DRIVER TRACKING

VelocityEHS' ChemTel offers an automated driver call-in program specifically designed for the explosives industry for compliance with US DOT Communications Plan Requirements found in 49 CFR Part 385.415C(1) regarding Hazardous Materials Safety Permits:

(c)(1) The operator of a motor vehicle used to transport a hazardous material listed in §385.403 must follow the communications plan required in §385.407(b)(2) to make contact with the carrier at the beginning and end of each duty tour, and at the pickup and delivery of each permitted load. Contact may be by telephone, radio or via an electronic tracking or monitoring system. The motor carrier or driver must maintain a record of communications for 6 months after the initial acceptance of a shipment of hazardous material for which a safety permit is required. The record of communications must contain the name of the driver, identification of the vehicle, permitted material(s) being transported, and the date, location, and time of each contact required under this section.

(c)(2) The motor carrier should contact the Transportation Security Administration’s Transportation Security Coordination Center (703–563–3236 or 703–563–3237) at any time the motor carrier suspects its shipment of a hazardous material listed in §385.403 is lost, stolen or otherwise unaccounted for.

This regulation requires all shippers of DOT threshold quantities of 1.1 and/or 1.5 Explosives to implement a driver tracking and log program in which the drivers report and log stops, tandem driver change over, departure and arrival to sites and return to home base. Our Driver Log Program allows drivers to call into our automated call system to log their daily route as it is being executed. Essential to the requirements of this regulation are:

• Accurate written or electronic log or record of communication that is to be submitted to the TSA on demand.
• Mandatory Six (6) months of logs are to be archived and made available.
• The record of communication must contain the name of the driver, identification of the vehicle, permitted material(s) being transported, and the date, location, and time of each contact required.
• Carrier must contact the TSA if at any time they are unable to locate their shipment or if it is otherwise unaccounted for.

The VelocityEHS ChemTel solution was specifically created to meet every requirement set forth in the regulation. Shippers who utilize the our Driver Tracking Program do not have to rely on driver hand written reports and have the piece mind that our 24 hour Emergency Response Center is able to assist their driver at any time as well as be alerted if a driver should miss reporting a stop on his route. We provide computerized log reports to shippers by driver and by vehicle number and also handles notification to the TSA if necessary.

Typical Automated Call Handling Process:

• Driver calls the VelcoityEHS ChemTel toll-free phone number provided upon entry to yard at beginning of shift and follows the automated prompts requiring company ID code supplied by VelocityEHS ChemTel, driver number, vehicle number. This first call represents the start of the daily log for this driver.
• ChemTel system automatically time/date stamps each contact call
• Driver again calls VelocityEHS ChemTel toll-free number upon departure from the yard. Driver follows automated prompts and supplies required information.
• Prompts include information on contents of truck, i.e. 1.1, 1.5, 1.6, or other.
• Driver continues to call into system upon arrival and departure from all stops on their route schedule.
• Should a driver experience a problem at any time, he may follow the automated prompt to obtain the assistance of a live ChemTel responder, 24/7. All calls that require the assistance of a live responder are recorded.
• Should suspicious activity be indicated or suspected, the VelocityEHS ChemTel responder will follow the specified protocol for handling of incidents, formulated by your company and VelocityEHS ChemTel.
• Authorities will be immediately contacted if deemed necessary.

Completed driver logs will be made available through internet access on a VelocityEHS ChemTel website or can be faxed or emailed.

REGULATORY REPORTING

With the increased focus on regulatory enforcement in today’s environment, companies are under constant pressure to stay informed of new and changing regulations, while at the same time facing staffing cutbacks and budgetary restrictions. The stress of impending fines for non-compliance looms large over the heads of small, medium and large businesses alike.

Outsourcing reporting tasks is a natural alternative for many regulatory reporting requirements. VelocityEHS ChemTel regulatory specialists will assist our clients evaluate hazardous materials inventories and facility diagrams to determine reporting requirements.

Tier II Reporting

VelocityEHS ChemTel is adept at filing Tier II reports in all 50 states. Our reporting services streamline and simplify the Tier II reporting process and provides a valuable solution for clients with multiple facilities and limited EH&S staff. An added benefit is the centralization of client’s regulatory reporting. Our technical department will assist in the compilation of your data in order to ensure accuracy and integrity in the reporting process.

Frequently Asked Questions Regarding Tier II Reports:

Who must report?
If you store, use or produce chemicals, requiring maintenance of Safety Data Sheets (SDS) under the Hazard Communication Standard, that are present in your facility in excess of the appropriate threshold, and are not exempt under Title III, then you must submit Section 311 and Section 312 (Tier II) reports.

What is a "reportable chemical"?
As defined by the EPA, a "reportable chemical" refers to hazardous chemicals and extremely hazardous substances present at your facility in excess of the relevant reporting threshold and not exempt under Title III.

How do I determine the "maximum amount"?
You must consider the daily (weekly, monthly) amounts (in pounds) of each reportable chemical at your facility. The amounts should vary as shipments increase your inventory and regular use depletes it. The "maximum amount" occurs for each chemical when its storage level reaches its highest point for that year. Reporting thresholds depend on the "maximum amount.”

How do I calculate the "average daily amount"?
Weights of reportable chemicals may be measured daily, weekly, or monthly as appropriate to your type of operation. For every reportable chemical, consider the number of days (weeks, months) that chemical is at your facility and compute its daily (weekly, monthly) storage weight. Then total these numbers and divide by the number of days (weeks, months) the chemical is on-site.

How specific must I be in reporting "general location"?
Is a site plan necessary?
For the Tier II form, you must indicate at least the building, lot, warehouse, shed, tank, field, etc. where the chemical is stored. On the Tier II form, where practical, the specific room in a building or quadrant of a field should also be noted. The EPA also recommends that you use a site-plan to indicate where chemicals are stored at your facility. Simply copy the facility plans and mark all appropriate storage areas for your reportable chemicals. Show all symbols and abbreviations in a complete, clear notation key.

ENVIRONMENTAL HEALTH & SAFETY RESOURCES

WERCS SUPPORT

The WERCSmart Program is a chemical assessment review process that is required by some retailers, including Wal-Mart, Sam’s Club, Sears, Safeway, Kmart, and others. WERCS operates by having the vendor input the product formulation, physical data, and other information into a web interface. WERCS then reviews the information, accepts or declines it, and if accepted, sends to the retailer. The process can be confusing at times, and long delays can occur if the information is not entered correctly. We can assist you with your WERCS submissions to ensure your products are completed as soon as possible and at the lowest cost.

We can provide help in the following areas:

• Full product submission
• Review information before submission
• Create SDS to be submitted
• Add additional UPC’s