FOX Corporation requires the implementation of specific steps, as specified in this Procedure, when its personnel ship hazardous materials (HazMat).
1.0 SCOPE
This procedure applies to all FOX Corporation (FOX) activities where hazardous materials are shipped.
The procedure prescribes the minimum requirements for the shipping and handling of hazardous materials in the course of your work. The Department of Transportation (DOT) in Title 49 of the Code of Federal Regulations (CFR) provides instructions for all modes of transportation. In addition, the International Civil Aviation Organization (ICAO) and the International Air Transport Association (IATA) impose more stringent requirements for air transportation by providing technical instructions. This procedure is designed to provide a framework for compliance with the requirements of the DOT and IATA regulations for shipping hazardous materials/dangerous goods by land or air.
Employees are required to have documented training prior to performing activities that involve the shipment of hazardous materials/dangerous goods on behalf of FOX Corporation. This policy does not apply to your personal belonging.
1.1 Failure to comply
The shipment of hazardous materials is a serious matter that requires Fox’s compliance with regulatory requirements. Failure to comply with federal and international transportation regulations when shipping hazardous materials can result in civil penalties and fines ranging from $500 to $32,500 per day per violation. For more serious offenses resulting in injury, death or destruction of property, fines and penalties can be up to $175,000 per incident.
Guidelines within the transportation regulations indicate increasing baseline penalties based on the following circumstances:
- Not declaring a Lithium Battery: $40,000 (Air), $20,000 (Ground)
- Offering untested Lithium batteries: $30,000 (Air), $15,000 (Ground)
- Offering batteries that are NOT protected against short circuit: $15,000
- Failure to apply the correct label: $7,000
- Offering a packaging that is damaged or not suitable: $7,500
In addition to civil penalties per occurrence, criminal penalties include the fines listed above plus up to 10 years in prison.
2.0 DEFINITIONS
Authorized – Fox employee or representative who has successfully completed HazMat training (i.e., Small Battery Training, etc.) and is knowledgeable and qualified to perform activities that involve the shipment of hazardous materials/dangerous goods.
Batteries – Two or more cells which are electrically connected together and fitted with devices necessary for use (case, terminals, protective devices, etc.). Examples include batteries for cameras, laptops, radios, mobile phones and 9v batteries.
Carrier – A person engaged in the transportation of passengers or property by land, water or air either as a common, contract, private carrier or civil aircraft.
Cell – A single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across two terminals. Examples include AA, AAA, D, C, CR123 and button cells. Button cells installed in equipment are not subject to the regulations.
Dangerous Goods (IATA) – Articles of substances which are capable of posing a risk to health, safety, property or the environment and which are shown in the list of dangerous goods in the Dangerous Goods Regulations (DGR) and/or IATA regulations or which are classified according to the DGR and/or IATA regulations. Dangerous goods are generally synonymous with hazardous materials.
Equipment – Equipment means the device or apparatus for which the lithium cells or batteries will provide electrical power for its operation. Examples include a radio with its battery, a camera with its battery or a laptop with its battery.
Hazardous Materials (US DOT) – A substance or material which has been determined by the US Secretary of Transportation to be capable of posing an unreasonable risk to health, safety and property when transported in commerce, and includes hazardous substances, hazardous wastes, marine pollutants and elevated temperature materials. Hazardous materials at Fox include, but are not limited to, compressed gas cylinders, alcohol for cleaning, paints, adhesives, camera batteries, UPS, drones, etc.
3.0 RESPONSIBILITIES
In addition to required Environmental, Health and Safety (EHS) Program responsibilities discussed in EHS001, EHS Policy, the responsibilities described below are necessary to ensure the effectiveness of the procedure.
3.1 Department Heads
Department Heads will ensure that supervisors of personnel shipping and/or handling hazardous materials are trained in this Procedure.
3.2 Employees & Contractors
All FOX employees and contractors/vendors working on behalf of Fox:
- Will not handle, receive or ship hazardous materials or dangerous goods without having appropriate and documented training as specified in this procedure.
- Will receive approval prior to shipping hazardous materials.
- Immediately notify their EHS representative of concerns or questions about dangerous goods to be shipped and/or received. EHS Representative Names and Contact information are provided in Section 6.
3.3 Environmental, Health & Safety Department
The EHS Department will:
- Develop appropriate procedures for shipping and handling of hazardous materials.
- Provide technical assistance in the shipping of hazardous materials as requested by Department Heads.
- Provide professional recommendation of services and facilitate the training of personnel authorized to ship hazardous materials.
- Perform a periodic review of this Procedure (at least annually) to ensure that all requirements are current and meet regulatory requirements.
4.0 PROCEDURE
4.1 Authorization and Shipping
Specific packaging and shipping instructions apply to all hazardous materials shipments. These instructions vary by chemical/product and are different for passenger aircraft and cargo aircraft. For hazardous materials to be shipped, Fox must follow all applicable regulations (e.g., DOT, IATA, etc.), the carrier’s instructions, and the guidelines for naming, packaging, labeling, marking, and quantity restrictions.
Only trained and qualified personnel are authorized to ship hazardous materials (e.g., paint, batteries, etc.).
Authorized personnel will:
- Notify their designated EHS Representative within 3 days of the upcoming shipment if guidance is needed.
- Follow all DOT/IATA regulations and specific carrier instructions.
- Follow all procedures in the “Battery Shipping Manual” provided in Attachment A when shipping batteries of any kind.
4.2 Training
Employees involved in shipping hazardous materials/dangerous goods (e.g., packaging, preparing paperwork, loading, unloading, and transporting hazardous materials) are required to have documented training prior to shipping activities.
4.2.1 Training Types
Training requirements are based on the type of materials shipped (e.g., compressed gases, batteries, laptops, etc.) and employee responsibility. Training curriculum will include general awareness/familiarization, function-specific, safety, security awareness and modal-specific.
Required training will be facilitated by the EHS Department. Initial training must be completed within 90 days of employment or job function. Employees must complete recurrent training every three years and any time DOT/IATA issues any new or revised rule applicable to the duties of a particular employee.
4.2.2 Documentation
Documentation of training will be maintained by the EHS Department. Documentation must include the following:
- Course outline
- Sign-up/log-in sheet with:
- Employee name
- Most recent training completion date
- Description, copy or the location of the training materials
- Name and address of the person providing training
- Proof of testing
- Certificate of completion from the training provider
5.0 REFERENCES
- EHS 001, EHS Policy
- 49 CFR 171-181, HM 181 with amendments
- DOT Emergency Response Guidebook (ERG2008)
- International Air Transport Association (IATA), Dangerous Goods Regulations
- International Civil Aviation Organization (ICAO), Technical Instructions for the Safe Transport of Dangerous Goods by Air, Document 9284-AN/905as amended
- US Department of Transportation (DOT), Pipeline and Hazardous Materials Safety Administration
6.0 EHS Contacts
|
Employee Hotline (866) 369-2225 |
||||
| FOX Safety | All Locations | o: (310) 369-2671 | f: (310) 369-9091 | fngsafety@fox.com |
| Ron Partilla | Fox Sports
Fox Sports 1 |
o: (310) 369-3046 | c: (843) 822-9600 | ron.partilla@fox.com |
| Dolores Salman | Fox Cable
Fox Broadcasting National Geographic Partners |
o: (310) 369-4077 | c: (949) 296-5235 | dolores.salman@fox.com |
| Chad Ross | FS Florida/Sun Sports
FS MidWest FS South FS Southwest YES Network |
o: (310) 369-8332 | c: (859) 512-7774 | chad.ross@fox.com |
| Brett Hodgson | FS Arizona
FS North/Wisconsin FS Ohio FS West/Prime Ticket FS San Diego FS Detroit Big Ten Network |
o: (310) 369-8331 | c: (616) 446-6910 | brett.hodgson@fox.com |
7.0 ATTACHMENTS
B: Airline Passenger Pack Safe Chart
C: Airline Passengers and Batteries
D: Airline Hazardous Materials Guide
E: UPS Guide for Shipping Hazardous Materials
F: UPS Battery Shipping Requirements