COSTHA
representatives meet with DOT officials to discuss the formation of
Partnership Agreements

L to R: John Currie, COSTHA Administrator
and Technical Consultant; Robert McGuire,Ph.D., Associate Administrator,
US DOT PHMSA; Sean Broderick, Regulatory
Compliance Manager, Procter & Gamble Distributing LLC and
COSTHA Regulatory Affairs Chair; Robert Richard, PhD, Deputy Associate
Administrator, US DOT PHMSA and Dave Sargent, Dir. Office HM Initiatives
& Trng, US DOT PHMSA
The
Council on Safe Transportation of Hazardous Articles (COSTHA)
Administrator Lara Currie reports that discussions with DOT regarding the
establishment of two partnership agreements have been well received and we
are looking forward to formalizing them. “From the initial
discussions with Bob Richard at the COSTHA Annual Meeting in March through
our first meeting in July of this year, the DOT has been very receptive to
the idea.” The first agreement concerns vendor returns/reverse logistics
and is being facilitated by COSTHA Regulatory Chair, Sean Broderick,
Regulatory Compliance Manager, Procter & Gamble Distributing LLC.
Mr. Broderick states, “Vendor returns are a challenge across many
industry segments and affect a large portion of the COSTHA membership. The
supply chain and distribution channels for the consumer product industry
have become so streamlined that huge volumes of products can be placed in
over 100,000 retail stores throughout North America within a matter of
days. On occasion, small quantities of these products are returned to the
vendor through retail sales agencies or instrumentality or directly from a
wholesale distribution center. Reasons for return may include but are not
limited to product obsolescence, malfunction, or damage rendering the
product unfit for use. Mr. Broderick went on to say, “In some
circumstances the products being returned may be subject to the waste
requirements contained in Title 40, Code of Federal Regulations, Part 262.
The scope of our project with DOT can not be accurately quantified without
input from the regulated industry. The purpose of the partnership is to
obtain vital industry input through open and candid disclosure at
organized workshops, discussion groups, meetings, or other for a. The
partnerships include PHMSA participation in an environment providing
opportunity for developing acceptable and reasonable standards. To further
enhance the project we have also reached out to EPA and have scheduled a
preliminary meeting with them.
The
second COSTHA/DOT partnership is focused on Enhancing the Image of the
HazMat Professional and is chaired by Jeanne Zmich, Vice President,
Labelmaster and Co-Chair COSTHA Education and Training Committee and Executive
Committee member. COSTHA has recognized a significant problem with regard
to career development of hazardous materials management professionals over
the past several years. Recent trends throughout the business community
have seen senior level management professionals experiencing accelerated
retirement packages designed to meet budgetary restraints in a highly
competitive economic environment. The hazardous materials regulatory
compliance management function is often targeted as a function which is
not perceived as contributing directly to revenue generation and
profitability of a company. COSTHA has witnessed numerous examples of this
trend where senior level hazmat managers have been retired and replaced by
either entry level employees or employees already employed in a discipline
with some similarity to the hazardous materials management function. Often
these environmental, health or safety managers have a full workload
without inclusion of the hazmat manager’s function and therefore have
limited resources to devote to expanded responsibilities. Since it is
often difficult, if not impossible to document the productivity of the
function and to exhibit tangible value to the position, promotional
opportunities may be limited within some corporations. Coupled with
increased complexity of the transportation regulations, criminal and civil
liability incurred as a result of errors or omissions, and lack of “top
down” recognition of the position to provide a career ladder, qualified
management candidates are not attracted to a career path which a focuses
on hazardous materials transportation.
COSTHA
Administrator and Technical Consultant John Currie noted, “This problem
is becoming international in scope. At the 29th Session of the
UN Sub-committee of Experts on the Transport of Dangerous Goods, the
Netherlands submitted (ST/SG/AC.10/C.3/2006/38) their concern regarding a
‘decline in the experts on the transport of dangerous goods regulations,
not only on the side of government but also on the side of industry.
Furthermore, it is getting more and more difficult to find new persons who
are interested in spending many years becoming an expert."
The
mission of the partnership is to enhance recognition within companies, the
industry, and the general public, for those involved in hazardous
materials and to ensure the safe and secure transportation of hazardous
materials. COSTHA and DOT/PHMSA will develop a strategic approach for
enhancing the “value added and key-role” image of the hazardous
material employee, with a goal to elevate the role within the industry.
A
task force for each of the partnerships has been formed. Members who are
interested in participating or obtaining more information should contact
the COSTHA office, 703.451.4031 or by email mail@costha.com.
COSTHA
is a not-for-profit industry association devoted to promoting regulatory
compliance and safety in the international and domestic transportation of
hazardous materials. COSTHA
represents shippers, carriers, container manufacturers, training
companies, and related businesses and associations responsible fthan $1.6
trillion in international commerce.
These entities are involved in all aspects of hazmat commerce,
including transportation of hazardous materials, hazardous substances,
marine pollutants, and hazardous wastes on a global basis.
For
more information on COSTHA and its initiatives, call 703.451.4031 or visit
our web site www.costha.com.
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