THE TANK truck industry needs to develop better and more up-to-date statistics on risk factors, including accidents and incidents. That's the only way to counter rail industry claims that the railroads are the safest way to ship hazardous materials.
Railroads currently have the edge on the controversy over which mode is safer or safest because the rail industry has better data, according to Cherry Burke, distribution safety and risk management consultant for DuPont Company. The lopsided preponderance of data makes it difficult for hazmat shippers to determine the best mode for a specific shipment.
“Railroad accident data is very centralized and up-to-date,” Burke said. “That's not the case for truck data, particularly tank truck shipments. Most risk assessments for tank truck shipments of hazardous materials are built on a Midwest Research Institute study that dates back to the 1980s. The survey used data from three states, and this data exhibited significant differences.
“For decades, the Association of American Railroads/RPI data collection and analysis effort has been examining tankcar release probabilities. There is no equivalent analysis effort for cargo tanks. All too often, shippers make the assumption that cargo tanks are less robust than tankcars. However, typical accident forces usually are not considered. In addition, many analysts fail to consider actual and maximum cargo release size in consequence estimation.
“With limited data for truck risk analysis, shippers assume rail is less risky. This probably is not true on a per-shipment basis. But it might be when viewed from a per-ton or per-ton-mile basis. Clearly, we need trucks, and we need to move hazardous materials safely by truck. To do that, we must have more and better data for tank trucks.”
Terror risk
The need for better truck risk data has become more pronounced due to heightened concern about the vulnerability of hazmat shipments to terrorist attack. Hazmat security now gets a great deal of attention, especially from government entities.
Speaking May 20 during the National Tank Truck Carriers annual conference in New Orleans, Louisiana, Burke said that companies involved in the movement of dangerous goods have had programs in place for years that provide a solid foundation for addressing terrorism threats. Industry has an excellent record of safe transportation of hazardous materials and response to incidents.
Despite the good record, a swarm of new terrorism-focused transport regulations are coming from the federal government. At the Department of Transportation, HM-232 calls for security plans and mandates other security requirements for shippers and transporters. Tests of technologies and procedures to safeguard truck shipments of hazmat are underway as part of HM-232A.
Background checks by the Federal Bureau of Investigation will be required for anyone holding a commercial driver license with a hazmat endorsement. A national transportation worker identification card that might include a requirement for a biometric indicator is in the works. “All of this sort of assumes that no terrorist would do anything with a tank truck without proper credentials,” Burke said.
The Transportation Security Administration (TSA) has said it plans to regulate hazmat transportation security. Rail movements of chlorine may be the first area covered. Risk assessment methodology is still being developed, and industry associations are meeting with TSA officials to educate and hopefully influence the direction of any new rules.
Making sense
“We're trying to show what makes sense,” Burke said. “Security needs to be a shared effort that involves shippers, carriers and other logistics providers, storage terminals and warehouses, transloading facilities, toll producers, suppliers, and customers. Most importantly, security should be integrated with our overall safety effort. They share many of the same elements, and vulnerabilities are likely to be similar during certain stages of cargo movement.
“We also believe that a systems approach is needed for the security process. Risk-based evaluations should be used to make balanced, informed decisions on security. We need good, reliable intelligence for rational baseline security efforts. We need to know what cargoes are most likely to be targeted. We must be able to adjust countermeasures to changing threat levels.”
Factors that don't help the effort to improve hazmat security are detailed commodity flow studies and location-specific vulnerability assessments of the “hot spots” that turn up in flow studies. “So many hazardous materials are on the move that the entire United States will show up as a hot spot,” she said.
Routing dictates also won't help because they just create new security vulnerabilities. “We're in the midst of security mania right now,” Burke said. “However, we have to be careful about taking steps such as major routing changes that could increase the possibility of accidents and create greater environmental risks.”
Mandatory tracking of all hazardous materials shipments would lead to information overload and chaos. However, tracking may be appropriate for certain shipments on a case-by-case basis. Extreme measures, such as removing placards from hazmat shipments, must be resisted. “We can't jeopardize our existing emergency response system,” Burke said. “Removing placards would turn the emergency response process upside down.”
Burke added that she believes the American Chemistry Council already has a good security code in place. It encompasses all chemical company activities, including all aspects of the logistics and supply chain processes. Further, it's flexible.
Burke called on tank truck carriers to lobby political representatives and customers to remain rational and balanced in their approach to transportation security. She urged tank truck carriers to be proactive in the development of their security plans and involve customers where possible. Avoid duplication of efforts, and work with customers to help them hone their own security plans. When something doesn't make sense, speak up.