Southwest Airlines’ Compliance Management Soars with 3E

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Courtesy of Verisk 3E

Southwest Airlines aims to use its 436 (and growing) colorful planes to safely move over 70 million Customers and 288 million pounds of cargo annually. That cargo and Customer baggage can contain all types of materials in them including clothing, paperwork, birthday presents, food stuffs and many other commercial products. Hazardous Materials (HAZMAT) are not allowed on Southwest Airlines (with limited exceptions) and even when offered on a commercial carrier that does transport hazardous materials, the HAZMAT must be properly classified, packaged, marked, labeled, documented and declared as HAZMAT. Many Airline Customers are unaware of these prohibitions and will inadvertently pack HAZMAT in their baggage or cargo. In an industry where time is of the essence, the airline found its Safety Specialists needing to answer frontline Employee questions quickly and accurately 24-7. The airline considered adding staff but then created an EH&S route that included the services of 3E. It’s been smooth flying ever since.

Background

From its beginnings as a small Texas company, Southwest Airlines has grown to become one of the largest airlines in America. With more than 2,800 flights daily, the airline flies more than 65 million miles annually to 60 cities all across the country.

The mission of Southwest Airlines is dedication to the highest quality of Customer Service delivered with a sense of warmth, friendliness, individual pride and Company Spirit. In other words, says the company, “We are always trying to do the right thing.” It’s led the way to the airline industry’s best cumulative consumer satisfaction record, according to statistics accumulated and published by the U.S. Department of Transportation.
In May 1988, Southwest was the first airline to win the coveted Triple Crown for a month: best on-time record, best baggage handling, and fewest Customer complaints. Since then, it’s won the Triple Crown more than thirty times. FORTUNE magazine has recognized Southwest Airlines in its annual survey of corporate reputations. Among airlines, Southwest came out on top as the most admired airline in the world every year from 1997 to 2003.

Southwest has been listed in the top 10 of FORTUNE’s “Best Places to Work” several times. The company strives to provide Employees with the same concern, respect and caring attitude they are expected to share externally with every Southwest Customer. Along with the millions of passengers, Southwest Airlines annually moves 288 million pounds of mail and cargo in its 436 planes—cargo that sometimes needs to be cleared in the name of Safety.

Challenges

John Andrus, based at Southwest’s Headquarters near Love Field in Dallas, TX, is senior manager of Southwest’s Safety and Environmental services.

“When you identify something in a Customer’s bag that is questionable, literally the clock is ticking,” said Andrus. “We have to very quickly determine if the product is regulated for flight, and whether the Customer can travel with the product. It’s a time sensitive issue.”

Andrus’ responsibilities include working with various departments, including Aircraft Maintenance and Ground Operations, on the issues that arise related to Hazardous Materials compliance with the Department of Transportation (DOT) and OSHA regulations.

Passengers check in or bring various chemicals to the airport ranging from something as simple as a spray starch container to extremely hazardous materials usually associated with chemical labs, such as nitric acid. These materials are regulated as Hazardous Materials and are not allowed to fly on passenger aircraft unless they are properly classified, packaged, marked, labeled and documented- and even then, they must be tendered to an Air Carrier that transports Hazardous Materials for its Customers. By choice, Southwest does not provide HAZMAT transportation for compensation. Southwest Employees may find themselves questioning other cargo items such as transmission parts, to a dentist’s supply of chloroform. The vast majority of issues come from Customers who are unaware of the hazardous nature of the materials they are trying to move about the country.

“It runs the whole gamut. Our Customers bring anything and everything to the airport—chemicals are readily available and often get mixed in with baggage and cargo shipments,” said Andrus. “To assure expedient and accurate recognition Southwest must provide our frontline Employees with a resource to help determine the air travel regulations associated with various materials.”

Southwest provides Hazardous Materials Transportation training to Employees on an annual basis, but “the challenge is that there are so many chemical compounds and products on the market that it’s difficult to know about the hazards associated with all of them. In addition, many of the indicators on the containers are related to OSHA Safety compliance issues versus Department of Transportation issues,” said Andrus. “It can be challenging to determine if a material is regulated or not.”

There are seven full time specialists on the corporate Safety staff, plus multiple Safety representatives in the field covering 60 stations, six reservation centers, plus several maintenance and hangar locations. Prior to contracting with 3E Company, staff pagers would go off all the time. “Anytime field Employees had questions, they called a team member from headquarters or a safety duty pager for guidance,” said Andrus. It put a lot of stress on a relatively small group of people, who sometimes were required to do extensive research to determine the classification of a product.

Southwest considered adding staff to create the 24-hour coverage provided by 3E, but realized it would still have research challenges in obtaining the necessary chemical information quickly.

Solutions

Southwest decided to go with 3E Company and four of its services: 3E MSDS on Demand, Spill Hotline, Poison & Exposure Hotline and Transportation Hotline.

The draw to 3E for Southwest was the company’s speed, price, capabilities, accessibility and quality of service. “The biggest issue for us is the 24-hour availability,” said Andrus. ”We operate across all four time zones. We have to have 24-hour coverage.”

Whether a material is regulated or not is an issue faced daily by a good number of people. Southwest has more than 30,000 Employees, and many are on the front line working with passengers. Clear and quick communication comes into frequent play in these situations, and that’s where the relationship with 3E is particularly valuable as Southwest Employees called 3E just over a thousand times in 2004 for transportation advice.

“In addition to the training we conduct in-house, 3E’s hotline is a valuable resource,” said Andrus. “Employees know what our policy is, but they want a reliable sounding board to make sure they’re doing the right thing. 3E has provided a good outlet for confirmation on regulatory information.”

Also, especially after new homeland security measures have been put in place, it’s important to be able to identify whether a material is hazardous—or not. “Allowing for the transportation as long as it’s a safe, non regulated, product improves our level of Customer satisfaction,” he said. “Every Customer is critical; we appreciate every seat.”

In addition to providing immediate answers, 3E has decreased the number of phone calls to Southwest’s Safety Specialists and Customer Service Coordinators “3E’s database is superior and can provide answers to the frontline in a timely manner,” said Andrus. When Southwest builds a new policy or procedure, it relies on 3E’s broad base of knowledge and familiarity with how other transportation organizations are handling similar situations.

Shortly following September 11, 2001, Southwest added 3E Spill Emergency Response to be prepared in the event that a spill response is needed. While spills are very rare and most often non-hazardous in nature, they happen on occasion. “3E has resources available at a click of a button and will dispatch a clean up team if a spill requires additional resources. That assists us in getting operations back to normal quickly,” said Andrus.

In addition, Southwest has its own internal policy and procedures on the Safe Transportation of Regulated Materials (STORM). 3E has a copy of this resource guide and is able to advise Southwest Employees how a material is treated based on the airline’s internal policy.

“Another benefit 3E provides is regulatory guidance that is more stringent or specific than the DOT HAZMAT regulations,” said Andrus. “In those situations, we can forward information to 3E to work with both regulatory requirements and areas that exceed regulations and give Employees that feedback.”

Results

“It was more cost effective to implement the transportation hotline versus bringing another person on board,” said Andrus. “3E offers greater coverage, better resources and, from a cost-benefit analysis perspective, it was a no brainer and significantly lowered costs.''

Plus, the airline’s frontline Employees’ reaction has been extremely supportive. “3E has given Southwest Airlines a tool, an additional resource that we didn’t have before that allows for a great sounding board for our frontline Employees for information on various materials,” said Andrus. With 3E, we get the right answers, which not only helps us comply with regulations, but also adds an extra measure of Safety.

“If the MSDS is not available, or further research is needed, sometimes we have to use 3E’s information and make recommendations,” said Andrus. “That’s where we really rely on 3E’s expertise.”

Best of all, the vast majority of Southwest’s materials questions are handled within three minutes. “And many times the answer comes even quicker as 3E reiterates what the Employee is expecting to hear,” said Andrus. “In our business, every minute counts and 3E delivers.”

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