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♦ New FAA enforcement enhancement objectives are currently looking hard at shipper training records to verify employee training is more than superficial. Enforcement data suggests that shippers are "speed dating" employee training and not providing sufficient training to meet regulatory requirements and many shippers are extending the 90-day supervision requirement due to budget and economic restraints and conditions. FAA offices in Atlanta, New Jersey, Dallas, Chicago and Dulles have all received orders to enhance inspections to include functional and security training commensurate with the company's transportation objectives.
An FAA note to shippers: The 90-day supervision rule runs out after 90 days!
♦ An increased number of shippers have been found to have not provided hazmat and dangerous goods training to employees that are administrating UPS, FedEx and DHL type shipments. Shippers need to provide and prescribe applicable training to employees that process carrier air waybills and employees that book shipments and cargo that is hazardous. FAA agents are looking more closely at the persons that are generating the air waybills at the end of the day.
Shippers and forwarders need to review hazardous materials and dangerous goods training and security requirements to ensure that they are current with the regulations. There have been significant changes in the last 3 to 4 years.
♦ FAA enforcement agents are checking shipper responsibilities for closure instructions and paperwork retention. Enforcement agents are also taking a "look back" of 24+ months at FedEx & UPS papers and documents related to hazmat and dangerous goods shipments.
Shippers are not retaining and maintaining paperwork for contracted 3rd party providers for paper retention requirements. When a shipper or forwarder contracts a sub-contractor, the shipper and subcontractor are both held responsible. Shippers and forwarders need to keep the "hard copies" of these files for presentation during FAA audits. Shippers don't want an FAA audit of corporate computer system files. That could include literally looking over your shoulder while you search company computer files for electronic information. The FAA will do whatever is has to do to collect hazmat history.
♦ FAA reports "A record year for/of leakers". Enforcement agents are focusing on shipper requirements for liquid hazmats & dangerous goods. Combination and single package pressure retention, secondary closure, leak proof liner and quantity limitations are all enhanced agent inspection requirements.
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