The Service Area Door That Was Opened by Someone Else
It is 8:40 p.m. at a New Jersey Turnpike service area. You are hauling 20 drums of UN1830, Sulfuric acid, Class 8, PG II, 400 lb each (8,000 lb total), on a placarded van trailer from Newark to a plant in Swedesboro. You locked the trailer at 8:05 and went inside to eat.
Returning ten minutes later, you find the rear roll-up door raised about two feet. One drum is lying on its side at the edge of the trailer floor with a puncture at the chime, and a pool of fuming liquid roughly six feet across is spreading on the pavement. Two people nearby are coughing; a third is sitting on the ground. A person in a gray hooded sweatshirt was seen walking quickly toward the fuel islands. Your own nose and throat are burning, and the wind is pushing the fume toward the building.
1. Give your actions for the first five minutes, in priority order, and explain what you must not do.
Read the worked answer
First: distance and air. Move upwind and uphill of the pool, and get the coughing bystanders moving the same way. Sulfuric acid fume is doing damage with every breath, including yours; you are useless as a witness if you become a casualty.
Second: call 911. Give the dispatcher a precise picture: New Jersey Turnpike service area, a punctured drum of sulfuric acid, a pool of unknown size, fumes moving toward the building, at least three people affected, and a possible tampering suspect last seen walking toward the fuel islands in a gray hoodie. Say the words "corrosive" and "hazardous materials."
Third: keep everyone else out. Stop people walking toward the pool, keep vehicles from driving through it, and stay back yourself. Do not attempt to right the drum, plug the puncture, or drag it out of the trailer - a 400-lb drum of acid on a tilted trailer floor is a mechanism for getting acid on you.
Fourth: be the information source. When fire and police arrive, hand over the shipping paper and the emergency response information, and state the class, quantity, packing group and the material's name exactly as written.
Must not do: do not move the truck; do not wash the spill down a drain or hose it toward a storm sewer; do not chase the suspect; do not try to neutralize an 8,000-lb load's spill with a handful of soda ash; do not leave the scene before responders have your statement.
2. Who must be notified, by whom, and within what time? Identify which reporting criteria this incident meets.
Read the worked answer
The person in physical possession of the material at the time of the incident - you, and through you the carrier - must make the immediate notification. Do not assume the fire department will do it; their notification does not discharge the carrier's obligation.
Criteria met here:
- A person was transported and admitted to a hospital as a result of the incident.
- A facility used by the public - the service area - was closed or disrupted for more than an hour.
- Property damage is likely to exceed $50,000 once the drum, the trailer floor, the pavement and cleanup are counted; confirm with the carrier, but plan as though it does.
- An unintentional release of a corrosive occurred.
Notifications:
- National Response Center, 1-800-424-8802, by telephone as soon as practicable and no later than 12 hours after the incident. Have the material, quantity, location, injuries and carrier information ready.
- New Jersey DEP spill hotline, for a release in New Jersey, plus whatever state police or turnpike authority notification the responding officers direct.
- Your carrier's 24-hour number and the shipper/consignee, immediately, so the shipper can assist with cleanup and product information.
- Written report on DOT Form 5800.1 to PHMSA within 30 days, covering the same event in detail.
Record times, names and reference numbers for every call. The written report is checked against the phone log.
3. The raised door and the departing stranger suggest something other than a load shift. What does that change about how you handle the scene and what you do afterward?
Read the worked answer
Treat it as a possible criminal act against a hazardous materials shipment until it is proven otherwise, and adjust accordingly.
At the scene:
- Tell the responding officers exactly what you told 911 - door raised, drum punctured at the chime, a person leaving the immediate area, direction of travel, clothing, approximate height and build. A puncture at the chime of a drum that was loaded upright is not a normal road-damage pattern.
- Touch nothing on the trailer until responders release it. Anything the suspect handled is potential evidence; anything he loosened is a second leak waiting.
- When it is safe and authorized, do a deliberate check of the rest of the load with the responders - other drums shifted, bungs loosened, seals cut, anything added to or removed from the trailer.
- Do not pursue, confront or photograph a fleeing person.
Afterward:
- Notify your carrier's security contact the same night, and file the internal security report alongside the incident report.
- Note whether the trailer seal was intact at your last stop and where the last unescorted stop was. Unescorted stops are the highest-risk window in a hazmat run.
- Review what the carrier's security plan requires for en route security, and expect a re-brief on parking, locking and reporting suspicious activity.
The exam point: your security duties do not end when an incident starts, and the emergency report and the security report are two separate obligations that both have to be met.