Are you a retailer, or are you associated with a retailer, that needs to return retail products (that happen to be hazardous materials) to a manufacturer, supplier, or distribution facility? If the answer is no, read no further, but if the answer is yes, shippers of these “return-to-vendor” hazardous materials can now choose to comply with new shipping standards as an alternative to the U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR) that were developed for materials posing a far higher risk to health, safety, and property.
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The Final Rule from the DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) (effective March 31, 2016) defines “reverse logistics” as “the process of offering for transport or transporting by motor vehicle goods from a retail store for return to its manufacturer, supplier, or distribution facility for the purpose of capturing value (e.g., to receive manufacturer’s credit), recall, replacement, recycling, or similar reason.” The Final Rule sets forth simplified requirements for transporting reverse logistics shipments by highway (but not by air, rail or vessel). These new requirements are closely aligned with those for the HMR limited quantity exceptions and, like them, provide relief from HMR labeling and marking, placarding, and specification packaging requirements, and, in most instances, from the need for shipping papers. Training obligations for retail employees preparing reverse logistics shipments have been reduced.