Recently, we have seen an increase in hazardous material (hazmat) shipping violations. In an effort to reduce these violations and protect the safety of your dealer employees and others, we are reiterating the requirement that any dealership personel performing the shipping function to be properly trained and certified. Also, we are providing some common violations that are noticed.
· Shipped hazmat part using UPS. All hazmat parts need to be returned using Central Transport.
· Bill of Lading (BOL) not properly filled out. The UN# that identifies the hazardous material being shipped must be selected on the BOL. Place an “X” in the column marked H.M. next to the correct UN#.
· Used a printed paper copy of the required label. Labels must meet certain durability requirements. A validated and approved label must be used.
· Package had label but was missing UN# and proper shipping name (commodity description). This can be written using a marker and must be on the same side/surface as the label. Labels can be purchased with the UN# and description as part of the label.
Previously, GM published multiple messages requesting verification of your hazmat training certification. If you have not already done so, please email proof of training to: email@example.com. Also, include your dealership BAC and the name and title of the person who is certified. Through May 2021, 21% of our dealers are still not certified to ship hazardous material.
When shipping any automotive hazardous materials to the Warranty Parts Center dealership service agents must follow all hazmat shipping requirements. The shipments must comply with applicable federal regulations, including being properly classified, described, marked, packaged, labeled, and in condition for shipment, and all persons performing the shipping functions in the dealership must be trained.
If the shipment is found in violation of Dangerous Good shipping protocol for any reason, the claim could be debited. In addition, any person knowingly violating a hazmat shipping requirement is liable for each offense.
For a typical automotive service facility, it is recommended that the following employees be trained:
Parts Managers – they oversee the transportation of hazmat.
Parts Shipping and Receiving – they load and unload dangerous goods and might even prepare shipping papers.
Other employees that may need to be trained include:
Parts Drivers – they may transport hazmat.
Service Technicians – they may prepare and package hazmat (e.g., an air bag being returned).
Service Managers – they may oversee hazmat employee operations and may sign for hazmat shipments or hazardous waste manifests for the proper disposal and management of their facility’s hazardous wastes.
Supervisors must also be trained, even if the supervisor is not directly responsible for any of the responsibilities listed above. Indirectly, supervisors are responsible for their employees, and their employees’ hazardous materials-related duties.
DEPARTMENT OF TRANSPORTATION HAZMAT TRAINING REQUIREMENTS
The U.S. Department of Transportation (DOT) regulates the transportation of hazardous materials. DOT regulations require that individuals shipping hazmat parts receive initial hazmat training within 90 days of starting on the job and recurring training at least every three (3) years thereafter. Dealers that ship hazmat are responsible for complying with DOT regulations. For further information regarding dangerous goods transportation, please visit the U.S. DOT website or Sections L. and H. of the 2021 GM Dealer Parts and Accessories Policies and Procedures Manual.
Please refer to Warranty Parts Center bulletin 99-00-89-019 for additional information and resources offered by GM.
Currently, the Coordinating Committee For Automotive Repair (CCAR) is offering online HazmatU subscriptions available for all US GM dealers to assist with your DOT obligations compliance:
Allows for unlimited training of employees at your dealership
CCAR provides GM with HazmatU training data on an ongoing basis
Cost is only $299.00 for 12-months of unlimited online course access
Once your dealership staff has passed the HazmatU final exam, CCAR will notify GM and your training records will be updated accordingly.
To sign up for HazmatU, call CCAR toll-free at (888) 476-5465 or go to www.HazmatU.org.