Any company that ships hazardous materials, which includes wastes (i.e., "hazmat") by air can face significant civil or criminal penalties if it violates the hazardous materials regulations (HMRs). Unfortunately, many companies do not fully understand the HMRs or realize that they are subject to Federal Aviation Administration’s (FAA) jurisdiction. Some companies also do not have in place proper hazmat shipping procedures or employee hazmat training.
In 2004, the FAA assessed over $3.7 million in civil penalties for HMR violations. A company is usually first apprised of a potential HMR violation when it receives a telephone call from a shipper or when the company is visited by a seemingly friendly FAA special agent seeking information about a particular shipment. The FAA visit is often followed by a Letter of Investigation (LOI), which requires a response within 10 days. Depending on the relevant facts and the company’s response to the LOI, the FAA may (1) issue a Notice of Proposed
