Over five days this summer, commercial motor vehicle inspectors in Canada and the U.S. conducted 4,629 inspections of commercial motor vehicles transporting hazardous materials/dangerous goods (HM/DG) as part of the Commercial Vehicle Safety Alliance’s (CVSA) unannounced HM/DG inspection and enforcement initiative.
During this year’s HM/DG Road Blitz, which was June 9-13, inspectors affixed 831 CVSA decals to inspected vehicles. A CVSA decal is placed on a vehicle or vehicle combination after an inspection to indicate there were no critical vehicle or specification cargo tank violations on those vehicles.
Conversely, inspectors discovered 1,169 HM/DG violations, of which 598 (51%) were out-of-service violations. Vehicles with HM/DG out-of-service violations, or any other out-of-service violations, were restricted from further travel until those violations were addressed.
The transportation of HM/DG demands rigorous training and heightened compliance requirements. For motor carriers and drivers, safely transporting HM/DG is imperative to the safety of the driver, the public and the environment. For inspectors, inspecting vehicles transporting HM/DG is a complex and detailed process that involves safely looking for leaking materials or unsecured HM/DG cargo, and verifying shipping papers, placarding, marking, labeling, packaging and loading compliance.
Forty-five jurisdictions participated in this year’s unannounced HM/DG Road Blitz – 10 Canadian provinces and 35 U.S. states. Enforcement personnel inspected 1,469 non-bulk packages/small means of containment, 2,522 bulk cargo tank packages/large means of containment and 447 other bulk packages/other large means of containment.
In the U.S., a hazardous material is a substance or material that poses an unreasonable risk to health, safety and property when transported in commerce, and has been designated as hazardous under Section 5103 of Federal Hazardous Materials Transportation Law. Motor carriers and commercial motor vehicle drivers involved in the transportation of hazardous materials are required to comply with the federal Hazardous Materials Regulations (HMRs), which govern the transportation of hazardous materials in interstate, intrastate and foreign commerce.
In Canada, dangerous goods are defined as any substance or material capable of posing an unreasonable risk to health, safety and property when transported in commerce. Canada’s Transportation of Dangerous Goods (TDG) Regulations prescribe safety standards and shipping requirements for dangerous goods and communicate the nature and level of hazard and risk associated with those dangerous goods.
Table 1 – U.S. HM Violations
| Type | Quantity |
| Non-Bulk Packaging | 15 |
| Bulk Packaging | 74 |
| Non-Bulk Labeling | 19 |
| Bulk Labeling | 8 |
| Non-Bulk Placarding | 104 |
| Bulk Placarding | 88 |
| Non-Bulk Package Marking | 27 |
| Bulk Package Marking | 99 |
| HM Package Integrity (Leaking) | 18 |
| No Copy of PHMSA Registration | 35 |
| No Emergency Response Information | 70 |
Table 2 – Canada DG Violations
| Type | Quantity |
| Small Means of Containment Packaging | 2 |
| Large Means of Containment Packaging | 12 |
| Small Means of Containment Labeling | 8 |
| Large Means of Containment Labeling | 6 |
| Small Means of Containment Placarding | 3 |
| Large Means of Containment Placarding | 37 |
| Small Means of Containment Safety Mark | 5 |
| Large Means of Containment Safety Mark | 21 |
| DG Package Integrity (Leaking) | 2 |
| TDG Training Certificate | 61 |
There are nine recognized classes of HM/DG. These classes designate HM/DG into categories based on the materials’ chemical and physical properties and the risks associated with those materials. A total of 7,294 Class 1-9 packages were inspected during the five days of the HM/DG inspection and enforcement initiative.
Table 3 – Packages Inspected by Class Type – Canada and U.S.
| Class | Description | Quantity |
| Class 1 | Explosives, such as ammunition, fireworks, flares, etc. | 447 |
| Class 2 | Gases, flammable, non-flammable oxygen and inhalation hazards | 1,239 |
| Class 3 | Flammable and combustible liquids, such as fuel oil, acetone, adhesives, paints, gasoline, ethanol, methanol, some pesticides, etc. | 2,478 |
| Class 4 | Flammable solids, substances liable to spontaneously combust, and substances that, on contact with water, emit flammable gases, such as white phosphorus and sodium | 354 |
| Class 5 | Oxidizing agents and organic peroxides, such as hydrogen peroxide, potassium permanganate, sodium nitrite, ammonium nitrate fertilizers and oxygen generators | 447 |
| Class 6 | Toxic and infectious substances; any material, other than a gas, that is so toxic to humans that it presents a health hazard during transportation, such as cyanide, biological samples, clinical wastes and some pesticides | 412 |
| Class 7 | Radioactive materials, such as cobalt-60 and cesium-137 | 319 |
| Class 8 | Liquid or solid corrosive substances, such as sulfuric acid and sodium hydroxide, which cause full thickness destruction of human skin at the site of contact within a specified time | 997 |
| Class 9 | Miscellaneous HM/DG, such as acetaldehyde ammonia, asbestos, elevated temperature materials and benzaldehyde | 601 |
| Total | 7,294 | |
Loading and Securement
Inspectors discovered 91 out-of-service loading and securement violations. Loading and securement requirements prevent cargo/goods/materials from moving in a manner that would cause damage to the package resulting in leaking, spilling, etc., in a commercial motor vehicle. This is especially important when it comes to the transportation of HM/DG.
Package Integrity
Inspectors identified 20 out-of-service HM/DG package integrity (leaking) violations. Leaking hazardous materials/dangerous goods pose a significant threat to human health and safety, property, and the environment. HMRs and TDG Regulations mandate specific packaging requirements to ensure package integrity and prevent leaks or releases during transportation.
Undeclared Packages
In the U.S., inspectors discovered 16 undeclared packages during the five days of the blitz. An undeclared hazardous material is a hazardous material that is subject to any hazardous communication requirements and offered for transportation in commerce without any visible indication to the person accepting the package(s) for transportation that a hazardous material is present. Hazardous materials must always be properly classified, packaged, labeled, handled and stowed for transportation. This protects workers, emergency responders and the general public from the risks associated with HM transportation.
PHMSA Registration
In the U.S., 35 drivers did not have a copy of their Pipeline and Hazardous Materials Safety Administration (PHMSA) registration. Drivers transporting certain hazardous materials are required to register with PHMSA. Every vehicle used for the transportation of hazardous materials that meets the registration criteria must have proof of PHMSA registration on board.
Emergency Response Documentation
In the U.S., 70 drivers did not have emergency response information in their vehicle. Emergency response information details the specific actions and information needed to address a hazmat release, including containment and mitigation. Emergency response documentation is mandated for specific hazardous materials and quantities, as outlined in the HMRs, and designed to facilitate a quick and coordinated response to incidents involving hazardous materials, minimizing potential harm to people, property and the environment.
There were 32 total emergency response assistance plan (ERAP) violations in Canada. Sixteen (50%) were out-of-service violations. An ERAP describes what to do in the event of a release or anticipated release of certain higher-risk dangerous goods while they are in transport. ERAPs are required in the transportation of certain dangerous goods above the quantity specified in the TDG Regulations.
Training Certificates
In Canada, inspectors identified 61 TDG training certificate violations, of which 39 (64%) were out-of-service violations. The training certificate demonstrates that the individual handling and/or transporting dangerous goods is properly trained and competent to safely fulfill their duties. According to TDG Regulations, anyone who imports, offers for transport, or handles or transports dangerous goods must be trained according to the regulatory requirements and must have a valid training certificate in their possession during transport.
CVSA’s annual unannounced HM/DG Road Blitz aims to:
- Inspect vehicles transporting HM/DG for regulatory compliance.
- Recognize vehicles without critical inspection violations by attaching a decal to vehicles and vehicle combinations.
- Remove vehicles with HM/DG out-of-service violations from roadways.
- Highlight the importance of the programs, processes and regulations associated with the safe transportation of HM/DG.
- Recognize safety-compliant HM/DG drivers, motor carriers, manufacturers, shippers, etc.
- Highlight the specially trained inspectors who prioritize transportation safety by inspecting vehicles transporting HM/DG and enforcing strict compliance regulations.
- Identify HM/DG shipping paper, placarding, marking, labeling, packaging and loading compliance violations.
The HM/DG Road Blitz is made possible through participation from CVSA’s member jurisdictions throughout North America. It is supported by the U.S. Pipeline and Hazardous Materials Safety Administration, U.S. Federal Motor Carrier Safety Administration and Transport Canada.
The initiative was adopted by the CVSA Hazardous Materials Committee, which is open to CVSA’s law enforcement members and transportation-safety industry members who work together to reduce HM/DG incidents and encourage uniformity and consistency in the application of the regulations.