hmcrp web-only document 3: evaluation of small quantities...

Web-Only Document 3:

Evaluation of Small Quantities of Class 3 and Class 9 Hazardous Materials in Transportation

Hazardous Materials Cooperative Research Program

M. Sam Mannan Texas A&M University

College Station, TX

Contractor’s Final Report for HMCRP Project 18 Submitted August 2016

HMCRP

ACKNOWLEDGMENT

This work is sponsored by the Pipeline and Hazardous Materials Safety Administration (PHMSA). It was conducted through the Hazardous Materials Cooperative Research Program (HMCRP), which is administered by the Transportation Research Board (TRB) of the National Academies of Sciences, Engineering, and Medicine.

COPYRIGHT INFORMATION

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Cooperative Research Programs (CRP) grants permission to reproduce material in this publication for classroom and not-for-profit purposes. Permission is given with the understanding that none of the material will be used to imply TRB, AASHTO, FAA, FHWA, FMCSA, FRA, FTA, Office of the Assistant Secretary for Research and Technology, PHMSA, or TDC endorsement of a particular product, method, or practice. It is expected that those reproducing the material in this document for educational and not-for-profit uses will give appropriate acknowledgment of the source of any reprinted or reproduced material. For other uses of the material, request permission from CRP.

DISCLAIMER

The opinions and conclusions expressed or implied in this report are those of the researchers who performed the research. They are not necessarily those of the Transportation Research Board; the National Academies of Sciences, Engineering, and Medicine; or the program sponsors.

The information contained in this document was taken directly from the submission of the author(s). This material has not been edited by TRB.

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EXECUTIVE SUMMARY

In 2004, the Pipeline and Hazardous Materials Safety Administration (PHMSA) revised the incident reporting requirements by eliminating certain exceptions for small quantities of Class 3 hazardous material (HAZMAT). In the following years the number of incident reports filed for small quantities of Class 3 HAZMAT has increased substantially. On the other hand, a large number of products that are currently not regulated under the Hazardous Materials Regulations (HMR) will become a regulated Class 9 HAZMAT under the United Nations Globally Harmonized System (GHS) of Classification and Labeling of Chemicals criteria. Consequently, the number of reported incidents involving Class 9 HAZMAT in transportation is likely to increase significantly in the near future. Due to the changes in the regulations along with the GHS classification scheme adopted at the international level, there is an increasing interest among the various stakeholders in better understanding the safety and risks associated with various commodities comprising Class 3 (Packing Groups II and III) and Class 9 HAZMAT.

The objectives of the current research were set to identify the commodities comprising Class 3 (Packing Group (PG) II and III) and Class 9 liquid HAZMAT (UN 3082) and to determine the risks of transportation of the HAZMAT in commerce by motor carriers. All analyses performed were based on a maximum single package capacity of the hazardous materials of eight gallons.

Figure A: Research plan for evaluation of small quantities of Class 3 and Class 9 HAZMAT in transportation

Figure A presents the research plan of the current work. The first step of the research was to properly identify the hazardous materials commodities that belong to the Class 3 (PG II & II) and Class 9 (UN 3082) materials as defined by the project objective, and to build a database repository. The commodities of Class 3 (PG II and III) and Class 9 (UN 3082) liquid HAZMAT that are regulated under newly adopted United Nations Globally Harmonized System (GHS) of classification and labeling criteria were identified. 49 CFR 172.101 provided the definitions and classification for the hazardous materials (e.g., hazard class, UN identification) and the list of materials. For not otherwise specified (n.o.s.) categories, the CAMEO chemical database from Office of Response and Restoration, Ocean Service of National Oceanic and Atmospheric Administration was used. Incident data on transportation of small quantities (8 gallons) of Class 3 (PG II and III) and Class 9 (UN3082) HAZMAT were collected from the Pipeline and Hazardous Materials Safety Administration (PHMSA) incident database. Although data from Canadian and European databases were searched and reviewed, they were not considered due to lack of relevant data for the current research. The data was screened according to the Class, packing

Identify Hazardous Materials

Identify Incidents

Data Analysis

Risk Assessment

Conclusions and Recommendations

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3

Table A: Incident frequency by failure cause category and transportation phase of Class 3 materials Class 3 (PG II & III)

Failure cause category Transportation phases

Overall Percent In‐transit storage

Loading In‐

transit Unloading

Procedural deviations 105 699 1374 9003 11181 35.7% Human error 259 1896 1755 5112 9022 28.8% Forklift incident 206 1135 108 4017 5466 17.5% Instrument failure 64 421 554 1973 3012 9.6% Management failure 58 317 520 1199 2094 6.7% Mechanical failure 12 84 111 236 443 1.4% Traffic incidents 0 4 41 10 55 0.2% Others 1 3 11 19 34 0.1% Total 705 4559 4474 21569 31307 Percent 2.3% 14.6% 14.3% 68.9%

Incident categorization expressed two important findings as:

a) 69% of the total incidents occurred during the “Unloading” phase of transportation. b) Three most frequently cited failure causes are

i) procedural deviation, ii) human error, and iii) forklift incident.

It should be noted that, the presented data and associated analysis are not normalized since no suitable denominator data (e.g., miles traveled, total consumption) were available. Hence, incident trend analysis was not very conclusive.

Incident data also describes the consequence such as fatality/injury, financial damage, quantity released, evacuation, and environmental damage. However, since the number of evacuation and environmental damage were found to be insignificant, they were not considered in the risk analysis. Some salient features of the data analysis (total 32,455 incidents over 10 years) can be summarized as:

a) No incident resulted in fatality b) Only two incidents (out of 32,455 incidents) resulted in a major injury that required

hospitalization c) 99.9% incidents caused no injury at all d) 98.2% incidents resulted in financial damages of less than $1,000 e) 0.05% incidents caused financial damage costing more than $10,000

Incident pyramids were prepared for financial damage, injuries, and quantity released to determine the level of severity. Incident pyramids dictated the four levels of consequence and five levels of likelihood and some expert judgement was used to define the levels of likelihood. Risk matrices for financial damage (Figure C) and injury (Figure D) suggests that the risk of Class 3 (PG II & III) HAZMAT in transportation is a low consequence‐high frequency phenomenon.

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However, some prevention measures should be adopted to reduce the frequency of incidents. Root cause categorization and their incident frequency may provide some insight for identification of some key issues (e.g., how to reduce the procedural deviation, or how to ensure safe forklift operation).

Financial Damage($)

UNLIKELY; but occurs couple of times per 10 years

POSSIBLE; occurs

couple of times per

year

LIKELY; occurs

couple of times per month

FREQUENTLY; occurs couple of times per

day

ALMOST CERTAIN; occurs more

frequently per day

SEVERE DAMAGE (100,000‐)

3

MAJOR DAMAGE (10,000‐100,000)

12

MINOR DAMAGE (1,000‐10,000)

545

SLIGHT DAMAGE (0‐1,000)

31895

Figure C: Risk matrix based on financial damages

Injury/ Fatality

UNLIKELY; but occurs couple of

times per 10 years

POSSIBLE; occurs

couple of times per

year

LIKELY; occurs

couple of times per month

FREQUENTLY; occurs couple of times per

day

ALMOST CERTAIN;

occurs more frequently per day

Fatality

Major injury/injuries

2

Minor injury/injuries

18

No injury

32435

Figure D: Risk matrix based on injury/fatality

Such risk matrix can serve as guidelines on how to construct risk matrix and how to interpret one. Organizations should have their own risk matrices considering their overall risk acceptance/tolerance level. Matrices should be based on company policy, volume transported each year, material properties, resource availability, past incident data, and overall risk acceptability. Once the risk matrices are developed, each task can be ranked in terms of risk and possible control measures can be designed to reduce the level of risk ‐ consequence or frequency or both. However, risk tolerability (acceptable/ tolerable/ unacceptable area of risk) and decision criteria under different circumstances should be clearly defined.

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TABLEOFCONTENTS

EXECUTIVESUMMARY............................................................................................................1

LISTOFTABLES.........................................................................................................................7

LISTOFFIGURES.......................................................................................................................8

1.0 INTRODUCTION............................................................................................................9

1.1 Background ..................................................................................................... 9

1.2 Literature Review ............................................................................................ 9

1.3 Objectives ..................................................................................................... 10

2.0 METHODOLOGY.........................................................................................................11

2.1 Identification of HAZMAT .............................................................................. 11

2.2 Data Collection .............................................................................................. 11

2.3 Data Mining Tools ......................................................................................... 12

2.4 Incident Categorization ................................................................................. 13

2.5 Risk Assessment ............................................................................................ 13

2.6 Risk Reduction .............................................................................................. 13

3.0 RESULTS.......................................................................................................................14

3.1 Identification of Hazardous Materials ............................................................ 14

3.2 Data Collection .............................................................................................. 18

3.3 Data Mining and Analysis .............................................................................. 20

3.4 Incident Categorization ................................................................................. 27

3.5 Risk Assessment ............................................................................................ 38

3.6 Risk Reduction through Best Practices ........................................................... 43

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4.0 DISCUSSIONANDCONCLUSIONS..........................................................................47

5.0 REFERENCES...............................................................................................................49

APPENDIXA:LISTOFCLASS3(PGII&III)&CLASS9(UN3082)HAZMAT......50

APPENDIXB:DATABASEINFORMATIONSUMMARY.................................................51

APPENDIXC:SURVEYDOCUMENTS.................................................................................53

LISTOFCLASS3(PGII&III)&CLASS9(UN3082)HAZMAT.................................58

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LISTOFTABLES

Table 1: Definitions of HAZMAT, Class 3 and Class 9 HAZMAT in hazardous materials regulations of U.S.A., U.K., and Canada............................................................................................................ 14 Table 2: Frequency of incidents by identification number ........................................................... 24 Table 3: Incident frequency of different transportation phase for Class 3 (PG II & III) HAZMAT . 29 Table 4: Frequency of Class 3 HAZMAT incidents by failure cause ............................................... 29 Table 5: Frequency of Class 9 (UN3082) incidents by failure cause .............................................. 31 Table 6: Incident frequency of different transportation phase for UN 1263 ................................ 32 Table 7: Incident frequency of different transportation phase for other than UN 1263 .............. 32 Table 8: Frequency of UN1263 incidents by top failure cause ...................................................... 33 Table 9: Incident frequency of the HAZMAT other than UN1263 by top failure cause ................ 34 Table 10: Categorization of cause of incidents ............................................................................. 35 Table 11: Incident frequency by failure cause category and transportation phase of Class 3 HAZMAT ......................................................................................................................................... 37 Table 12: Incident frequency of Class 3 HAZMAT by financial damage ........................................ 38 Table 13: Incident frequency of Class 3 HAZMAT by quantity released ....................................... 39 Table 14: Incident frequency of Class 3 HAZMAT by injuries ........................................................ 40

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LISTOFFIGURES

Figure 1: Research plan for evaluation of small quantities of Class 3 and Class 9 HAZMAT in transportation ............................................................................................................................... 11 Figure 2: Flow chart presenting identification of Class 3 (PG II & III) and Class 9 (UN3082) hazardous materials ...................................................................................................................... 17 Figure 3: Process of data screening and mining for Class 3 and Class 9 HAZMAT ........................ 23 Figure 4: Trend of incidents involving Class 3 HAZMAT ................................................................ 26 Figure 5: Trend of incidents involving Class 9 HAZMAT ................................................................ 27 Figure 6: Incident data in different transportation phase of Class 3 (PG II & III) HAZMAT ........... 28 Figure 7: Incident data in different transportation phase of Class 9 (UN3082) HAZMAT ............. 28 Figure 8: Incident pyramid of Class 3 HAZMAT for financial damage ........................................... 39 Figure 9: Incident pyramid of Class 3 material for quantity released ........................................... 39 Figure 10: Incident pyramid of Class 3 HAZMAT of Injuries .......................................................... 40 Figure 11: Risk matrix based on financial damages....................................................................... 41 Figure 12: Risk matrix based on quantity released ....................................................................... 41 Figure 13: Risk matrix based on injury/fatality ............................................................................. 42 Figure 14: AHRA process and linkage to emergency management planning (www.publicsafety.gc.ca) .............................................................................................................. 43 Figure 15: Diverse risk event scenarios (www.publicsafety.gc.ca) ............................................... 44 Figure 16: Risk analysis elements used in UNECE ......................................................................... 45 Figure 17: Example of an F‐N graph for societal risk with possible areas for risk evaluation (UNECE, 2008) ............................................................................................................................... 46

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1.0 INTRODUCTION

1.1 BackgroundA hazardous material (HAZMAT) is defined as any substance or material in commerce that has the potential to harm people, property or environment. Hazardous materials classified as Class 3 (Packing Group (PG) II and III) present a very low flammability hazard (e.g., perfume, food flavorings, paint, adhesives, printing ink, cleaning supplies, and personal care products) and Class 9 materials that are liquid include many of the same types of products (e.g., perfumes and personal care products, food flavorings, paint, adhesives, printing ink, and cleaning supplies). Historically, incidents involving these materials with small packaging size were not required to be reported to the Pipeline and Hazardous Materials Safety Administration (PHMSA).

The primary objective of the Hazardous Materials Transportation Act (HMTA) is to ensure safety of life and property inherent in the transportation of hazardous materials in commerce. In 2004, PHMSA revised the incident reporting requirements by eliminating certain exceptions for small quantities of Class 3 materials. Consequently, the number of incident reports filed by industry for small quantities of Class 3 materials has increased substantially. On the other hand, a large number of products that are currently unregulated under the Hazardous Materials Regulations (HMR) will become a regulated Class 9 material under the United Nations Globally Harmonized System (GHS) of classification and labeling of chemicals criteria. Consequently, the number of reported incidents involving Class 9 materials in transportation is likely to increase significantly in the near future. Due to the changes in the regulations along with the classification scheme adopted at the international level, the industry has interest in better understanding the safety and risks associated with various commodities comprising Class 3 (PG II and III) and Class 9 hazardous materials. The term ‘industry’ in this report refers to the entities who are involved with shipping and transporting the hazardous materials.

1.2 LiteratureReviewRisk assessment for transportation of hazardous materials has been studied for decades, but the investigations specifically for transportation risk of Class 3 and Class 9 HAZMAT is uncommon.

A quantitative risk assessment was conducted to estimate the risk from transporting toxic inhalation hazards (TIH), liquefied petroleum gas, gasoline, and explosives (Hwang et al.). For TIH materials, both highway and rail transportation incidents were examined while for other toxic materials; only incidents in highway transportation were considered. Risk distributions and quantitative risk measures for additional materials were presented. This study demonstrates the capability to evaluate national risk of transporting certain hazardous materials. Risk distributions provide valuable information on probability of certain effects in a given time period, whereas risk measures provide a convenient way to compare relative risk for different commodities, transportation modes, and incident types.

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A methodology and a tool to integrate multiple data sources were proposed to analyze HAZMAT road incidents in Québec, Canada by Trépanier et al. (2009). The databases used in the study include: Dangerous Goods Incident Information System (DGAIS) from Transport Canada, Road Incident Database from the Société de l'assurance automobile du Québec (SAAQ), and Community Database on Work Incidents. DGAIS has information on spills, injuries, death counts, and other parameters related to HAZMAT, but the information reported is only for instances in which Canadian laws require it. Since not all of the databases collect the same data or even all the data that is needed to analyze incidents, the databases were integrated using the Transportation Object‐Oriented Modeling (TOOM) approach which allows analysis of data in relation to other transportation sources.

A decision support system was developed to identify risks associated with transportation of hazardous materials (Romano and Romano, 2009). The model integrates a database covering each mode of transportation in the study region with GIS capabilities to illustrate potential risks. Database includes transported materials, transportation length, release probabilities, and population density of surrounding areas. By inputting the data of material hazardous level and how close that material travels near populated area, this model calculates the risk and potential affected population.

1.3 ObjectivesThe general objective of the research was set to identify the commodities comprising Class 3 (PG II and III) and Class 9 liquid hazardous materials (UN 3082) and to determine the risks for transportation of the materials in commerce by motor carriers. Risk analysis performed in this project was based on a maximum single package capacity of the hazardous materials of eight gallons.

Based on the general objective six specific objectives were set: To identify Class 3 HAZMAT under packing group II and III and Class 9 HAZMAT with UN

3082 and to develop a database with all identified HAZMATs. To identify and collect incident data in which these HAZMAT have been involved. To analyze incident databases to discover patterns in the datasets and to extract

information from the dataset and transform it into an understandable structure. To categorize the failure causes of the incidents and to determine incident frequency of

incidents. This information is structured in the incident pyramid for injuries, financialdamage or quantity released.

To build risk matrices for fatalities, financial damages, and quantity released to establishprecursors that can give a clear view on where efforts can be placed for further riskreduction.

Best practices, standard operating procedures, and technological improvements thatcould reduce both likelihood and consequence of transportation incidents involvingClass 3 (PG II and III) and Class 9 HAZMAT will be identified.

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2.0 METHODOLOGY

The current research identifies the commodities comprising Class 3 (PG II and III) and Class 9 liquid hazardous materials under the GHS criteria and determines the risk for transportation by motor carriers for the Class 3 materials and risk for transportation in commerce for the Class 9 materials. The research plan is shown in Figure 1.

Figure 1: Research plan for evaluation of small quantities of Class 3 and Class 9 HAZMAT in transportation

2.1 IdentificationofHAZMATThe first step was to properly identify Class 3 materials under Packing Group II and III and Class 9 materials with UN 3082. The regulation 49 CFR 173.120 presented a description of the different classes of materials and the regulation 49 CFR 172.101 listed all materials along with their respective hazard class, UN identification, and information about the packaging, including the packing group. The hazardous material database for Class 3 materials (PG II and III) as provided by the 49 CFR 172.101 regulations listed either precise components like kerosene or methanol, or categorizes components like paints or perfumery products. Class 9 materials under the UN 3082 are only listed as “Environmentally hazardous substances, liquid, n.o.s. (not otherwise specified)”. Hence, chemical products databases were interrogated to properly identify the range of materials. Interactive Learning Paradigms, Incorporated (ILPI), a company based in New Jersey provided on their website a list of resources for Material Safety Data Sheets. The Environmental Health and Safety group of the Oklahoma State University also provided a list of databases of materials. From these databases, a systematic search by the UN identification allowed a better understanding of the different classes of products. From that search, a database of all identified Class 3 (PG II and III) and Class 9 materials (UN 3082) has been developed.

2.2 DataCollectionOnce the hazardous materials pertaining to this study were correctly identified, the second step was to identify the type of incidents in which these materials had been involved. Relevant information for the incidents that were collected and compiled, including: total number of

Identify Hazardous Materials•Builddatabase repository

Identify Incidents•Collectincident data

Data Analysis

Risk Assessment

Conclusions and

Recommendations

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incidents by chemical, volume released, cost of damage, type of package, size of containers, injuries, fatalities, evacuation area, and environmental and health impact. Additional information, such as how an incident was caused, was collected based on the availability of information. A database repository was developed.

Data from past incidents Incidents that involved Class 3 and Class 9 hazardous materials were studied back to the year 2000 to provide sufficient data for analysis. The first data source to be analyzed is the US states’ or federal agencies’ databases. The PHMSA provides online access to the incident reports database and gives a large number of fields describing the incident (175 entries per incident). Concerning European databases, the European Road Safety Observatory lists 10 European incident databases, and the best ones for this research project are CARE, ETAC, and RISER. The major Canadian database for transportation incidents is DGAIS provided by Transport Canada. The US databases are consulted primarily for Class 3 materials, and other countries’ databases are also considered after the most high profile chemicals from the US are identified. For the Class 9 materials, all databases are systematically consulted.

Data from shippers and carriers Shippers and carriers are in direct contact with these chemicals, and it was expected that they could provide the transportation record of hazardous materials (e.g., containers). However, it is possible that they have more specific information than what is reported to state or federal agencies from internal incident investigations. To gain additional incident information, interviews of shippers and carriers, as well as questionnaires and online surveys, were planned. For Class 3 materials, 10 shippers and 10 carriers were selected. These shippers and carriers were chosen based on different criteria such as the size of the company they work for (from local companies to the top 10 largest US companies and out to international groups), the incident frequency the companies experience, and the time when a typical incident occurred. Studies and recommendations about interviewing techniques (best practices for incident investigation published by OSHA, U.S. Department of Labor, Mine Safety and Health Administration) state that the data collected are less altered if the events discussed in the interview are recent.

2.3 DataMiningToolsSince the incident data collection results in a large incident database and a material database, proper analysis of this data is important. Therefore, data mining tools were used (Anand 2006, Mahdiyati 2011). These tools helped to discover patterns in large datasets, and to extract information from a data set and transform it into an understandable structure. Examples of the applicability of data mining include, but are not limited to: the chemical that reports the most incidents, the average size of spills, the type of container involved in the most incidents, the average cost per incident, and the average size of release. The data mining tools used on the database were cluster analysis, association rule and classification, and regression tree (Cerrito 2006, Giudici 2009). In general, data mining allowed detection of interesting patterns such as

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group data records (e.g., frequencies, higher or lower trends); unusual records, useful for anomaly detection and; dependencies among different factors. One example of data mining would be the identification of the top 20 hazardous materials with highest incident frequencies and largest container sizes and find their corresponding incident consequences.

2.4 IncidentCategorizationData mining tools helped establish frequency and consequence of different scenarios from the afore‐mentioned database. First, this information was structured in the incident pyramid format (Heinrich, 1931). The initial purpose of this pyramid was to show how unsafe acts can lead to minor injuries and, over time, to major injuries. This categorization, combined with frequencies and consequences obtained from the database and output of the data mining analysis, served as the basis to establish thresholds of a risk matrix.

2.5 RiskAssessmentRisk is defined as a function of the severity of an incident consequence and its expected frequency. According to the information from databases, in principle both frequency and consequence can be estimated. The period a database covers, is finite and there may be substances which are hazardous but so far have not been involved in an incident. The incident categorization further helps in identifying scenarios with high risk levels. The final evaluation of risk is determined by the overall likelihood and consequence of an incident. The factors to be considered for the impact of incident can most likely be: injuries or fatalities, asset damage or release.

2.6 RiskReductionBest practices, standard operating procedures, and technological improvements that could reduce both likelihood and consequence of transportation incidents involving Class 3 (PG II and III) and Class 9 HAZMAT were identified and cost‐effective engineering solutions to reduce ormitigate those risks are provided. To fulfill that task, literature and regulations were studied to determine current practices and requirements for transportation of HAZMAT. Finally, based on the risk assessment, the risk for transportation of commodities comprising Class 3 (PG II and III) and Class 9 liquid HAZMAT in commerce were estimated, also the risk reduction strategies are provided.

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3.0 Results

3.1 IdentificationofHazardousMaterialsTo better understand the properties of HAZMAT materials to be studied in this project, a comparison was first made among the definition of Class 3 and Class 9 HAZMAT were based on the regulations for transportation of hazardous materials or dangerous goods in three countries: U.S.A., U.K., and Canada. The detailed classifications as reported in the regulations are summarized in Table 1.

Table 1: Definitions of HAZMAT, Class 3 and Class 9 HAZMAT in hazardous materials regulations of U.S.A., U.K., and Canada

Country HAZMAT Class 3 Class 9 U. S. A. Any substance

which may pose an unreasonable risk to health and safety of operating or emergency personnel, the public, and/or the environment if not properly controlled during handling, storage, manufacture, processing, packaging, use, disposal, or transportation.

A flammable liquid (Class 3) means a liquid having a flash point of not more than 60.5°C (141°F), or any material in a liquid phase with a flash point at or above 37.8°C (100°F) that is intentionally heated and offered for transportation or transported at or above its flash point in a bulk packaging, with the following exceptions:

• Any liquid meeting one ofthe definitions specified in49CFR 173.115.

• Any mixture having one ormore components with aflash point of 60.5°C (141°F)or higher, that make up atleast 99 percent of the totalvolume of the mixture, if themixture is not offered fortransportation ortransported at or above itsflash point.

• Any liquid with a flash pointgreater than 35°C (95°F)which does not sustaincombustion according toASTM 4206 or the procedure

Miscellaneous hazardous material (Class 9) means a material which presents a hazard during transportation but which does not meet the definition of any other hazard class. This class includes:

• Any material which has ananesthetic, noxious orother similar propertywhich could cause extremeannoyance or discomfortto a flight crew member soas to prevent the correctperformance of assignedduties; or

• Any material that meetsthe definition in § 171.8 foran elevated temperaturematerial, a hazardoussubstance, a hazardouswaste, or a marinepollutant.

• Elevated temperaturematerial means a materialwhich when offered fortransportation ortransported in a bulk

15

in Appendix H of this part. • Any liquid with a flash point greater than 35°C (95°F) and with a fire point greater than 100°C (212°F) according to ISO 2592.

• Any liquid with a flash point greater than 35°C (95°F) which is in a water‐miscible solution with a water content of more than 90 percent by mass.

Class 3 Packing group II & III: Packing Groups I, II and III indicate the degree of danger presented by the material is great, medium or minor, respectively. Packing Group II: Flash point (closed‐cup) Initial boiling point 35 °C(95 °F). Packing Group III: Flash point (closed‐cup) Initial boiling point ≥23 °C, ≤60 °C(≥73 °F, ≤140 °F) >35 °C(95 °F).

packaging: (1) is in a liquid phase and

at a temperature at or above 100oC or 212oF;

(2) is in a liquid phase with a flash point at or above 38oC (100oF) that is intentionally heated and offered for transportation or transported at or above its flash point; or

(3) is in a solid phase and at a temperature at or above 240oC (464oF).

U. K. Flammable Liquids covers substances and articles, which:

• are liquids at 20°C and at a pressure of 101.3 kPa, with a melting point or initial melting point of 20°C or less at a pressure of 101.3 kPa

• at 50°C have a vapor pressure of not more than 300kPa

• have a flash point of not more than 60°C.

This group also contains:

These are substances and articles which during transport present a danger not covered by other classes.

Magnetic materials are classified in this category (magnetism may affect the navigation systems of airplanes). Polychlorinated biphenyls are placed in Class 9 because they may damage the environment. Dry ice (solid carbon dioxide) can evaporate producing

16

• liquid substances and molten solid substances with a flash point of more than 60°C that are carried or handed over for carriage while heated at temperatures equal to or higher than their flash point

• liquid desensitized explosives, which are explosive substances that are dissolved or suspended in water or other liquid substances to form a homogeneous liquid mixture to suppress their explosive properties.

asphyxiating fumes, and displace oxygen in the air in confined places such as cargo holds in ships and storage cellars. Asbestos can damage the lungs and the effect on health is not immediate, the damage appears after many years, therefore, asbestos is not placed in Class 6.1 but in Class 9.

Canada A substance is dangerous goods when:

• it is listed by name in Schedule 1 and is in any form, state or concentration that meets the criteria in this Part for inclusion in at least one of the 9 classes of dangerous goods; or

• it is not listed by name in Schedule 1 but meets the criteria in this Part for inclusion in at least one of the 9 classes of dangerous goods.

1) Substances that are liquids or liquids containing solids in solution or suspension are included in Class 3, Flammable Liquids, if they: a) have a flash point less than or equal to 60ºC using the closed‐cup test method ;

b) are intended or expected to be at a temperature that is greater than or equal to their flash point at any time while the substances are in transport.

2) Despite paragraph (1)(a), liquids that have a flash point greater than 35°C are not included in Class 3, Flammable Liquids, if they: a) do not sustain combustion, as determined in accordance with the sustained combustibility test ;

A substance is included in Class 9, Miscellaneous Products, Substances or Organisms, if it:

a) is included in Class 9 in column 3 of Schedule 1; or

b) is not included in Class 9 in column 3 of Schedule 1 and does not meet the criteria for inclusion in any of Classes 1 to 8 and i. contains a genetically

modified micro‐organism that would endanger public safety if incidentally released during transport,

ii. is listed in Appendix 1 (Marine Pollutants)

iii. except for asphalt or tar, is offered for transport or transported at a temperature greater

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18

packaging, including the packing group were recorded along with the chemicals. However, for each n.o.s. categories, no detailed chemicals were listed. For example, UN1986 is described as alcohols, flammable, toxic, n.o.s. chemicals belonging to that category can be alcohols, flammable, poisonous, n.o.s., cyclohexanol, denatured alcohol (Toxic), diisobutylcarbinol, 2‐ethyl hexanol, propargyl alcohol. To resolve this problem, the CAMEO chemicals database was also investigated. It is a public database owned by Office of Response and Restoration, Ocean Service of National Oceanic and Atmospheric Administration. With the help of this database, 325 specific chemicals in these 41 n.o.s. categories were also identified. Similar methodology was applied for Class 9 chemicals with UN 3082. 103 chemicals were identified from CAMEO chemicals besides the general information listed as “Environmentally hazardous substances, liquid, n.o.s. (not otherwise specified)” in 49 CFR 172.101. The list of materials along with their respective hazard class, UN identification, and information about the packaging has been included in Appendix A. There are four tabs or sections in Appendix A. The first section contains the list of 406 chemicals found in 49 CFR 172.101. The second and third sections list 41 n.o.s. categories found in 49 CFR 172.101 and 325 chemicals under these categories identified from CAMEO database, respectively. The fourth section has the list of 103 chemicals identified from CAMEO database.

It should be noted that a database titled “FACTUAL” (https://www.factual.com/products/cpg) was found that can identify common consumer products. The database includes over 600,000 consumer packaged goods, including categories such as “beauty & skincare”, “food & beverage”, “pet products”, “baby products”, “healthcare products” and “household supplies”. This database has some usability to find the common consumer goods containing Class 3 (PG II and III) and Class 9 (UN 3082) materials.

3.2 DataCollectionIn order to select the appropriate incident database, databases in U.S., Canada, and Europe were studied.

Canadian database Incident data is available for HAZMAT shipped by motor carriers from the Dangerous Goods Incident Information System (DGAIS), Transport Canada Statistics. Incident database DGAIS was searched for non‐bulk quantities. Incident data collection and analysis were based on small quantities, ones with capacity lower than 30.3 liters (basis: 1 US gallon = 3.7854 liter), for both Class 3 (Packing Group II & III) and Class 9 (UN3082). The incident data was screened based on death count, major injury, moderate injury, minor injury, evacuation area, evacuation number, and damage (damage to property, damage to equipment, damage to cleanup and other). It was observed that no incident record was found in the final list for Class 9 and Class 3 Packing Groups II & III.

European database Several European databases were consulted for transportation incidents involving HAZMAT and the results can be summarized as follows:

19

• Analysis, Research and Information on Incidents (ARIA), France: It is not comprehensive, and only selected incidents are included. The purpose of the database is to enhance learning from incidents. This database was found not very useful for this research.

• CCPS Process Safety Incident Database (PSID): It is not available for public access. Access was denied by the person in charge due to confidentiality issues.

• Central Reporting and Evaluation Office for Hazardous Incidents (ZEMA) database, Germany: The focus is on manufacturing‐related incidents; only 2% data are related to transportation. It was available for public access, but web address for accessing data does not exist anymore.

• European Process Safety Center: Statistics on process safety was not found. • United Kingdom Petroleum Industry Association (UKPIA), U.K.: It is used for internal

review/trend analysis as appropriate. Authority did not share incident database due to sensitivity of information regarding member companies.

• The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR): Information on the United Nations Economic Commission for Europe (UNECE) website was checked and no incident database was found.

U. S. database The first database studied was the Pipeline and Hazardous Materials Safety Administration (PHMSA) from the U. S. Department of Transportation. PHMSA provides online access to the incident reports database. Raw incident data was searched by setting searching criteria, such as date of incident, mode of transportation, packaging type, incident cause, incident consequence, and so on. PHMSA incident report database provides a large number of fields describing the incident, including but not limited to mode of transportation, transportation phase, carrier and shipper information, Identification number of materials, hazard class code, quantity released, packaging type, package capacity, failure cause and consequence factors such as financial damage, fatality, injury, and evacuation. Given the large number of the fields, researchers can easily screen the database to fit their scope of the study. In the study, raw database could be obtained by searching for non‐bulk shipments via highway mode of transportation from 2005 to 2014.

Incidents were searched for non‐bulk shipments via highway mode of transportation. The incidents were further screened based on the individual package capacity of the shipment. Maximum allowable package capacity was set to be eight gallons for Class 3 (PG II and III) and Class 9 (UN 3082) HAZMAT. Compiled data were then sorted based on several consequence criteria, e.g., fatality, injury, evacuation and damage amount. These lists were prepared to select shipper and carrier for further investigation.

Since only after 2004, incidents involved with small quantity of Class 3 packing group II and III and Class 9 with UN 3082 were reported, 10 year incidents from PHMSA were selected for analysis. Incident database of transporting non‐bulk hazardous materials on highway from January 01, 2005 to December 31, 2014 was downloaded from PHMSA public database. There are three columns in the database describing failures: how fails, what fails, and failure cause.

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Failure cause is further categorized as procedural deviations, human error, mechanical failure, instrument failure, management failure, traffic incidents, forklift incident, and others based on knowledge. No fatalities have been reported with small quantities of Class 3 and Class 9 hazardous materials. Some of the serious events include injury of 11 personnel involving toluene, injury of four personnel, and evacuation of 165 employees involving pyridine and injury of two and evacuation of 155 personnel with approximately $1.5 million property damage due to the incident involving methyl alcohol, hexane isopropanol, orig. klearkote 5185, methanol absolute, #12 deglazer, ethanol isopropanol, chrome sludge, terchloroethylene, and metal hydroxide. 10‐15 incidents were selected from PHMSA database based on the severity and type of incidents and from the incidents potential shippers and carriers were identified for survey purpose.

By comparing different incident databases, PHMSA database seems to be the most comprehensive database and fits the interest of the study. Thus the study was continued with only PHMSA incident database. Information of the database is summarized in Appendix B.

Data from survey All human subject research conducted by Texas A&M employees or students is submitted to the Institutional Review Board (IRB) for review. A pre‐application consultation with the IRB about this specific study was made. Principal investigator and researchers completed several comprehensive training on survey ethics, data privacy and protection. Finally, an application for survey, consent form, recruitment letter, list of participants of the survey (name and address of shipper and carrier companies), and questionnaires for shippers and carriers were submitted. After the review process all documents were approved and stamped. All approved and stamped documents have been attached in Appendix C.

Questionnaire for shippers consists of nine parts seeking some general information on company policies and incident experiences; health, safety and environment standards and practices; carrier selection process; hazard identification & risk assessment methodology; safety and risk communication; human factors (i.e., driver/loader competency development or monitoring procedure); emergency response procedures; best practices and record‐keeping methodologies. Questionnaire for carriers consists of four parts: general information on HAZMAT transportation practices and experiences; human error consideration and competency development; quality control and inspection; documentation and learning from past incidents.

However, due to the lack of responses from the shippers and carriers, survey could not be completed. Survey request and consent form were sent to the enlisted and approved shippers and carriers multiple times. Both shippers and carriers were attempted to contact over phone, but without success.

3.3 DataMiningandAnalysisMS SQL (Server Query Language) Management Studio was used as a database engine, and SQL was used for query to screen and organize data. The data mining software provided a strong

21

technical support to reveal patterns of transportation incident, identify trends, and categorize the failure causes. Data mining results were further used to develop a transportation risk matrix. Figure 3 shows the methodology of data mining implemented in the study. First, raw data of the incidents was collected from PHMSA by searching for non‐bulk shipments via highway mode of transportation. The collected data included 126,178 observations and the incidents were occurred from January 1, 2005 to December 4, 1995. In the database, an incident involving single materials was recorded as a single observation. For the incidents involving multiple materials, they were recorded as multiple observations since each involved material was recorded as one observation. After obtaining the raw database, data mining were preceded by two phases. Phase I was data screening, and Phase II was data analysis using the screened data.

Phase I: Data Screening Both Class 3 and Class 9 materials are involved in the study, thus raw data was divided into two parts to obtain database for each class. In order to evaluate frequency and consequence of Class 3 incidents, Class 3 Data‐1 was obtained by querying those incidents, satisfying the following conditions:

Incident involved only Class 3 materials with packing group II or III, and with 8‐gallon maximum package capacity.

Incidents involved single material.

Incidents involving multiple UN number were not considered in this study primarily because of two reasons. First, total incident number of Class 3 materials with packing group II or III and with 8‐gallon maximum package capacity is 32,634. Only 0.55% of the incidents (179) were reported as incidents involving multiple UN numbers. Second, for the incidents involving multiple UN number, consequences of the incidents were accumulated by the multiple UN number. Consequence of releasing a single Class 3 material could not be reflected from those incidents. Thus, the incidents involving multiple materials were not considered, and the Class 3 Data‐1 were screened by searching for those incidents involving single material. Finally, there are 32,455 incidents were screened in Class 3 Data‐1. Root causes of incidents are important to be studied for preventing or reducing reoccurrences of similar incidents. There is considerable doubt about the consistency and validity of the definition used to classify root causes in the incident reports. In this report, we have used the failure cause categories (knowing that on a consistent basis not all the failure causes represent real root causes) reported in the incident database to conduct our data analysis and derive the conclusions. In order to implement the analysis, Class 3 Data‐2 was generated. Besides the criteria to generate Class 3 Data‐1, one more criterion to obtain Class 3 Data‐2 was extracting the incidents causing by single failure cause. Only around 5% incidents of the 32,455 incidents were caused by multiple failure cause. Finally, 31,307 incidents were covered in Class 3 Data‐2.

Class 9 UN3082 data was obtained by querying the incidents satisfying the following conditions: Incidents involving only Class 9 material, specifically UN3082.

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Incidents involving the materials with maximum package capacity which was eight gallons.

Incidents involving single material.

By using first two conditions to query, 30 incidents involving the Class 9 UN3082 were identified. Among these incidents, only one incident was involved multiple materials and all incidents were caused by single failure cause. The incident involving multiple materials was removed and final dataset used for the analysis related to Class 9 UN3082 covers 29 incidents.

Phase II: Data Analysis Data analyses were implemented in three parts: analysis based on incident frequency, consequence, and failure cause. These data analysis were implemented separately for Class 3 and Class 9 materials.

Class 3 Data‐1 was used to evaluate frequency and consequence of incidents. First, in order to study the trend of the hazard materials which were most frequently involved in incidents, top 23 materials with the highest incident frequencies were listed. Trends during the 10 years for the 23 materials were analyzed separately. In the database, there are four transportation phases including in‐transit storage, in transit, unloading and loading. In order to understand which transportation phase was most likely to cause the incident, the incident frequency distribution for the 23 materials were studied. According to the frequencies of incidents involving the top 23 materials, incidents of the material UN1263 accounting for 60% of the Class 3 incidents, thus further analysis of incident frequency and consequence regarding Class 3 incidents was implemented separately for the incidents involving UN1263 and for the incidents involving the Class 3 materials other than UN1263.

Incident consequences were analyzed to categorize incidents, which would be further used to construct a transportation risk matrix. Consequence could be evaluated based on four factors‐ number of fatalities/injuries, amount of financial damage, quantity of a material released, and whether there was an evacuation ordered. Amount of financial damage and quantity of a material categorized to four levels based on corresponding frequencies. Incident pyramids were constructed to present incident categorizations based on number of fatalities/injuries, amount of financial damage, quantity of a material released. As for evacuation ordered, only few incidents resulted in evacuation, thus incidents were simply categorized to the incidents resulting in evacuation and those not resulting in evacuation.

Additionally, Class 3 Data‐2 was used to categorize failure causes of incidents. Via SQL management system, it was found that 31,307 incidents were caused by 45 failure causes. These failure causes were categorized into eight groups based on expert opinion. In order to get a deeper understanding top failure causes under each cause category were listed separately with corresponding frequencies. On the other hand, top failure causes associated with transportation phases were listed with corresponding frequencies, along with frequency of failure cause categories associated with transportation phases.

Figure 3: Process of data screenin

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g and mining for Class 3 and Classs 9 HAZMAT

24

Similar to the analysis of incidents involving Class 3 materials, Class 9 UN3082 data were analyzed based on incident frequency first. Trend of incidents involving class 9 UN3082 during the 10 years was analyzed. And the frequency distributions of incidents in different transportation phases were presented.

However, since Class 9 UN3082 data only has 29 incidents, incident pyramids could not be developed. As for the analysis of failure causes, considering the small size of the data, causes were not categorized to the 10 categories, but failure causes associated with different transportation phases were listed with corresponding frequencies.

Trend analysis First, top Class 3 materials which have most incidents are ranked. There are 126 materials in total involved in the incidents during the 10 years, 23 out of them have more than 100 incidents in 10 years. The top 23 materials and the number of the incidents they were involved are listed as Table 2.

Table 2: Frequency of incidents by identification number Identification

Number Number of incidents happened in 10 years

UN1263 19358 UN1219 2323 UN1993 1688 UN1133 1217 UN1170 851 UN1090 794 UN1230 786 UN1210 781 UN1866 623 UN1987 620 UN1268 289 UN1294 262 UN1197 254 UN2924 253 UN1648 249 UN1193 212 UN1307 185 NA1993 184 UN1139 180 UN2056 175 UN1173 166 UN1208 116 UN1247 102

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The trends of incidents for each material are shown in Figure 4. 60% of the total incidents of Class 3 materials over the 10 years are UN1263‐related, and number of incidents in each year is decreasing as time goes by. Based on the following charts, incidents involving UN1993, UN1866, and NA1993 per year are obviously decreasing. On the other hand, incidents involving UN1090 and UN1208 are increasing during the last 10 years, which warns people to take actions and reduce these incidents when transporting. The trends of other materials are relatively flat, but numbers of incidents involving UN1170, UN1133, UN1139 and UN1268 tend to increase in the past several years, which also warn people to improve the transportation safety of these materials. It should be noted that the data used to present the trend analysis are not normalized. We did not find appropriate or suitable data (e.g. the total amount/volume of material of each UN number transported in that period) to normalize the dataset presented here. As a result, the trends become inconclusive. For example, UN 1090 has an increasing trend over last 10 year. But we cannot definitely say that the frequency of incident of the material is increasing since the transport of UN 1090 might have increased as well in that period of time.

0

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Figure 4: Trend of incidents involving Class 3 HAZMAT

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Similarly, the trend of incidents for Class 9 UN 3082 is shown in Figure 5. In general, the trend of UN 3082 incidents is increasing as time goes by.

Figure 5: Trend of incidents involving Class 9 HAZMAT

3.4 IncidentCategorizationTransportation phases Data exploration has been done via SQL management studio and results are shown in this section. Incidents that happened in different transportation phases were studied and results for both Class 3 and Class 9 (UN3082) are shown in Figure 6 and Figure 7, respectively.

“Unloading” is the transportation phase which tends to have most incidents. The number of incidents that happened during “loading” and “in transit” is relatively similar. As per the “in transit storage” category the transportation phase which is least likely to involve incidents. Even though there are only 29 records of UN3082 available to study, the results related to UN3082 shows same pattern.

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2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

Num

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FFigure 6: Incid

Figure 7: Inci

dent data in d

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28

sportation ph

nsportation p

hase of Class

phase of Class

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s 9 (UN3082)

HAZMAT

HAZMAT

29

Further, top failure causes corresponding to incidents that happened in each transportation phase are studied. For Class 3 materials, incidents are caused by single failure cause and multiple failure causes, and some failure causes for incidents are unknown. As Table 3 shows, more than 94% of incidents are caused by single failure causes. Referring to both Figure 3 and Table 3, the number of incidents for Class 3 commodities with single component and single failure cause was 31,307, and approximately 69% of these incidents (21566) occurred during the unloading phase of transportation.

Table 3: Incident frequency of different transportation phase for Class 3 (PG II & III) HAZMAT Class 3

Transportation Phase

Number of incidents

Unknown failure cause

Multi failure cause

Single failure cause

Loading 4813 191 61 4561 In Transit 4691 136 113 4442

In Transit Storage 729 17 11 701 Unloading 22222 361 295 21566

Among these single‐failure‐cause incidents, top failure causes in each transportation phase are listed as Table 4.

Table 4: Frequency of Class 3 HAZMAT incidents by failure cause Failure cause Incident number Class 3 Loading Forklift Incident 1135 Human Error 850 Dropped 838 Defective Component or Device 321 Inadequate Preparation for Transportation 285 Improper Preparation for Transportation 274 Too Much Weight on Package 213 Impact with Sharp or Protruding Object (e.g. nails) 208 Inadequate Blocking and Bracing 184 Valve Open 58 Class 3 In Transit Dropped 891 Human Error 690 Improper Preparation for Transportation 548 Inadequate Preparation for Transportation 475 Inadequate Blocking and Bracing 426 Defective Component or Device 386 Too Much Weight on Package 373 Impact with Sharp or Protruding Object (e.g. nails) 174 Valve Open 125

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Forklift Incident 108 Class 3 In Transit Storage Forklift Incident 206 Human Error 130 Dropped 69 Impact with Sharp or Protruding Object (e.g. nails) 59 Defective Component or Device 51 Inadequate Preparation for Transportation 48 Improper Preparation for Transportation 44 Too Much Weight on Package 32 Inadequate Blocking and Bracing 22 Inadequate Procedures 10 Class 3 Unloading Inadequate Blocking and Bracing 5324 Forklift Incident 4017 Human Error 2631 Improper Preparation for Transportation 1878 Too Much Weight on Package 1708 Dropped 1463 Defective Component or Device 1112 Inadequate Preparation for Transportation 1060 Impact with Sharp or Protruding Object (e.g., nails) 1018 Loose Closure Component or Device 718

Class 9 (UN3082) Similar study was done for Class 9 UN 3082. There are only 29 incidents involving UN3082 materials. And eight of them occurred during “in transit”, eight of them happened during “loading”, and 13 happened during “unloading”. Because of the small database for UN 3082, incident numbers regarding to each failure cause in each transportation phase are listed in Table 5. Even though, the database is too small to provide enough evidence to make a conclusion, it is possible to find that forklift incidents are the top failure cause to lead incidents during “loading” and “unloading” phase.

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Table 5: Frequency of Class 9 (UN3082) incidents by failure cause Failure Cause Incident Number UN3082 Loading Forklift Incident 3 Human Error 1 Impact with Sharp or Protruding Object (e.g. nails) 1 Improper Preparation for Transportation 1 Inadequate Preparation for Transportation 1 Unknown 1 UN3082 In Transit Deterioration or Aging 1 Dropped 1 Forklift Incident 1 Human Error 1 Impact with Sharp or Protruding Object (e.g. nails) 1 Inadequate Preparation for Transportation 1 Too Much Weight on Package 1 Vehicular Crash or Incident Damage 1 UN 3082 In Transit Storage UN 3082 Unloading Forklift Incident 4 Inadequate Blocking and Bracing 2 Unknown 1 Too Much Weight on Package 1 Inadequate Preparation for Transportation 1 Improper Preparation for Transportation 1 Human Error 1 Deterioration or Aging 1 Abrasion 1

Class 3 materials: “UN1263” and “Other than UN1263” Incident frequency of UN1263 is 19,358 out of 32,455 incidents related to Class 3 materials. Thus, incidents of transporting Class 3 materials are divided into two groups: incidents of transporting UN1263 and incidents of transporting “Other than UN1263”. In this way, the high weight of UN1263 incidents can be avoided when analyzing top failure causes. For both groups of Class 3 materials, incidents are based on single failure cause and multiple failure causes. Some failure causes for incidents are unknown. As Table 6 and Table 7 shows, for both groups, frequencies of incidents with unknown cause and multiple causes are no more than 5%, so that these causes can be ignored and only incidents caused by single failure cause will be used for further analysis.

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Table 6: Incident frequency of different transportation phase for UN 1263 Class 3 UN 1263

Transportation Phase

Incident frequency

Unknown cause

Multiple cause

Single cause % for unknown and multiple causes

Loading 2060 51 37 1972 4.27% In Transit 1828 59 48 1721 5.85% In Transit Storage

425 8 5 412 3.06%

Unloading 15045 180 189 14676 2.45% overall % of unknown and multiple causes 2.98%

Table 7: Incident frequency of different transportation phase for other than UN 1263

Class 3 other than UN1263 Transportation

Phase Incident frequency

Unknown cause

Multiple cause

Single cause

% of unknown and multiple causes

Loading 2753 140 26 2587 6.03% In Transit 2863 77 33 2753 3.84% In Transit Storage

304 9 2 293 3.62%

Unloading 7177 181 103 6893 3.96% overall % of unknown and multiple causes 4.36%

Top failure causes for both groups regarding to transportation phases are shown in Table 8 and Table 9.

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Table 8: Frequency of UN1263 incidents by top failure cause Failure cause Frequency Class 3 UN1263 Loading Forklift Incident 742 Human Error 304 Dropped 191 Too Much Weight on Package 135 Inadequate Blocking and Bracing 126 Impact with Sharp or Protruding Object (e.g. nails) 123 Improper Preparation for Transportation 114 In Transit Improper Preparation for Transportation 308 Inadequate Blocking and Bracing 281 Human Error 214 Too Much Weight on Package 214 Inadequate Preparation for Transportation 169 Dropped 158 In Transit Storage Forklift Incident 148 Human Error 69 Unloading Forklift Incident 2918 Human Error 1758 Improper Preparation for Transportation 1288 Too Much Weight on Package 1186

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Table 9: Incident frequency of the HAZMAT other than UN1263 by top failure cause Failure Cause Frequency Class 3 Other than UN1263 Loading Dropped 647 Human Error 546 Forklift Incident 393 Defective Component or Device 268 Inadequate Preparation for Transportation 191 Improper Preparation for Transportation 160 In Transit Dropped 733 Human Error 476 Inadequate Preparation for Transportation 306 Defective Component or Device 299 Improper Preparation for Transportation 240 Too Much Weight on Package 159 Inadequate Blocking and Bracing 145 Valve Open 111 In Transit Storage Human Error 61 Forklift Incident 58 Defective Component or Device 37 Dropped 34 Inadequate Preparation for Transportation 29 Impact with Sharp or Protruding Object (e.g., nails) 24 Improper Preparation for Transportation 19 Unloading Inadequate Blocking and Bracing 1129 Forklift Incident 1099 Human Error 873 Dropped 687 Improper Preparation for Transportation 590 Too Much Weight on Package 522 Inadequate Preparation for Transportation 457 Defective Component or Device 447 Impact with Sharp or Protruding Object (e.g. nails) 443 Loose Closure Component or Device 360

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Failure causes were categorized in order to get a better understanding of the failure causes and their frequencies. There are three columns in the database describing failures: how failed, what failed and failure cause. They were categorized into eight groups as shown in Table 10.

Table 10: Categorization of cause of incidents Procedural deviations Mechanical failure Commodity Polymerization Abrasion Commodity Self‐Ignition Corrosion – Exterior Fire Temperature or heat Conveyer or Material Handling Equipment MishapIncompatible Product Corrosion – Interior Inadequate Maintenance Deterioration or Aging Improper Preparation for Transportation Punctured Inadequate Blocking and Bracing Structural Inadequate Accident Damage Protection Threaded Connection Overfilled Threads Worn or Cross Threaded Over‐pressurized In

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