Practical EHS Tips, News & Advice. Updated Daily.
We ship empty methyl-ethyl ketone (MEK) containers by truck back to the supplier for refill. Must we classify them as Hazardous Material since the empty containers have only residual amount of MEK left in them, or is there an empty container exemption?
Yesterday we discussed the relationship between labeling under the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HazCom) and the U.S. Department of Transportation’s (DOT) labeling requirements. Today we will offer some placarding tips for shipments of DOT-regulated hazardous materials. Quick Review Placards, like labels, are used to graphically communicate a cargo’s hazard. Generally, […]
The top violation DOT inspectors have found so far in FY 2015 is that packages are not secured in vehicles. At 1,207 violations, this mistake accounted for 8.12% of the total violations. Following at a close second, inspectors have found 1,197 instances when there was no copy of the U.S. DOT registration number in the […]
Civil Penalties With a few exceptions, most violations of the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) hazardous materials regulations (HMRs) carry a civil penalty of up to $75,000 per day per violation for knowingly violating one of the HMRs. If the violation results in death, serious illness, or severe injury to any person or […]
There is much confusion concerning who an offeror is under the Pipeline and Hazardous Materials Safety Administrations (PHMSA) Hazardous Materials Regulations (HMRs). PHMSA has numerous interpretation letters that attempt to clarify this issue for individual scenarios. We found two letters we think are pertinent to help you determine whether you are an offeror under the […]