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Safety Recommendation Details

Safety Recommendation I-90-001
Details
Synopsis: ABOUT 11:30 A.M., ON NOVEMBER 30, 1988, A TRACTOR-FLATBED SEMITRAILER OPERATED BY HY YIELD BROMINE COMPANY OVERTURNED AT THE INTERSECTION OF TWO FARM ROADS IN A SPARSELY POPULATED AREA OF COLLER COUNTY, FLORIDA. THE SEMITRAILER WAS LOADED WITH 32 CYLINDERS OF A POISONOUS AND TOXIC BY INHALATION MIXTURE, 98 PERCENT METHYL BROMIDE AND 2 PERCENT CHLOROPICRIN. ELEVEN OF THE CYLINDERS WERE FULL, EACH CONTAINING ABOUT 1,500 POUNDS OF THE POISONOUS MIXTURE, AND THE REMAINDER OF THE CYLINDERS WERE PARTIALLY FULL OR EMPTY EXCEPT FOR RESIDUE. THE DRIVER HAD COMPLETED THE SECOND OF FOUR SCHEDULED STOPS WHEN THE ACCIDENT OCCURRED.
Recommendation: THE NTST RECOMMENDS THAT THE HY YIELD BROMINE COMPANY: ESTABLISH A PROCEDURE TO DISTINGUISH CYLINDERS THAT CONTAIN SIGNIFICANT QUANTITIES OF HAZARDOUS MATERIALS FROM THOSE THAT ARE EMPTY (EXCEPT FOR HAZARDOUS MATERIALS RESIDUE) WHEN IN TRANSPORTATION, AND REQUIRE APPROPRIATE SHIPPING PAPER NOTATIONS.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Intermodal
Location: Collier County, FL, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA89MZ001
Accident Reports: ​Puncture of a Cylinder Containing a Mixture of Methyl Bromide and Chloropicrin Following the Overturn of a Tractor/Semitrailer
Report #: HZM-90-01
Accident Date: 11/30/1988
Issue Date: 3/23/1990
Date Closed: 7/29/1993
Addressee(s) and Addressee Status: Hy Yield Bromine Company (Closed - Acceptable Action)
Keyword(s): Hazmat

Safety Recommendation History
From: NTSB
To: Hy Yield Bromine Company
Date: 7/29/1993
Response: THE BOARD NOTES THAT THE HY YIELD SAFETY MANUAL ESTABLISHES WRITTEN OBJECTIVES & PROCEDURES FOR HIRING & QUALIFYING DRIVERS, INITIAL & RECURRENT TRAINING, THE REVIEW OF DRIVER PERFORMANCE, & THE MONITORING OF DRIVERS' HOURS OF SERVICE. THE BOARD FURTHER NOTES THAT HY YIELD HAS INCLUDED IN THE SAFETY MANUAL CARGO RESTRAINT PROCEDURES THAT DRIVERS MUST FOLLOW & HAS IMPLEMENTED A COLOR CODE SYSTEM TO DISTINGUISH FULL, PARTIALLY FULL, & EMPTY CYLINDERS IN TRANSIT. THE BOARD BELIEVES THAT THE POLICIES & PROCEDURES ESTABLISHED IN THE SAFETY MANUAL SATISFY THE OBJECTIVES OF THE RECOMMENDATIONS MADE TO HY YIELD. BECAUSE OF THE POSITIVE ACTIONS TAKEN BY HY YIELD TO ADDRESS THESE SAFETY ISSUES, SAFETY RECOMMENDATIONS H-90-8, H-90-9 AND I-90-1 ARE CLASSIFIED "CLOSED--ACCEPTABLE ACTION."

From: Hy Yield Bromine Company
To: NTSB
Date: 6/1/1993
Response: ON MAY 29, 1990, HY YIELD RESPONDED THAT IT AGREED WITH THE RECOMMENDATIONS MADE BY THE BOARD. ON JUNE 1, 1993, HY YIELD PROVIDED A COPY OF THE COMPANY'S WRITTEN TRANSPORTION MANUAL THAT HAD BEEN REQUESTED BY THE BOARD ON SEPTEMBER 11, 1990. THE MANUAL WAS SENT AFTER A FOLLOW-UP TELEPHONE REQUEST BY HAZARDOUS MATERIALS DIVISION STAFF.

From: NTSB
To: Hy Yield Bromine Company
Date: 9/11/1990
Response: With respect to the issue of distinguishing cylinders that contain significant quantities of hazardous materials from those that are empty, as addressed in Safety Recommendation I-90-1, the Safety Board notes that Hy Yield Bromine has decided to use a color-coded tagging system. Because the success of this system depends on the customer properly tagging and identifying all returned cylinders, the Safety Board believes that Hy Yield Bromine should evaluate its customers' adherence to the color-coded tagging system to determine the effectiveness of the system. Further, the Safety Board suggests that the tagging codes be prominently placed on the cylinders and the bills of lading to ensure that emergency response personnel can readily determine the approximate quantity of material contained in the cylinders. The Safety Board notes your statements that (1) the practice of using the same bill of lading for outbound and return loads has been discontinued, (2) drivers now carry blank forms so they can properly identify their loads, and (3) a new form will be used for bill of lading returns. Although the use of a separate form to track returned cylinders appears to be an improvement over the previous practice, it is unclear from your response as to whether the driver or the customer will be responsible for filling out the form for returned cylinders. The Safety Board would appreciate more detailed information regarding the use of these forms and the particular responsibilities of the driver and the customer in using these forms. The Board also believes that because a new procedure is being implemented, Hy Yield Bromine needs to review the use of these forms to determine the effectiveness of the new procedure. Pending your response to these Safety Board comments, Safety Recommendation I-90-1 will be held in an "Open--Acceptable Response" status.

From: Hy Yield Bromine Company
To: NTSB
Date: 5/29/1990
Response: The recommendations expressed in the NTSB report dated March 211, 1990 are all sound and certainly we should adopt them as our minimum standards. Shortly after the Nov. 1988 accident we began to reevaluate and change our transportation procedures. That process is ongoing and will be evaluated periodically in the future. The following is an update on our current progress. A safe transportation manual is in the process of being developed. This manual will include procedures for hiring and qualifying drivers. Basic information on our fumigant products. A medical examination and drug testing program. Requirements for road test and written tests. Objectives for safe delivery of our products. Standards of behavior while operating company vehicles. Standards of behavior at the customer's premise. Scheduling standards to comply with log book requirements. System to monitor driver hours. Accident management recommendations carried on the truck. A. Information on board to help rescue personnel. B. List of phone numbers on board to contact other personnel. C. Recommendations on evacuation. D. First Aid recommendations. E. Safety equipment. Prior to completion of this manual we have already adopted many of these items. The following is the portion of this manual that have [sic] been in practice: We conduct annual reviews of the drivers, including an MRV report. 6. We have adopted the 8 day, 70 hour log system and monitor it very closely. 7. Safety equipment on board includes a Self Contained Breathing Apparatus and water in addition to the regular DOT safety equipment. Our safe transportation manual will include requirements for securing cylinders. Currently we have adopted the following system. Our large cylinders are positioned on the truck when full SO that the nose ring of one row fits inside the butt ring of the adjacent row. Each row of 3 cylinders (5700 lbs) is secured by d 4" nylon strap rated at 12,000 lbs. In addition, the first row and the last row are secured by 2 each 12,000 lb. straps . 'the small cylinders are banded 10 to a pallet in a staggered fashion. Two horizontal bands are used along with a third vertical band that secures the cylinders to the pallet. The large cylinders are returned empty to our plant in the vertical position. Each row of three is secured with a 12,000 lb. strap. The small cylinders are returned stacked horizontally in rows. Each row is secured with a 12,000 lb. strap. The identification of returned cylinders has been a problem for both transportation purposes and customer crediting purposes. Finding tags that will not be Lost in the wind and the rain is difficult. In recent discussions we have decided to try a new system. This system will use plastic tags similar to those used in nurseries to identify plants. These tags will be color coded and printed to aid in identification. The code is as follows; Red Full cylinder Yellow Partial cylinder White Empty cylinder No tag Full cylinder. All outbound loads will not be tagged as they will all be full. All return cylinder will be tagged and identified by customer on the reverse ride. A supply of these tags will be carried by all drivers, salesmen, distributor salesmen, and distribution warehouses. They will also be available to any grower who wishes to tag his own for proper credit. we have discontinued the practice of using the same bill Of lading for outbound and return loads. Our drivers now carry blank forms SO they can properly identify their loads. We also have decided to adopt a separate form for Bill Of Lading returns -The new form will be a different size and contain wording specific to cylinder returns. All of these procedures have been either adopted or are in process. Please notify me if you see any deficiencies. Thank you.