April 16, 2009
An excellent audit — and an award — for the UW Environmental Health and Safety Department
A compliance audit is not usually an occasion for celebration, but Environmental Health and Safety employees Matt Moeller and Doug Gallucci left their last audit with smiles on their faces and an award in their hands.
The award — a plaque — is from the Federal Aviation Administration (FAA) and says, “In recognition and appreciation for your commitment towards the safe transport of hazardous materials. Presented to the University of Washington Environmental Health and Safety Department. Your policies and procedures, as well as your cooperation with the FAA, have contributed significantly in establishing a high standard of safety and responsibility concerning the transportation of hazardous materials.”
Although Gallucci and Moeller do not themselves ship hazardous materials, it’s their job to see that everyone at the University who does is properly trained and certified. And that’s quite a challenge, considering that “hundreds of shipments of hazardous material go out of here every day,” Gallucci says.
What is considered hazardous material? Primarily chemicals and infectious agents, although even seemingly innocuous materials such as dry ice can be hazardous if shipped by air or water (dry ice’s carbon dioxide can displace oxygen in the air and kill pets in a cargo hold, for example).
Each transportation system — air, water and ground — has a thick manual of regulations that must be followed when hazardous materials are shipped, and those regulations are changed — sometimes significantly — every year. Moeller and Gallucci undergo training and recertification on a yearly basis to keep up with those regulations, and they have copies of all of them in their office.
“We buy 15 copies of these a year, so that people in the areas we call shipping centers can have their own copies,” Moeller says. “And we’re always available to consult with anyone who has questions.”
There are three main matters to consider when shipping hazardous substances — packaging, labeling and paperwork. Failing to provide a secure package, failing to label that package correctly and failing to declare the substance properly in the accompanying paperwork can all result in infractions that are punishable by fines. If the person preparing the package has not been properly trained and certified, that too is an infraction.
Fines for infractions can be substantial — in the thousands of dollars. So, Moeller and Gallucci say, the name of the game is to make sure all employees who transport hazardous substances get trained and know what they’re doing. Moeller conducts on-site, four-hour training sessions about once a month. Employees are expected to do the training — which is free — every two years to stay current.
“We’ve recently created an online course for people too,” Moeller says. “Staff who handle category A substances [the most dangerous] still have to take the in-person class, but others can do the online version if they want.”
The University is a big place, and despite Gallucci and Moeller’s efforts, there are infractions. When that happens, the agency in charge will propose a fine. The two take part in negotiations, together with representatives of the agency, the shipping department and the attorney general’s office.
“We’ll say, ‘What if we make sure the whole department is trained, what if we do some outreach for you, would you mitigate the fine?’ I remember one case where we were able to get a $20,000 fine reduced to $1,000,” Gallucci says.
The fine itself is paid by the offending department, and fines cannot be paid with grant money, which provides motivation for safety training. Gallucci and Moeller say University departments have been very cooperative with their program and careful about seeking advice when they need help.
Although the whole hazardous transport program is under the national Department of Transportation, enforcement is the job of the agencies governing the different types of transportation. Because most of the University’s packages go by air, the FAA is the agency Gallucci and Moeller most often deal with. Audits, they say, are routine, based on who has orders in with carriers like FedEx or DHL in a given week.
But the audit last month with its award presentation was anything but routine. “The FAA agents said that the work done by Matt and Doug has created a safe hazardous materials shipping program for the University that has tangible and significant impact on transportation safety,” said Barbara McPhee, acting director of Environmental Health and Safety. “They see the UW program as an example for others and stated that they often refer others to the UW for advice on establishing an effective transportation safety program.”
Gallucci is modest about his and Moeller’s accomplishments. “I think they (the FAA) go to a lot of places that don’t care,” he says. “People will say, ‘I have 500 things to do. So I shipped some paint cans wrong. So what.’ Well, maybe those paint cans will take a plane down. So when the FAA sees us, and we have a program, and every time there’s a problem, we find out what it is and get it resolved, we get the people trained — of course they’re happy about that.”
“The award caught us by surprise,” Moeller added, “but Doug and I really believe in what we do. The FAA doesn’t need a stick. They don’t have to convince us that this is important.”
