Question: I understand that the U.S. Department of Transportation (DOT) hazardous material regulations do not require a Class 9 placard for domestic transportation of either non-bulk or bulk shipments but that some shippers decide to attach a placard to their Class 9 domestic hazmat shipment with the applicable UN number even when the placard is not […]
In 1971, the EPA and the Department of Transportation (DOT) issued a joint memorandum to clarify jurisdictional issues related to the regulation of facilities with the potential to discharge oil into the environment. Nearly 50 years later, there is still significant uncertainty about where one agency’s authority ends and the other’s begins.
To placard, or not to placard, that is the question. While it’s a general truth that each person who offers for transportation or transports any hazardous material must comply with applicable placarding requirements, fortunately there are many instances when placarding a shipment of hazardous materials is not required by the U.S. Department of Transportation’s (DOT) […]
Confused? It’s not surprising considering that the U.S. Department of Transportation (DOT) has revised its hazardous material regulations (HMRs) for shipping lithium cells and batteries several times over the past 2 years. The DOT has added Proper Shipping Names and Identification Numbers to the Hazardous Materials Table (HMT) and revised packaging, including labeling, requirements for […]
The U.S. Department of Transportation (DOT) recently finalized efforts to make reverse logistics easier for retailers that have to ship hazardous materials. Yesterday we provided an overview of the new reverse logistics rule. Today we review some specific requirements for those retailers who choose to avail themselves of this new rule’s regulatory flexibility.
Reverse operations just got a nudge forward for retailers. If you manage a retail operation, you are confronted with waste and hazardous materials problems that can be confusing for even the most seasoned manager. The U.S. Department of Transportation (DOT) recently finalized efforts to make reverse logistics easier for retailers that have to ship hazardous […]
Get a group of EHS professionals together and the subject of hazardous materials (hazmat) training will invariably come up. What does the Department of Transportation (DOT) expect? How can you be sure that your training is effective and compliant with the DOT Hazardous Materials Regulations (HMRs)? Today we offer steps for developing a training program […]
According to the U.S. Department of Transportation (DOT), more than one-third of hazardous materials transportation violations involve the failure of employers to provide training or maintain employee training records. In most cases, violations are attributed to failure to provide function-specific training. Aside from providing the required training for loading and unloading cargo tank vehicles, there […]
The U.S. Environmental Protection Agency (EPA) proposed what it calls the Hazardous Waste Generator Improvements on September 25, 2015. An extended comment period closed December 24, 2015. The Agency has received over 230 comments on the proposal. The Advisor reviewed a number of them and will give you the gist of what people are saying […]
Don’t get caught short by a U.S. Department of Transportation (DOT) roadside inspection. In its most recent data for fiscal year (FY) 2016, DOT’s Federal Motor Carrier Safety Administration (FMCSA) had performed 26,570 roadside inspections of trucks targeting compliance with hazardous materials transportation regulations. During these inspections, DOT inspectors found 5,894 violations. The top violation […]