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.
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 […]
In a new final rule, the Pipeline and Hazardous Materials Safety Administration (PHMSA) is adopting the provisions of 96 special permits (SPs) into its hazardous materials regulations (HMRs).
The Pipeline and Hazardous Materials Safety Administration (PHMSA) recently issued a final rule codifying the provisions of nine special permits for companies that transport certain bulk explosives. What are special permits and what kind of flexibility do they offer for transporting hazardous materials? How is training handled under special permits? How is PHMSA moving toward […]
By Elizabeth Dickinson, JD The “Hazardous Materials: Harmonization with International Standards (RRR)” final rule was issued on January 8, 2015. Voluntary compliance with the new rule began January 1, 2015, with mandatory compliance delayed until January 1, 2016, unless otherwise specified (as it is for numerous provisions).
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?
When are you subject to the U.S. Department of Transportation (DOT) hazardous materials requirements? Some of the more onerous regulations environmental, health, and safety (EHS) managers face are the tangled and confusing Hazardous Materials Regulations (HMR) under DOT’s Pipeline and Hazardous Materials Administration (PHMSA). Yesterday we reviewed PHMSA’s responses to three scenarios concerning hazmat transportation […]
When are you subject to the U.S. Department of Transportation’s (DOT) hazardous materials (hazmat) requirements? Some of the more onerous regulations environmental health and safety managers face are the tangled and confusing Hazardous Materials Regulations (HMRs) under DOT’s Pipeline and Hazardous Materials Administration (PHMSA). Today we’ll tackle hazmat transportation training by reviewing PHMSA’s responses to […]
Problem # 1: Have you crossed the line to hazmat offeror? You’re a hazardous waste generator and you have hired a hazardous waste transporter to pick up your waste and haul it off. You’ve checked everything off your Resource Conservation and Recovery Act (RCRA) checklist and you’re ready for the waste to be out of […]