbie Dent
Director, Program Services
Border Connect, Inc.

 

Registration for the 2019 CTPAT Conference in San Antonio, TX will open June 3, 2019 at 10 am EDT

U.S. Customs and Border Protection (CBP) has released its 2019 CTPAT Conference information after weeks of only a “save-the-date” notification. The conference will be held in San Antonio, TX. The conference dates are June 25 – 26, 2019.  June 25 will be a general session with multiple speakers and panel discussions.  June 26 will be a day of workshops.  Both days will begin at 8 am and conclude around 5:30 pm.  

  • The registration fee is $142 USD. Registration must be made online.
  • Payment must be made by credit card via the pay.gov online system.
  • Registration for the conference will be confirmed and processed on a first-come, first-served basis once payment has been received. 
  • Please monitor your email and the CTPAT website for the registration link that opens on June 3, 2019 at 10 am EDT
  • Any questions please write the 2019 CTPAT Conference mailbox at:  

Agriculture Pest Contamination

 Agriculture is the largest industry and employment sector in the U.S., with more than $1 trillion dollars in economic activity.  Agriculture Pest Contamination will soon be a CTPAT highway carrier responsibility under a new category of transportation security. New sections like this one will include detailing internal controls for compliance, auditing practices, documentation and disciplinary procedures.

Recently another business associate brought to our attention some new rules that came into affect on May 1, 2019 that can be used to demonstrate compliance to this new responsibility:

Permits and Training Required by Pennsylvania Department of Agriculture to Prevent Spread of Spotted Lantern Fly, Effective May 2019

 To prevent the further spread of the Spotted Lanternfly (which is damaging to agriculture), a series of quarantined areas have been designated in southeastern Pennsylvania and in and around Philadelphia. The spotted lanternfly is an invasive species of insects from Asia that first appeared in Pennsylvania in 2014.

If your trucks stop in the quarantine zones for any purpose (other than for refueling or at a traffic signal), including to take a rest break, your drivers are required to obtain training and a permit is required for the truck.

The training and permits are FREE and can be completed online. Enforcement will commence May 2019 with roadside stops. States that surround the quarantine areas (NY, DE and NJ) will also be conducting stops, checking logs and bills of lading. All surrounding states will be recognizing permits and training received through the Pennsylvania program.

A company manager will have to take a short online course through Penn State’s Agriculture Extension Service. The training typically takes 1.5 hours or less to complete. Once completed, the manager can order the permits and train drivers and warehouse workers.

After online training is completed, companies will be able to request the number of permits they require. Permits are sent via mail and arrive within 2-3 weeks.

For detailed information on the training and permits, please go to https://bit.ly/2lGJQzQ. For an interactive map of the affected areas, please click here.

For some additional information here is another helpful link: ttps://extension.psu.edu/does-your-business-need-a-spotted-lanternfly-permit   

Upcoming Detroit area event (Save the Date):

8th Annual Trade Day at Cobo Center in Downtown Detroit will be held Tuesday, August 13, 2019 from 7:30 a.m. to 3:30 p.m.  This event provides trade with an opportunity to interact with CBP personnel, Detroit Field Office trade staff, Canadian Government Officials and a multitude of representatives from Partner Government Agencies (PGA). In addition, formal presentations shall be given continuously throughout the day providing information on current programs and policies relating to import and export of merchandise.

Registration for this free event shall be open until July 26, 2019 and can be completed online at https://teregistration.cbp.gov/index.asp?w=144. To register after that date please e-mail the Trade Team at  . The same e-mail can be used if you have questions related to this event.

The only thing consistent in the world of international business is change!

Debbie Dent can be reached at 1-800-596-5176 or by e-mail

Compliance From the Top Down

By Stephanie Congiusta
Lead Sales and Marketing Admin.
Bureau of Dangerous Goods, Ltd.

While safety and compliance in the handling and transportation of dangerous goods or hazardous materials should be a top priority for every organization, the importance of and emphasis on these things varies from organization to organization.  As a sales representative at the Bureau of Dangerous Goods, I’ve been disheartened to discover the lack of priority when it comes to safety and compliance with the regulations.  From one perspective, I understand why this phenomenon occurs across the dangerous goods industry.  Regardless of the reason, whether it be due to a lack of understanding about compliance or that it’s viewed as a financial burden, this seems to happen all too often.

Some of the best organizations that I’ve come across in my five years as a sales representative of compliance products are ones where there is an emphasis on safety and compliance, which all begins with management.  When I say that they are the “best,” what I mean is that they are not only extremely easy to work with, but they incur minimal risks and penalties.  Managers who prioritize safety and compliance promote the importance of it down to the employees who are involved in the day to day dangerous goods operations.  Employees will naturally adapt to their upper managers’ practices and philosophies.  

On the other hand, in an organization where safety and compliance are not a priority, problems are likely to occur.  I’ve spoken to many dangerous goods shippers and handlers who have trouble getting the funding approved for compliance services such as training, software, and consulting.  This in turn leads to the staff not being adequately trained and lacking the necessary resources to perform their job functions related to dangerous goods shipments. When management does not set high expectations related to a dangerous goods program, their hazmat employees may be susceptible to adopting the philosophy and misconception that safety and compliance are not priorities.  In the worst case scenario, neglecting safety and compliance can cause devastating accidents and put lives at risk when transporting dangerous goods.  

While compliance and safety can be seen as overhead expenses and unnecessary, it’s important to allocate funds to an annual budget for training, software, and consulting services as needed.  A prime example of a poor decision-making process is opting for a cheaper, shortened version of dangerous goods training programs to save time and money in the short term.  What’s not realized when making this decision is the long term consequences. Hazmat employees must receive adequate training for them to properly, efficiently and safely perform their job functions.  

The Bureau of Dangerous Goods is known for being one of the top compliance companies in the world.  We often hear comments such as, “I now feel prepared and confident to apply what I have learned in the training to perform my job.”  Many of the organizations that seek out BDG’s services prioritize safety and compliance, because compliance is a primary concern that will later translate into safety.  We are extremely thankful for management and their teams that we work with who practice what they preach. Compliance and Safety always come first!

Written by Stephanie Congiusta, Lead Sales and Marketing Admin at BDG