employees and customers, lawsuits, enormous fines, and
damage to facilities—are far worse.
Here’s a look at the extent of this troubling situation, the
reasons behind it, and what can be done about it.
WAIT— THAT’S HAZARDOUS?
A surprising number of consumer products are regulated as
hazardous materials. Some, like household cleaners and solvents, are fairly obvious, says Keith Anderson, senior director of regulatory compliance for Inmar, a third-party logistics company. But the average person may not think of
items like health and beauty care products, aerosols, and
batteries as hazardous, he says.
Most consumer electronics, including televisions, cameras, mobile handsets, computer monitors, and printers,
contain materials that could be considered hazardous, says
King. “Televisions, for example, are built with electronic circuit boards, glass, and color cathode ray tubes (CRTs),
which often contain hazardous materials such as lead and
mercury, as well as lesser-known toxins like cadmium,
chromium, antimony, beryllium, and brominated flame
retardants,” he explains.
Sometimes only parts of consumer goods are subject to
regulation, says Robert Jaffin, who teaches an online course
in hazmat reverse logistics for the American Public
University. Seemingly innocuous components like the toner
in printer cartridges or the ink in dry-erase markers
become a health and regulatory risk when a commercial
entity accepts them as returned goods, he says.
Some items that were not subject to regulation when pur-
chased by the consumer may be hazardous when they are
returned, notes Jack Currie, administrator of the Council
on Safe Transportation of Hazardous Articles (COSTHA)
and president of the regulatory compliance firm Currie
Associates. Examples include construction, camping, and
lawn and garden equipment powered by gasoline, kerosene,
or propane. If these machines have been used, then there
will be fuel, oil, and—most dangerous of all—volatile vapor
in the fuel tanks, fuel lines, and engines, he says.
▪ Follow the same hazmat policies and procedures you use in
forward logistics in your reverse logistics operations. All of the
legal and safety requirements that apply to outbound shipments also apply to returns. That includes documentation,
labeling, packaging, transportation, mitigation and safety
plans, and training, Anderson says. Make sure the returned-goods areas of facilities have the necessary safety equipment, and that insurance coverage reflects these hazmat-related activities and conditions, Jaffin advises.
▪ Train the right people. Experts recommend that anybody
who could be called on to handle returned consumer
goods, whether at a customer service desk, in a stockroom,
in transportation, or at the warehouse or returns center,
receive job-appropriate hazmat safety training.
For more information …
Here are some resources for information on reverse logistics for hazardous products.
▪ The Council on Safe Transportation of Hazardous
Articles (COSTHA), an industry association that promotes
regulatory compliance and safety, has launched a reverse
logistics initiative and is working with retailers and government agencies to improve awareness, safe handling,
and regulatory compliance. The group’s recommendations to the U.S. Department of Transportation are available on its website, www.costha.com.
▪ The American Public University, an online educational
institution, and its associated American Military University
periodically offer courses on reverse logistics, including
one for hazardous materials. For details, visit
www.apu.apus.edu/login/Schedule/byCourse/undergrad/tl
and www.amu.apus.edu/login/Schedule/byCourse/
undergrad/tl.
