Hazardous Materials Transportation (HMT)

The Firm performs Hazardous Materials Transportation (HMT) audits as one of its premier services.  The Firm’s attorneys and professionals are uniquely educated and experienced, and possess HMT multi-modal transport certifications, to provide efficient,  high quality audits at a reasonable cost.  Our goal is to add significant value to our clients’ HMT programs.  These audits can be performed at a single facility, across multiple facilities, can review a corporate HMT program, review supplier practices, or can simply review the parcel post activity. 

We often can combine HMT audits into a fully integrated, comprehensive EHS/HMT compliance and management systems audit.  To maximize program effectiveness and reliability, we also recommend auditing the corrective action process and root cause identification (to prevent recurrent findings) and the self-assessment process (to ensure regulatory understanding and risk identification) to get the most from the audit process, and to ensure the most significant and efficient improvement process.

Our HMT audits focus primarily on the shipper’s responsibilities when shipping hazardous materials by highway, rail, air, and vessel.  We consider whether the facility operates a robust hazardous material identification process, properly and completes and certifies shipping papers, correctly marks and labels packages, placards vehicles when required, (or properly avoids these package and vehicle identifiers when necessary), operates an adequate emergency response program from 24-hour telephone numbers to emergency response procedures and materials, provides the required HMT training and maintains required training documentation, and operates a site security plan and program, if required.  While these are the primary focal areas, we also have audited rail and tank truck loading and unloading procedures, DOT-container specifications, material stowage, and highway and rail shipping requirements. 

We have audited hundreds of industrial facilities ranging from those in the automotive, chemical, pharmaceutical, utility, paper, waste recycling and disposal, foundries, electronics and printed circuit boards, and transportation industries to those in the food, beverage, research and development, and consumer products businesses.  Many of these audits have been within the United States and have included HMT audit scopes. 

Our HMT audit practice has also led the Firm to provide HMT regulatory counseling, training, and support, including placing employees on on-site Temporarily to improve HMT programs.