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Safety Recommendation Details

Safety Recommendation I-90-011
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 COLLIER 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 NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: DEVELOP AND IMPLEMENT REQUIREMENTS FOR IMPROVING THE VISIBILITY AND EFFECTIVENESS OF HAZARDOUS MATERIALS PLACARDS, CONSIDERING THE ORIENTATION OF VEHICLES AFTER ACCIDENTS.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Unacceptable 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: 10/4/1995
Addressee(s) and Addressee Status: RSPA (Closed - Unacceptable Action)
Keyword(s): Hazmat

Safety Recommendation History
From: NTSB
To: RSPA
Date: 10/4/1995
Response: THE BOARD COMMENTED ON BOTH RULEMAKINGS & SUPPORTED REQUIREMENTS TO IMPROVE THE EFFECTIVENESS OF PLACARDS. HOWEVER, RSPA STATED THAT IT DOES NOT PLAN TO MAKE CHANGES IN PLACARDING REQUIREMENTS BASED ON COMMENTS RECEIVED TO THE ANPRM. THEREFORE, I-90-11 IS CLASSIFIED "CLOSED--UNACCEPTABLE ACTION."

From: RSPA
To: NTSB
Date: 7/28/1995
Response: AN ANPRM WAS PUBLISHED IN 1992 UNDER DOCKET HM-206 WHICH ADDRESSED THIS RECOMMENDATION. BASED ON COMMENTS RECEIVED CONCERNING COST & OPERATIONAL CONSIDERATIONS THE ITEM WAS NOT PROPOSED IN THE SUBSEQUENT NPRM. WE NOT PLAN ANY FURTHER RULEMAKING ACTION IN THIS AREA IN THE FUTURE. THEY REQUESTED THAT THE SR BE CLASSIFIED "CLOSED-RECONSIDERED."

From: NTSB
To: RSPA
Date: 7/8/1994
Response: THE BOARD NOTES THAT RSPA PUBLISHED AN ANPRM IN JUNE 1992 UNDER DOCKET HM-206 THAT ADDRESSES THE LOCATION, ATTACHMENT, & TYPE OF PLACARD, & THAT RSPA ALSO PLANS TO PUBLISH THE NPRM IN 1994. BECAUSE OF THIS ON-GOING PROGRESS, I-90-11 IS CLASSIFIED "OPEN--ACCETABLE RESPONSE."

From: RSPA
To: NTSB
Date: 5/3/1994
Response: RSPA IS ADDRESSING THIS RECOMMENDATION UNDER DOCKET HM-206, IMPROVING HAZARDOUS MATERIALS IDENTIFICATION SYSTEMS. THE LOCATION, ATTATCHMENT & TYPE OF PLACARD IS BEING ADDRESSED & WILL TAKE INTO CONSIDERATION THE POSITION OF THE VEHICLE AFTER AN ACCIDENT. THE ANPRM WAS PUBLISHED IN JUNE 1992, & THE NPRM IS UNDER DEVELOPMENT & PLANNED FOR PUBLICATION DURING THE FIRST HALF OF THIS YEAR.

From: NTSB
To: RSPA
Date: 6/21/1993
Response: OUR RECORDS SHOW THAT WE HAVE NOT RECEIVED ANY FURTHER RESPONSE FROM THE RSPA REGARDING THESE RECOMMENDATIONS. WE WOULD APPRECIATE BEING INFORMED ABOUT EFFORTS THAT HAVE BEEN OR ARE BEING MADE TO IMPLEMENT THESE RECOMMENDATIONS.

From: NTSB
To: RSPA
Date: 12/13/1990
Response:

From: RSPA
To: NTSB
Date: 9/24/1990
Response: ALTHOUGH NOT SPECIFICALLY STATED, THE RECOMMENDATION APPEARS TO BE AVOCATING THE ADDITION OF TWO MORE PLACARDS (ONE ON THE TOP AND ONE ON THE BOTTOM) TO VEHICLES ALONG WITH THE FOUR THAT ARE REQUIRED BY CURRENT REGULATIONS (ONE ON EACH SIDE AND EACH END). THE CURRENT RULE IS VERY EFFECTIVE WHEN IT IS FOLLOWED AND, IN MOST CASES WHEN A TRUCK OVERTURNS AT LEAST TWO PLACARDS ARE VISIBLE FOR FIRST RESPONDERS TO SEE. THE DIFFICULTY IN IDENTIFYING THE PLACARDS ON THE TRUCK IN THE COLLIER COUNTY ACCIDENT APPEARS TO BE MORE RELATED TO THE TYPE OF VEHICLE INVOLVED (FLAT-BED TRAILER) AND THE EMERGENCY RESPONSE TRAINING OF THE FIRST RESPONDERS. INSTALLATION OF THE PLACARDS ON THE TOP AND BOTTOM OF TRUCKS WOULD NOT BE A SIMPLE SOLUTION SINCE THERE MAY BE SUBSTAINAL SAFETY AND COST EFFECTS. PLACING ADDITIONAL PLACARDS IN THESE LOCATIONS WOULD EXPOSE TRANSPORTATION WORKERS TO CONDITIONS THAT RESULT IN INJURIES FROM BUMPS, SLIPS AND FALLS. THE RISK ASSOCIATED WITH PLACEMENT, CLEANING AND/OR REMOVAL OF TENS-OF-THOUSANDS OF PLACARDS A DAY FAR OUTWEIGHS THE BENEFITS TO BE GAINED FROM AN ADDITIONAL COMMUNICATION THAT WOULD BE HELPFUL ONLY ON RARE OCCASIONS. FURTHER, SUCH A PROPOSAL WOULD RESULT IN ADDITIONAL COSTS FOR PLACARDS AND FOR CLEANING AND MAINTENANCE. RSPA CONCLUDES THAT THIS PROPOSAL IS NOT COST BENEFICAIAL AND IS COUNTERPRODUCTIVE TO SAFETY SINCE IT WOULD LIKELY RESULT IN A NET GAIN IN INJURIES. RSPA CONCLUDES THAT RECOMMENDATION I-90-11 SHOULD NOT BE PROMULGATED AS A REGULATION BECAUSE ITS COSTS WOULD SUBTANTIALLY EXCEED ITS BENEFIT. ACCORDINGLY, WE REQUEST THAT RECOMMENDATION I-90-11 BE CLASSIFIED AS "CLOSED ACCEPTABLE ACTION."