Safety Recommendation A-97-080

A-97-80 ASKED THE USPS TO DEVELOP A PROGRAM FOR USPS EMPLOYEES TO HELP THEM IDENTIFY UNDECLARED HAZMAT BEING OFFERED FOR TRANSPORTATION. BECAUSE THE USPS' ACTIONS MEET THE INTENT OF A-97-80, IT IS CLASSIFIED "CLOSED--ACCEPTABLE ACTION."

Letter Mail Controlled 3/15/99 4:13:38 PM MC# 990243 IN OUR FEBRUARY LETTER, WE IDENTIFIED VARIOUS HAZMAT AWARENESS-TRAINING PROGRAMS BEING PROVIDED TO THOUSANDS OF OUR EMPLOYEES NATIONWIDE. WE HAVE ALSO ISSUED NATIONAL HAZMAT HANDLING INSTRUCTIONS SIGNED BY THE POSTMASTER GENERAL, TO ALL POSTAL SERVICE AIRPORT MAIL FACILITIES THAT ASSIGN AND TENDER MAIL FOR AIR TRANSPORTATION. THESE INSTRUCTIONS DEFINE THE PROPER HANDLING PROCEDURES FOR DECLARED/UNDECLARED PARCELS FOUND IN THE MAIL. IN COORDINATION WITH OUR AVIATION MAIL SECURITY GROUP, THE FAA'S VOLPE CENTER HAS BEEN CONTRACTED TO TAILOR HAZARDOUS MATERIAL TRAINING MODULES TO FIT POSTAL REGULATIONS.

THESE TRAINING MODULES SPECIFICALLY ADDRESS EMPLOYEE AWARENESS, ACCEPTANCE, HANDLING AND PROCESSING PROCEDURES, PROPER TRANSPORTATION ASSIGNMENT, TENDER AND HANDOFF FOR HAZMAT PARCELS REQUIRING AIR TRANSPORTATION. THE ACTUAL TRAINING IS SCHEDULED TO BEGIN IN MAY 1999. IT IS EXPECTED THAT OVER 2,000 POSTAL SERVICE AIRPORT EMPLOYEES ASSIGNED TO HANDLE HAZMAT WILL BE TRAINED BY DECEMBER 1999. (ADDITIONAL INFORMATION WAS PROVIDED BY PHONE CONVERSATION WITH MR. BILL CARLTON, THE USPS REPRESENTATIVE FOR THIS ACTION)

ALTHOUGH THE USPS RESPONSE LETTER CONTAINED SOME INFORMATION ABOUT POSTAL EMPLOYEE TRAINING, IT CONTAINED NO INFORMATION SPECIFICALLY RELATED TO A-97-80. THE SAFETY BOARD WOULD APPRECIATE RECEIVING SPECIFIC INFORMATION RELATED TO USPS TRAINING THAT ASSISTS ALL EMPLOYEES IN IDENTIFYING UNDECLARED HAZARDOUS MATERIALS FOR TRANSPORTATION. THE BOARD WOULD APPRECIATE RECEIVING INFORMATION ON THE CONTENT OF THE TRAINING PROVIDED AND THE NUMBER OF USPS EMPLOYEES RECEIVING SUCH TRAINING. PENDING RECEIPT OF INFORMATION ON SUCH A TRAINING PROGRAM, A-97-80 IS CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE."

Letter Mail Controlled 3/3/98 2:41:01 PM MC# 980285 THE USPS PROVIDES ONGOING HAZMAT TRAINING MODULES DEVELOPED INTERNALLY WITH THE ASSISTANCE OF CONSULTANTS AND THROUGH INTERAGENCY AGREEMENTS. THOUSANDS OF POSTAL EMPLOYEES RECEIVE ANNUAL TRAINING IN HAZMAT PACKAGING/LABELING/ACCEPTANCE PROCEDURES, AIRPORT TRANSFER/RAMP CLERK TRAINING, RAPID EMERGENCY RESPONSE, OSHA AND EPA REQUIREMENTS AND MANY OTHERS. THE USPS VERY NARROWLY LIMITS AND STRICTLY REGULATES THE CLASS AND QUANTITY OF HAZMAT ACCEPTED IN THE MAIL.

REVISED PROCEDURES ARE BEING ISSUED TO FIELD UNITES AROUND THE COUNTRY TO ENSURE THAT THE IDENTITY OF HAZMAT IS MAINTAINED THROUGHOUT PROCESSING AND THAT HAZMAT CONTINUES TO BE TENDERED PROPERLY TO COMMERCIAL AIRLINES. AN IMPORTANT PART OF THESE PROCEDURES IS SPECIFIC GUIDANCE TO RECOGNIZE INDICATORS WHICH MAY POINT TO UNDECLARED HAZMAT IN THE MAILSTREAM.

THE BOARD NOTES THAT THE USPS HAS ESTABLISHED A HAZARDOUS MATERIALS WORKING GROUP & THE REPRESENTATIVES HAVE ALREADY MET WITH MANAGER OF THE DANGEROUS GOODS & CARGO SECURITY DIVISION OF THE FAA TO BEGIN A JOINT EFFORT TO STRENGTHEN THE USPS HAZARDOUS MATERIALS PROGRAM. THE BOARD ALSO NOTES THAT USPS REPRESENTATIVES HAVE "MET WITH MEMBERS OF THE FAA'S VOLPE CENTER TO DETERMINE WHAT TRAINING MATERIALS & COURSES THEY HAVE THAT MIGHT BE USEFUL IN TRAINING POSTAL EMPLOYEES & EDUCATING POSTAL CUSTOMERS ON HAZARDOUS MATERIALS.

THE BOARD IS AWARE THAT THE VOLPE NATIONAL TRANSPORTATION SYSTEMS CENTER IS CONDUCTING A QUANTITATIVE RISK ANALYSIS OF TRANSPORTING HAZARDOUS MATERIALS IN AIRCRAFT CARGO COMPARTMENTS FOR THE DOT'S RESEARCH & SPECIAL PROGRAMS ADMINISTRATION; HOWEVER, WE ARE NOT AWARE OF ANY HAZARDOUS MATERIALS TRAINING PROGRAMS OFFERED BY THE CENTER. THE BOARD WOULD APPRECIATE SPECIFIC INFO ON WHAT PROGRAMS ARE AVAILABLE & HOW THE USPS INTEND TO INCORPORATE THEM INTO ITS PROGRAM.

THE BOARD WOULD ALSO APPRECIATE INFO ON THE SPECIFIC MECHANISMS THAT THE USPS WILL USE TO EDUCATE POSTAL CUSTOMERS ABOUT THE RESTRICTIONS OF OFFERING CERTAIN HAZARDOUS MATERIALS THROUGH THE MAIL & THE POTENTIAL DISASTROUS CONSEQUENCES OF SUCH AN ACT, & ABOUT THE PROGRAMS THAT WILL BE PROVIDED TO HELP POSTAL EMPOYEES IDENTIFY UNDECLARED HAZARDOUS MATERIALS OFERED BY MAIL. IN ADDITION TO EMPLOYEE TRAINING, THE USPS SHOULD ADDRESS THE NEED TO QUESTION THE CONTENTS OF PACKAGES. PENDING THIS ADDITIONAL INFO A-97-79 & -80 ARE CLASSIFIED "OPEN--ACCEPTABLE RESPONSE."

THE POSTAL SERVICE DOES FULLY RECOGNIZE THE RISK THAT UNDECLARED HAZARDOUS MATERIALS SHIPMENTS, INCLUDING MAIL SHIPMENTS, CAN PRESENT TO AVIATION, ESPECIALLY PASSENGER-CARRYING AIRCRAFT. FURTHER, IT RECOGNIZES & ACKNOWLEDGES ITS RESPONSIBILITIES TO MINIMIZE THE OPPORTUNITIES FOR UNDECLARED HAZARDOUS MATERIALS IN THE MAIL TO BE TRANSPORTED BY AIR. WE TAKE THIS RESPONSIBILITY VERY SERIOUSLY. THE POSTAL SERVICE CONCURS IN THE NTSB'S RECOMMENDATION A-97-80, & MY STAFF HAS MET WITH MEMBERS OF THE FAA'S VOLPE CENTER TO DETERMINE WHAT TRAINING MATERIALS & COURSES THEY HAVE THAT MIGHT BE USEFUL IN TRAINING POSTAL EMPLOYEES & EDUCATING POSTAL CUSTOMERS ON HAZARDOUS MATERIALS.