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 […]
In its most recent data, the U.S. Department of Transportation’s (DOT) Federal Motor Carrier Safety Administration (FMCSA) had performed over 154,000 roadside inspections of trucks in 2012 targeting compliance with hazardous materials transportation regulations. During these inspections, DOT inspectors found almost 35,000 violations.
Make a plan. PHMSA suggests the plan include a statement of purpose and the benefits of thorough and regular employee training as appropriate to the job function(s), the company, and its resources. The plan should include specific directions on evaluating the effectiveness of training and directions for completing administrative tasks, such as recordkeeping and scheduling. […]
Notwithstanding the complexity inherent in the phrase closed container, managers must be confident that they understand what must be done with the hazwaste containers at their facilities to ensure that a state or federal inspector will have no doubt that the regulations are being met. Keep in mind that containers in which hazwastes are held […]