We understand that having a Federal Inspector at your door can be daunting. The inspector's goal is not to issue fines or to interfere with your operations. They aim to work with you to ensure compliance with the regulations, minimize risk, and ensure safety in transporting hazardous materials or dangerous goods by air.

The Office of Hazardous Materials Safety's objective is to correctly identify and work with you to fix the root causes of noncompliance permanently, such as a lack of understanding or flawed procedures. Generally, we are willing to collaborate if you can cooperate and do not have an egregious violation history. We usually issue civil penalties as a last resort when a regulated party is unwilling or unable to comply, evidence supports an intentional deviation, reckless or criminal behavior, or we discover a significant safety risk.

Here is a basic breakdown of what to expect during a shipper, freight forwarder, or repair station inspection:

Document Review

• Package Closure Instructions
  *Must be retained for 90 days after acceptance by the initial carrier
   
• Special Permit Documentation & Special Permit Training Records
  *If shipping under a Special Permit(s)
   
• Shippers Declarations (aka Shipping Papers) – Click here for a fillable Dangerous Goods Declaration.
  *Two-year retention for Shippers, One year for an Air Carrier
   
• Training Records for hazmat employees. General and security awareness, safety, modal, and function-specific training are required.
  * A hazmat employee must be trained at least once every three years, and the hazmat employer must retain records of training
  *In-depth security training, if applicable
   
• Shipper Registration
  *If applicable, click here
   
• Safety and Security Plans
  
  
• UN 38.3 Testing
  *This requirement is only applicable to Lithium Battery Shipments
   
• Safety Data Sheets *Provided by the manufacturer or supplier
  • Identification number
  • Proper shipping name
  • Hazard class or division
  • Packing group

Laboratory inspection

• Has the individual who selected the HAZMAT packaging received HAZMAT training?
• Has the individual securing a closure on a hazardous materials package or container received Hazmat training?
• Has the individual responsible for filling inner or single packagings received training?
• Classification when executed through laboratory testing.

Warehouse inspection

• Warehouse storage and segregation of HAZMAT
  • Was the material properly segregated in the warehouse?
• Marking
  • Was the package correctly marked and unobscured?
  • Were the proper markings on hand?
• Labeling
  • Was the package correctly labeled and unobscured?
  • Were the proper labels on hand?
  • Were the subsidiary labels correctly marked and unobscured?
• Emergency Response Information
  • Was the emergency response number monitored at all times the hazardous material was in transportation?
  • Was the person who answered knowledgeable of the HAZMAT being shipped?
  • Were they able to provide comprehensive response and incident mitigation information for the material?
• Packaging
  • View information on packaging your HazMat
  • Is UN Specification packaging required?
  • If so, did the shipper follow the closure instructions?
  • Is the packing group¹ of the material compliant with the UN Specification markings?
  • Does the weight of the inner packaging exceed the rated capacity of the package?
  • Proper Packing Materials
    • Does the shipper have the proper tools for securing lids, i.e., torque wrenches and calibration equipment?
    • Does the shipper have the proper supplies, such as tape, absorbent material, cushioning, etc., as specified in the package closure instructions?

Does the shipper have the proper supplies, such as tape, absorbent material, cushioning, etc., as specified in the package closure instructions?

Common inspection findings

• Misclassification
  • Packing group for flammable liquids
  • Errors when materials present more than one hazard
• Packaging and closing procedures
  • Non-specification packaging used when required
  • Inner containers not authorized
  • Improper final closing of specification packages
  • Gross mass of package not authorized (e.g., overstuffing)
• Shipping paper errors
  • Improper shipping name
  • Improper UN number
  • Additional description requirements are missing
  • Hazardous Substances (RQ)
  • Improper technical name for NOS material
  • The shipper's declaration was signed by someone other than the person who prepared the package
• Invalid emergency response information
  • Telephone not monitored² while in transportation
  • The company is not registered with the third-party provider
  • The person is not knowledgeable about the material
  • Requires call-back
• Training Violations
  • No training
  • Not all employees performing a transportation or pre-transportation function have received training
  • No modal-specific training
  • Record-keeping Requirements
  • Missing information on training records
• Marking and Labeling Violations
  • The markings or labels were obscured
  • Missing subsidiary hazard labels
  • Out-of-date markings or labels

¹ Packing Groups I, II, and III indicate the degree of danger the material presents - great, medium, or minor, respectively.

² Emergency Telephone Number staffed 24 hours per day while shipment is in transit.

Post Inspection Expectations

The inspector should provide an out briefing to notify you of any concerns or discrepancies found during the inspection. You will likely receive a Letter of Investigation within ten days of the inspection if there were findings. A Letter of Investigation is an investigative tool that serves the dual purposes of notifying an alleged violator that they are under investigation and providing them with an opportunity to respond to allegations.

For more information, refer to the compliance and enforcement section of Safe Cargo.