The
Council on Safe Transportation of Hazardous Articles (COSTHA) President
Bill Duff, Corp Mgr Environmental Coordination Office, Toyota Motor Sales,
is pleased to report that “we have signed a partnership agreement with
the U.S. Department of
Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA).”
DOT/PHMSA is the Federal
agency responsible for promulgating a national safety program that
minimizes the risks to life and property inherent in commercial
transportation of hazardous materials. COSTHA and DOT will work
together on transportation issues involving vendor returns or
"reverse logistics".
In
discussing the partnership, Pipeline and Hazardous Materials Safety
Administrator Thomas Barrett stated “ We all know regulation alone is
not enough to fulfill our safety mission. So we rely on partners like
COSTHA to help protect the public and the environment. The partnership we
are entering will develop and introduce practical safety solutions that
work for the public interest and the regulated industry.”
COSTHA
Administrator John Currie stated, “The industry has established an
excellent record for regulatory compliance and safety in the distribution
of hazardous materials, including consumer commodities, from the
manufacturer and distributors to the consumer. We now need to candidly
examine the reverse logistics process where the person packing the returns
may not be a trained hazmat employee, the packaging may not be the same as
when it was originally shipped, and the person preparing the returns may
not even be aware of the hazards associated with transportation. Through
this partnership COSTHA and PHMSA can openly discuss the issue and provide
solutions to enhance transportation safety.”
The
project 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, and meetings. The partnerships
includes 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.

Thomas
Barrett Administrator US DOT PHMSA and (L to R) Robert Richard, PhD,
Deputy Associate Administrator, US DOT PHMSA, Sean Broderick, Hazardous
Materials Manager, Procter & Gamble Distributing LLC, Robert
McGuire, Ph.D.Associate Administrator, US DOT PHMSA and
Richard Lattimer, Associate Environmental, Consultant, Eli Lilly and
Company look on while COSTHA Administrator John Currie signs the
partnership agreement between COSTHA and DOT regarding reverse logistics
A
task force for the partnership is being 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
for more than $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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