A Foreign Military Sales Primer on Hazardous Materials: What Are Competent Authority Approvals? and Why Are They Required for Foreign Military Sales Shipments?
Lockhart, Paula, Dugan, Joseph, Groenenboom, Orris, DISAM Journal
The Military Surface Deployment Distribution Command (SDDC), U.S. Department of Transportation (DOT), Defense Security Cooperation Agency (DSCA), foreign military sales (FMS) transportation community, and Department of Defense (DoD) Material Manager Safety Offices seek to clarify and update existing procedures for the shipment of hazardous materials (HAZMAT) to FMS customers--especially explosive HAZMAT. All HAZMAT must be properly packed, labeled, and documented before shipment. However, the most important task of the FMS community at-large is to ensure that FMS customers have proper documentation for shipping HAZMAT Class 1 explosives, and that FMS customers know how Competent Authority Approval (CAA) requirements apply to them. This article provides a brief overview on how to identify and process HAZMAT shipments and discusses the more urgent topic of problems concerning CAA requirements. This paper addresses topics lacking in current guidance, difficulties associated with fixing the problems, and procedures that are being considered to fix these problems. A frequently asked questions (FAQ) section is provided at the end of this article.
What are Hazardous Materials?
HAZMAT items are materials that are dangerous in and of themselves, usually for chemical reasons. HAZMAT can damage or destroy property and cause health problems, and sometimes even death, if they leak, break, evaporate, or react when improperly stored or packed. Transportation hazard communication requirements are fulfilled by assuring that proper marking, labeling, and documentation standards are in full compliance. These standards help ensure that transportation workers and the general public are cautious of HAZMAT and know what to do in the event of an in-transit accident or other incident. The DoT and international HAZMAT regulatory organizations segregate dangerous goods--or HAZMAT--into nine (9) classes. The listing below is from the DoT HAZMAT regulation published in 49 CFR 173.2, Hazardous Materials Classes and Index to Hazard Class Divisions. The purpose of segregating HAZMAT into classes is to identify the hazard risk to health, safety, and property when transported. An item. falls into Class 1 when the predominant hazard is an explosive reaction. Gases fall into Hazard Class 2, and so forth.
Shipping Hazardous materials
HAZMAT moves everywhere. HAZMAT is transported within, through, and between countries. National and international agencies monitor and regulate HAZMAT to make sure that it moves safely. Any country that moves HAZMAT has a competent authority (CA). The CA controls and regulates the movement of HAZMAT within its own country by researching and classifying new HAZMAT items and publishing HAZMAT regulations.
National CAs meet, confer, and work with each other to produce international rules and regulations to ensure the safe movement of HAZMAT worldwide. The two primary international organizations that regulate worldwide HAZMAT deliveries are the International Civil Aviation Organization (ICAO) and the International Maritime Organization (IMO). The ICAO publishes technical instructions for international air shipments, which are assimilated for easier use in the InternationalAir Transportation Association's (IATA's) Dangerous Goods Regulation. The IMO publishes the International Maritime Dangerous Goods (IMDG) Code for ocean HAZMAT shipments. The Dangerous Goods Regulation and IMDG address all classes of hazardous material.
The DoT is the only recognized CA for the United States Government (USG). The DoT publishes HAZMAT rules and regulations under Title 49, Parts 100-199, of the Code of Federal Regulations (49 CFR 100-199). The CFR outlines the legal requirements for preparing hazardous material for transportation by rail, air, vessel, and motor vehicles within the Continental United States (CONUS). ICAO, IATA, and IMO regulations apply to HAZMAT shipments that exit the U.S. All shippers of dangerous goods must follow these regulations. …